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We are writing to inform you that the Mass Bankers Group Insurance Plan has recently updated the Summary Plan Description (SPD) of our benefit plan. An SPD is a document provided to plan participants to explain their rights and benefits under a welfare benefit plan. This document is required by the Employee Retirement Income Security Act of 1974 (ERISA), a federal law that sets minimum standards for employee benefit plans maintained by private-sector employers.
The Department of Labor (DOL), through its Employee Benefits Security Administration (EBSA), enforces most of ERISA's provisions. Violating ERISA can have serious and costly consequences; therefore, we urge you to take immediate action to ensure that employees receive the updated SPD.
Here is a copy of the latest document.
Summary Plan Description Link
Mass Bankers held a webinar on June 25, 2024, to inform member banks about the ERISA compliance requirements and allowable distribution methods with our ERISA Counsel, Howard Kirkpatrick, Partner, Smith & Downey, P.A. The link to the webinar is available on demand for six months.
For more information, please view our recent Overview of ERISA Disclosure Requirements webinar:
The slide deck can be found here.
In summary, under ERISA:
- Newly Covered Participants: Distribute the SPD within 90 days after a participant first becomes covered.
- Ongoing Participants: Provide an updated SPD every five years if there have been material changes or every ten years if there have been no material changes.
Paper Delivery Distribution:
- Hand Delivery: During orientation, welcome packet distribution, or with other new hire documents, this can be done.
- Mail: First-, second-, or third-class mail is acceptable. Ensure the materials are "reasonably calculated to ensure actual receipt" by participants.
Electronic Delivery Distribution:
For Employees with Work-Related Computer Access Integral to Their Job Duties:
- No consent is required.
- Include a notice about the document's significance and the right to request a paper version.
For Employees without Work-Related Computer Access Integral to Their Job Duties:
- Obtain electronic consent before distribution.
- The consent form must demonstrate the individual's ability to access information electronically.
Reminder: Important documents and employee communication materials are hosted on the Mass Bankers Employee Benefits portal. Navigate to this section by visiting our website and clicking on Membership > Bank Members > Employee Benefits.
For questions regarding this memo's contents, contact Chad Pook at cpook@massbankers.org or 617-502-3810.
Kind regards,
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