The Internal Revenue Service and U.S. Department of Labor recently issued guidance on various aspects of the Consolidated Appropriations Act of 2023, commonly referred to as SECURE 2.0. Below is a summary of key provisions...more
The IRS issued Notice 2024-2 (Notice), which provides guidance in a question and answer format concerning certain provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0). The following is a brief overview of key provisions in...more
Approximately one year after Congress enacted the SECURE 2.0 Act of 2022 (“SECURE 2.0”), the IRS issued Notice 2024-02, which addresses SECURE 2.0 implementation issues and extends the plan amendment deadline. Although...more
Warner’s Employee Benefits Practice Group is pleased to present a webinar series on significant new retirement plan legislation, the SECURE Act 2.0. While we expect implementing the new law to take several years, some...more
The President signed the Consolidated Appropriations Act, which included SECURE Act 2.0, on December 29, 2022—the “enactment date”. SECURE Act 2.0 has over 90 provisions, some major and some minor. One of the most...more
Besides ensuring the federal government remains fully funded, President Biden’s signature Thursday on the Continuing Appropriations Act, 2023 (CAA 23) contains several provisions that will directly impact health and...more
Congress has passed long-awaited retirement legislation under Division T of the Consolidated Appropriations Act of 2023 known as the SECURE 2.0 Act of 2022 (the “Act”), which awaits the President’s signature. The Act is a...more
Plan sponsors and other administrators of eligible retirement plans must ensure that these plans are operated properly in accordance with the applicable requirements of the Internal Revenue Code, including the applicable plan...more
Colorado is just another state that is offering a payroll deduction IRA program, forcing businesses to offer this program if they have five or more employees. I’m in favor of anything that offers increased retirement plan...more
People are flawed, except for saints and Popes. One of my many flaws is that I enjoy being right. I love predicting things and being right (such as the end of revenue sharing, and a former employer going out of business...more
When I was at college, I was very involved politically. Someone I met my freshman year at Stony Brook and a friend to this day was someone I met through these political circles and has made a name for himself as a state party...more
There are many choices in developing options for a 401(k) plan and certain features such as automatic enrollment and Roth 401(k) have only been law since 2006. 14 years later, it would not be surprising that the percentage of...more
The SECURE Act* makes significant changes to employer-sponsored retirement plans and many of the changes take effect immediately. Highlights of the provisions of the SECURE Act that are effective in 2020 include: -...more
Hundreds of articles have been published over the last two weeks about the SECURE Act (“Act”), which was signed into law in late December as part of the most recent budget bill. As you are certainly aware by now, the Act...more
On March 28, 2019, New Jersey became the sixth state to pass legislation requiring that certain employers offer to employees a state-sponsored individual retirement account (“IRA”) program with automatic enrollment and...more
The U.S. Department of Labor (the "DOL") issued an Information Letter on December 8, 2018 (the “Letter”) confirming that state laws requiring written consent before amounts are withheld from employees’ wages to contribute to...more
As we previously reported, Illinois is implementing the Illinois Secure Choice Savings Program (Program), under which private sector workers in Illinois who do not have access to an employer-sponsored retirement plan will be...more
When automatic enrollment was first introduced, it was introduced as a negative election and I thought it was just a cheap gimmick by an employer to help their actual deferral percentage test because all money from the...more
As 2017 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered...more
Concepts You May Not Be Aware Of As A 401(k) Plan Sponsor. Quite a few things out there. As a child, I was never taught the birds and the bees. I was actually handed some cartoon book from my parents when I was...more
The Plan Sponsor Council of America’s newest annual report shows that in 2015, 25.5% of small 401(k) plans offer automatic enrollment. In their survey, small plans are considered plans with less than 50 participants....more
Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more
The Bipartisan Budget Act includes the following important employee-benefit related provisions: - It repeals the automatic enrollment mandate of the Affordable Care Act. Under the ACA, employers with more than 200...more