This guide outlines the more significant components of the recently released final rule on Department of Labor (DOL) Form T-1, Required for Trusts Where a Labor Organization Is Interested. The DOL released proposed rulemaking on May 30, 2019 which was open for public opinion through July 29, 2019. The DOL received 33 substantive public comments including those submitted by Withum. On March 6, 2020, the DOL issued the final rule which is effective April 6, 2020.
The proposed rulemaking looked very familiar to rulemaking initiated in 2002. The earlier rulemaking went through a series of legal challenges but was made final effective January 1, 2009. However, that rule was further delayed and ultimately rescinded on December 1, 2010.
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