PROFESSOR SAMANTHA PRINCE AND RESEARCH ASSISTANT ALYSSA BOOB FILE PUBLIC COMMENTS ON EFFECTIVENESS OF PUBLIC DISCLOSURES WITH THE U.S. DEPARTMENT OF TREASURY
May 2024 — Professor Samantha J. Prince, joined by a member of her research team, Alyssa Boob ’25, authored a public comment responding to the Department of Treasury’s, Department of Labor’s and the PBGC’s request for information to improve the effectiveness of existing reporting and disclosure requirements for certain Employee Retirement Income Security Act of 1974 (ERISA) governed and Internal Revenue Code qualified plans.
Their public comment drew on Professor Prince’s scholarship in the employee benefits space to inform the agencies as to how lack of reliable, easy-to-find, and understandable 401(k) plan benefits disclosure exacerbates retirement insecurity. The comment recommends requiring detailed disclosure of a select list of 401(k) plan features on easily accessible platforms, such as company websites and employer job postings. In its discussion of a wide range of impacted stakeholders, the comment highlights how detailed disclosure can normalize the value of retirement benefits and even nudge or shame employers into providing better benefits. The comment also illuminates how such disclosure assists plan participants and jobseekers in making informed employment and retirement planning decisions.
This comment builds off research illustrated in Professor Prince’s recent scholarship: Benefits Transparency and Megacompany Employee Churn Meets 401(k) Vesting Schedules: A Sabotage on Workers’ Retirement Wealth.
The comment was submitted to the Employee Benefits Security Administration of the Department of Labor on April 22, 2024.
Professor Samantha Prince is an Assistant Professor of Law and Director of Legal Analysis & Writing at Dickinson Law. She has a Master of Laws in Taxation from Georgetown University Law Center and was a partner in a regional law firm where she handled transactional matters that ranged from an initial public offering to regular representation of a publicly-traded company. Most of her clients were small to medium sized businesses and entrepreneurs, including start-ups. A significant part of her practice was in employee benefits including retirement plan design and operation. An expert in entrepreneurship law, she established the Dickinson Law entrepreneurship program, is an advisor for the Entrepreneurship Law Certificate that is available to students, and is the founder and moderator of the Inside Entrepreneurship Law blog. Her research mainly comprises the changing world of work.