The Employee Benefits Security Administration’s (EBSA) April 2026 Field Assistance Bulletin marks a pivotal change in Department of Labor enforcement for ESOPs. The new guiding principles and enforcement priorities are designed to curb aggressive, unpredictable actions by the DOL, especially around ESOP valuation, and to ensure fair treatment for plan fiduciaries. These changes prioritize targeting only the most serious violations, require advance notice and clarity for regulated parties, and mandate leadership oversight for significant enforcement initiatives. This edition of Thinking ESOPs provides a detailed analysis of EBSA’s historical approach, the impact of these new priorities, and practical takeaways for ESOP stakeholders navigating this evolving regulatory landscape.
To view the full alert, visit the Faegre Drinker website.
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