BENEFITS DIGEST

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A publication of The Inner Firm

Monday, August 31, 2026

№ 42

22 items · ~4 min read

Court Decisions (1)·Retirement Plans (6)·Health & Welfare (6)·Case Commentary (4)·Executive Compensation (1)·Also Noteworthy (4)

The One Thing

Congressional standardization efforts on rollovers, both SECURE 2.0's mandate for sample forms and the IRS's new rollover guidance, signal that plan-to-plan portability is shifting from discretionary administrator choice toward prescribed uniformity. As the IRS and DOL jointly tighten procedures and the DOL defaults to e-delivery, advisers should expect less flexibility in rollover mechanics and greater compliance risk for plans that deviate from emerging federal templates.

Court Decisions (1)

Andrew Halloran v. Unum Life Ins. Co. of America
Court of Appeals for the Eighth Circuit 2026-08-28

Insurer properly terminated long-term disability benefits where the treating physician's assessments established the claimant could perform sedentary work, satisfying the plan's "any gainful occupation" standard.

Retirement Plans (6)

IRS Issues New Guidance on Rollovers
Groom Law Group 2026-08-28

Under current rollover regulations, plan administrators may prescribe any reasonable procedure for a distributee to elect a direct rollover and may impose reasonable requirements for a distributee to provide information or documentation to facilitate the rollover.

IRS Proposes Rules for Trump Account Investment Options: Considerations for Employers
Mayer Brown 2026-08-28

Proposed regulations under section 530A would confine Trump Account investments during the growth period to unleveraged index funds that track broad U.S. equity benchmarks and charge annual fees of 0.1% or less, excluding actively managed, sector, and ESG-labeled funds. Employers contributing to the accounts bear no fiduciary duty for investment selection but should confirm contributions flow to compliant accounts. Comments are due October 20.

The Employee Complaint You Should Never Ignore
The Rosenbaum Law Firm P.C · via JD Supra 2026-08-28

Most employee complaints involve relatively minor issues. Questions about vacation time, payroll, benefits, or workplace policies are common in every organization.

Health & Welfare (6)

DOL Proposes E-Delivery as Default Option for Employers
Hall Benefits Law 2026-08-28

The U.S. Department of Labor has drafted a regulation designed to facilitate employers' use of electronic delivery systems as the default option when dealing with the Employee Benefits Security Administration and other federal agencies.

Case Commentary (4)

ERISA Long-Term Disability Denial Upheld: Eighth Circuit Affirms Unum Termination Where Treating Doctor's Own Records Supported Sedentary Work
Roberts Disability Law 2026-08-29

In Halloran v. Unum Life Insurance Company of America, No. 25-2550, 2026 WL 2545315 (8th Cir. Aug. 28, 2026), a panel of Chief Judge Colloton and Circuit Judges Gruender and Kobes, with Judge Kobes writing, affirmed the termination of a claimant's ERISA long-term disability benefits. The slip opinion appears in Court Decisions above.

Sixth Circuit Reaffirms ERISA Preempts State Law Claims Arising From Benefits Verification Calls
Mayer Brown 2026-08-28

In Laurel Hill Management Services v. La-Z-Boy, the Sixth Circuit held that ERISA preempts out-of-network providers' negligent-misrepresentation and promissory-estoppel claims premised on oral assurances given during benefits-verification calls, reaffirming its 1991 Cromwell precedent. Mayer Brown flags a developing circuit split and counsels administrators to keep call recordings and rely on the written plan when providers claim they relied on the phone call.

Fifth Circuit Affirms Summary Judgment for MetLife on De Novo Review, Holding LTD Claimant Was Not Totally Disabled and Declining to Resolve Choice-of-Law Dispute Over Dueling State Bans on Delegation Clauses
Roberts Disability Law 2026-08-28

In Grice v. Metropolitan Life Insurance Company, No. 25-50566, 2026 WL 2519457 (5th Cir. Aug. 26, 2026), a per curiam opinion, the Fifth Circuit affirmed the district court's grant of summary judgment to Metropolitan Life Insurance Company in this ERISA action challenging the denial of long-term disability benefits.

Executive Compensation (1)

SEC Submits Executive Compensation Disclosure Rulemaking for OIRA Review
Goodwin · via JD Supra 2026-08-29

On August 26, 2026, the SEC submitted a rule proposal titled "Executive Compensation Disclosure Reform" to the White House's Office of Information and Regulatory Affairs. SEC rulemaking initiatives under review by OIRA are listed on a dashboard until the review is completed.

Also Noteworthy (4)