Alternative Reporting Methods
for Apprenticeship and Training Plans and Top Hat Plans
Extension without change of a currently approved collection
No
Regular
05/28/2025
Requested
Previously Approved
36 Months From Approved
08/31/2025
86
1,800
14
300
0
0
Section 2520.104-22 provides an
exemption to the reporting and provision of part 1 of title I of
ERISA for employee welfare benefit plans that provide exclusively
apprenticeship and training benefits if the plan administrator
meets the following requirements: (1) Files a notice with the
Secretary that provides the name of the plan, the plan sponsor's
Employer Identification Number, the plan administrator's name, and
the name and location of an office or person from whom interested
individuals can obtain certain info about courses offered by the
plan; and (2) takes steps reasonably designed to ensure that the
information required to be contained in the notice is disclosed to
employees of employers contribution to the plan who may be eligible
to enroll in any course of study sponsored or establish by the
plan; (3) and makes the notice available to employees upon request.
Under 2520.14-23, the Department provides an alternative method of
compliance with the reporting and disclosure of Title I of ERISA
for unfunded or insured plan established for a select group of
management of highly compensated employees (i.e., top hat plans).
In order to satisfy the alternative method of compliance, the plan
administrator must file a statement with the Secretary of Labor
that includes the name and address of the employer, the employer
EIN, a declaration that the employer maintains a plan or plans
primarily for the purpose of providing deferred compensation for a
select group of management or highly compensated employees, and a
statement of the number of such plans and the employees covered by
each. Plan documents must be made available to the Secretary upon
request, and only one statement needs to be filed for each employer
maintaining one or more of the plans. The 2019 final rule requires
electronic filing with the Secretary through EBSA's website in
accordance with instructions published by the Department.
US Code:
29
USC 1023 Name of Law: Employee Retirement Income Security Act
of 1974
The Department has updated the
number of filings and the current wage rate. In the previous
information collection, the cost included paper filings. However,
filings are now required to be submitted electronically through the
Department’s system, resulting in a decrease in the burden to file.
The number of respondents has decreased by 1,714. The hour burden
has decreased by 286 hours.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
1210-0153 Apprenticeship and Training Plan Notices ss 5-2-2025.docx
Alternative Reporting Method