Defined Contribution Plans

News & Analysis as of

More and Less Expensive Options for Retirement Plan Corrections: New IRS Guidance on EPCRS

In This Issue: - Rev. Proc. 2015-27 - Rev. Proc. 2015-28 - For More Information - Excerpt from Rev. Proc. 2015-27: Rev. Proc. 2015-27 may be used beginning March 27, 2015 and is effective July 1,...more

DOL Provides Greater Flexibility for Distribution of Annual Participant Fee Disclosure Effective Immediately

The U.S. Department of Labor (DOL) recently issued guidance providing defined contribution plan administrators with additional flexibility on the timing requirements for distribution of the required annual fee disclosure to...more

Two-Year Preapproved Defined Contribution Plan Window is Still Open

Retirement plan vendors sponsoring defined contribution plan documents approved by the Internal Revenue Service (IRS) have begun issuing packages containing the new IRS-approved version of those documents—reflecting the...more

DOL Provides More Timing Flexibility for Annual Participant Investment Disclosures

As promised, on March 19, 2015, the U.S. Department of Labor (DOL) published guidance that would provide more flexibility in the timing of the annual plan and investment disclosures for participant-directed defined...more

White House Budget Recommends Elimination of in-Plan Roth Rollovers of After-Tax Contributions

As reported, the Internal Revenue Code currently permits a plan design that allows plan participants to convert non-Roth after-tax contributions to Roth contributions through in-plan Roth rollovers. This design would allow a...more

IRS Required Restatement of Retirement Plan

Every six years, the Internal Revenue Service requires that all pre-approved volume submitter and prototype retirement plan documents be updated and restated. The current restatement period will incorporate provisions from...more

Significant Multiemployer and Single Employer Benefit Rule Changes Take Effect

On December 16, 2014, President Obama signed into law the $1.1 trillion Consolidated and Further Continuing Appropriations Act of 2015 (Appropriations Act), which includes some significant changes to the rules governing...more

ERISA Section 4062(e) Significantly Reformed Effective December 16, 2014

On December 16, 2014, President Obama signed into law the Consolidated and Further Continuing Appropriations Act, which contains provisions that significantly reform ERISA Section 4062(e). The new law is meant to ensure that...more

Monthly Benefits Update - December 2014

Illinois Becomes the First State to Require Automatic Retirement Savings Program for Workers Without Access to a Workplace Retirement Plan - On January 5, 2015, outgoing Governor Quinn signed landmark legislation that...more

More news on the ORPP

On December 18th, 2014, the Ontario government released its consultation paper on the new Ontario Retirement Pension Plan (ORPP). What’s important to note is that the government’s “preferred approach” is to impose the...more

Final regulations on qualified longevity annuity contracts

An ongoing focus for the IRS and the DOL has been trying to ensure that individuals have a regular stream of income for the duration of their lives. In connection with this goal, in July of this year, the IRS released final...more

PBGC Issues Final Regulations Regarding Rollovers from Defined Contribution Plans to Pension Plans

The PBGC has recently initiated efforts to enhance retirement security for Americans by promoting lifetime income options (i.e., annuitized benefits). As part of these efforts, as well as those of the IRS and U.S. Department...more

IRS and DOL Issue Guidance on Including Deferred Annuities in Target Date Funds

Guidance addresses nondiscrimination, qualified default investment alternative, and annuity safe harbor rules. On October 24, the Internal Revenue Service (IRS) and the U.S. Department of Labor (DOL) each issued...more

New IRS Rules on Direct Rollovers of Taxable and Non-Taxable Amounts Require Changes to Defined Contribution Plan Administration...

The Internal Revenue Service (IRS) recently released guidance allowing participants to allocate the taxable and non-taxable portions of a single distribution from a defined contribution retirement plan into separate accounts....more

DOL Issues Guidance on Missing Participants in Terminated Plans - The Guidance Focuses on How to Search for Missing Participants...

The Department of Labor (DOL) Field Assistance Bulletin (FAB) 2014-01 provides guidance on (1) how fiduciaries should go about searching for missing participants or beneficiaries in terminated defined contribution plans; and...more

IRS Increases Maximum Employee Contribution to Health Care FSAs for 2015

The IRS announced yesterday that the maximum annual employee contribution to a health care flexible spending account plan is increasing by $50 to $2,550 for 2015 (up from the $2,500 limit that has applied since 2013)....more

IRS and DOL Issue Favorable Guidance on Lifetime Income Provided Through Target Date Funds in Retirement Plans

On October 23 and 24, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued coordinated guidance on lifetime income provided through target date funds held by retirement plans. According to an...more

Treasury Department and IRS Allow Lifetime Annuity Contracts as Investments by Target Date Funds

Last week, the IRS issued Notice 2014-66, providing a special rule that allows defined contribution pension plans to give participants a lifetime annuity income option by offering target date funds ("TDFs") that include...more

IRS Announces 2015 COLA Increases for Dollar Limitations on Benefits and Contributions

On October 23, 2014 the Internal Revenue Service (IRS) announced the cost-of-living adjustments impacting tax-qualified pension plans for 2015. The increase in the cost-of-living index met the statutory thresholds that...more

IRS Issues 2015 HSA Contribution Limits

Each year, the IRS issues contribution limits for Health Savings Accounts for the upcoming year. The 2015 contribution limits are outlined below....more

Ninth Circuit Joins First Circuit in Finding that the Elimination of a Pension Transfer Option does not Violate ERISA's...

In Anderson v. DHL Retirement Pension Plan, the Ninth Circuit followed the First Circuit in finding that the elimination of the right to transfer an account balance from a defined contribution plan to a defined benefit plan...more

Missing Participants in Your Terminated Defined Contribution Retirement Plan? The DOL Has Issued Guidance to Help You

Background - The U.S. Department of Labor ("DOL") recently issued Field Assistance Bulletin 2014-01 (the "FAB"), which provides guidance about how fiduciaries of terminated defined contribution retirement plans can...more

Does your Company’s Retirement Plan Need to be Restated?

Between May 1, 2014 and April 30, 2016, all pre-approved defined contribution plans (e.g. most 401(k), profit sharing, money purchase and other qualified plans) must be restated to reflect the provisions of the Pension...more

Where Oh Where Could They Be? Finding Missing Participants Under the New DOL Guidance

The U.S. Department of Labor (DOL) has issued updated guidance on locating missing participants in a terminated defined contribution plan. The guidance reflects the discontinuance of the IRS and SSA letter forwarding...more

IRS Seeking Comments on Business Hardship Rules for Safe Harbor Defined Contribution Plans

The IRS is seeking comments on rules that permit sponsors of 401(k) plans to reduce or suspend safe harbor contributions in the middle of the plan year. As we wrote in a previous alert, under rules issued in November of 2013,...more

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