U.S. Department of Labor Signals Shift in ERISA Enforcement Priorities in FAB 2026-01

On April 14, 2026, the U.S. Department of Labor (the “DOL”) issued Field Assistance Bulletin 2026-01 (“FAB 2026-01”), outlining updated enforcement priorities for the Employee Benefits Security Administration (“EBSA”). The guidance signals a more focused and process-oriented enforcement approach, emphasizing core fiduciary duties, limits on “regulation through enforcement,” and increased scrutiny of certain plan practices.... By: Snell & Wilmer