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DOL Issues Model Annual Funding Notices Reflecting SECURE 2.0 Changes

On April 3, 2025, the US Department of Labor (“DOL”) released Field Assistance Bulletin No. 2025-02 (“FAB 2025-02”), which provides guidance regarding new content requirements that apply to pension plans’ annual funding...more

DOL Finalizes VFC Program Self-Correction Component for Late Deposits and Loan Failures

On January 14, 2025, the US Department of Labor (“DOL”) released a final regulation revising its Voluntary Fiduciary Correction (“VFC”) Program and related prohibited transaction exemption (“PTE”) 2002-51 to add a...more

IRS Issues Guidance on Overpayment Correction Rules under SECURE 2.0

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) made significant changes to the rules governing the correction of overpayments from employer sponsored retirement plans, including 401(k) plans, 403(b) plans, and defined benefit...more

IRS Releases SECURE 2.0 Guidance; Extends Amendment Deadlines

On December 20, 2023, the Internal Revenue Service (“IRS”) issued Notice 2024-2, which provides guidance on some important provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”). Notice 2024-2, is not comprehensive guidance...more

IRS Proposes Long-Term Part-Time Rule

The IRS and the Department of the Treasury published a proposed regulation on November 27, 2023, clarifying certain points relating to the coverage of long-term part-time employees (“LTPTE”) in defined contribution plans...more

SECURE 2.0: A Deeper Dive into the Provisions Affecting Defined Benefit Pension Plans

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) includes a number of changes that affect defined benefit pension plans. This includes new reporting and disclosure requirements in connection with offering a lump sum window and...more

IRS Delays SECURE 2.0 Roth Catch-Up Requirement

Among the most challenging components of the SECURE 2.0 Act of 2022 (SECURE 2.0) for plan sponsors is a requirement that any catch-up contributions for high wage earners can only be made on a Roth (after-tax) basis beginning...more

IRS Issues SECURE 2.0 Guidance on Expanded Availability of Self-Correction

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) greatly expands the availability of self-correction of compliance failures involving employer retirement plans and IRAs. On May 25, 2023, the IRS issued Notice 2023-43, which...more

SECURE 2.0 Required Minimum Distributions and DC Plan Lifetime Income

The SECURE 2.0 Act of 2022 (“SECURE 2.0”), like the original SECURE Act of 2019 (“SECURE 1.0”), made significant changes to the required minimum distribution (“RMD”) rules. The SECURE 2.0 changes generally allow for...more

SECURE 2.0 Upends IRS Correction Procedure

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) is one of the most significant pieces of retirement plan legislation in many years. (See our high level summary of SECURE 2.0 at link.) Among other things, SECURE 2.0 brings sweeping...more

IRS Extends CARES and CAA Amendment Deadlines

As discussed in our prior blog post, the IRS previously extended the deadline to adopt most plan amendments relating to the Setting Every Community Up for Retirement Act of 2019 (“Secure Act”), the Bipartisan American Miners...more

5 Key Takeaways | Establishing Tax Qualified Retirement Plans [Video]

Kilpatrick Townsend's Sterling Perkinson and Peter Daines recently presented "Establishing Tax Qualified Retirement Plans." These are the 5 key takeaways from their presentation....more

Secure Act 2.0 – Summary of Key Provisions

The House and Senate are moving forward on several versions of legislation, which are collectively known as the “Secure Act 2.0” because they would build off of the Secure Act, the last major retirement plan legislation...more

Regulations Proposed on SECURE Act RMD Changes

The IRS released proposed regulations today that implement certain SECURE Act changes to the rules governing required minimum distributions (“RMDs”) from qualified retirement plans, 403(b) plans, IRAs, and certain other...more

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