By this point, most people in the employee benefits space have heard about the MOVEit and Retirement Clearing House (RCH) cyber incidents, which could directly impact employers’ benefit plans. The MOVEit file transfer...more
Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019 (“SECURE 1.0”), significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the...more
On July 26, 2021, the U.S. Internal Revenue Service (“IRS”) issued Notice 2021-46, providing additional guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) and premium assistance and tax credit...more
Seyfarth Synopsis: Electronic signatures may be the wave of the future for the IRS, and are more necessary now as a result of the remote work environment. The IRS issued some recent guidance, allowing two authorization forms...more
Seyfarth Synopsis: The IRS has extended the remote notarization relief that gives plans and participants greater flexibility for participant elections, including spousal consents, that must be signed in person and witnessed...more
Seyfarth Synopsis: In response to immediate requests from participants for tax-favored coronavirus-related distributions (“CV Distributions”) and loans, as described in more detail in our prior post, and participants who want...more
Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more
Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more
Seyfarth Synopsis: On Tuesday, shortly after the IRS extended deadline relief to employee benefit plans, the U.S. Department of Labor granted its own relief for a number of deadlines related to the administration of employee...more
On April 19, 2019, the IRS issued Rev. Proc. 2019-19, updating its Employee Plans Compliance Resolution System (“EPCRS”) which permits retirement plan sponsors and administrators to correct compliance failures that may...more
In September, the IRS issued Rev. Proc. 2018-52 updating the IRS correction program, i.e., Employee Plans Compliance Resolution System (“EPCRS”). EPCRS allows retirement plan sponsors to correct compliance failures that may...more
On January 29, 2016, the IRS issued Notice 2016-16, which provides much-needed guidance and flexibility for mid-year amendments to safe harbor plans. The notice provides that a mid-year amendment either to a safe harbor...more