DOL Final Regulations on Shareholder Rights in ERISA Plans: New Mandates for Plan Sponsors and Asset Managers

Proxy Votes, Safe Harbors, Increased Burden Under Investment Duties Regulation, Pooled Vehicles of Multiple Employee Benefit Plans

Recording of a 90-minute premium CLE video webinar with Q&A

Conducted on Wednesday, March 10, 2021

Recorded event now available

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Course Materials

This CLE course will guide employee benefits counsel and fiduciaries on the implications of the recent final DOL rule for the exercise of shareholder rights for benefit plans. The panel will discuss key provisions of the rule and potential implications to fiduciaries, ERISA plans and other stakeholders. The panel will provide a critical analysis of proxy votes, investment duty regulations, issues with pooled investment vehicles, such as collective investment trusts, and other items of concern under the rule.


On Dec. 11, 2020, the DOL issued a final rule establishing a regulatory framework for private employee benefit plans' fiduciaries when they exercise shareholder rights, including proxy voting. Plan sponsors and fund managers must ensure compliance with the new rule and alignment with retirees' best interests.

The DOL final rule addresses applying certain ERISA fiduciary duties to the exercise of proxy voting and other shareholder rights for benefit plans. The rule clarifies that fiduciaries are not obligated to vote every proxy or exercise every shareholder right.

Fiduciaries must act solely for the plan's economic interests, considering the costs to the plan, which further solidifies the DOL's shift from a rules-based or prescriptive approach to a principles-based approach to proxy voting guidance.

Listen as our panel discusses the final rule on proxy voting and other shareholder rights, as well as offers strategies and best practices for ERISA counsel and fiduciaries.



  1. Overview of the final DOL rule for proxy votes and other shareholder powers
  2. Fiduciary obligations of plan sponsors and investment managers
  3. Challenges for managers of pooled investment vehicles
  4. Best practices for plan sponsors and investment managers


The panel will review these and other key issues:

  • What are the key provisions of DOL's final rule for proxy voting and other shareholder rights?
  • What is required of plan sponsors and investment managers under the rule?
  • What is the impact on the fiduciary obligations of plan sponsors and investment managers?
  • What issues arise for investment managers for pooled investment vehicles?


Sichel, Robert
Robert L. Sichel

K&L Gates

Mr. Sichel is a partner in the firm’s New York office, where he is a member of the Investment Management practice...  |  Read More

Zanotti, Kristina
Kristina M. Zanotti

K&L Gates

Ms. Zanotti is a partner in the investment management practice group, concentrating in the ERISA fiduciary and...  |  Read More

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