On May 16, 2025, the SEC’s Division of Corporation Finance issued new and revised Compliance and Disclosure Interpretations (C&DIs) regarding public utility securitizations. These C&DIs were issued following a no-action letter issued to the Securities Industry and Financial Markets Association that clarified certain ambiguities related to Rule 192 under the Securities Act of 1933, the securitization conflicts-of-interest rule.

While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.