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DOL Requires Disclosure of Audio Recordings under ERISA Claims Procedure

The Department of Labor (DOL) recently issued Information Letter 06-14-2021 in which the DOL opined that audio recordings of a conversation between a participant and plan representative, and transcripts of the recordings, are subject to disclosure during the claims adjudication process under ERISA Section 503. The DOL’s position is not surprising based upon the transparency theme that has dominated recent legislation.

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