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Transition Relief for Certain RMDs before 2023

The IRS has published transitional relief in Notice 2022-53 (the “Notice”) for required minimum distributions (“RMDs”) to certain beneficiaries who may not have anticipated the IRS’s interpretation of the RMD rules announced...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

Brokerage Window Fiduciary Duties in Light of DOL Cryptocurrency Guidance

The DOL’s (DOL) recent warning that it is launching a new investigative program aimed at plans that offer investments in cryptocurrency and related products, including through brokerage windows, sent shockwaves through the...more

401(k) Plan Investments: ESG, Private Equity and Cryptocurrency

Many employers desire to offer innovative investments in their 401(k) plans as a way to enhance the plan’s value, attract talent and appeal to a younger workforce. But decisions regarding investment options are subject to...more

Supreme Court Affirms Fiduciaries’ Responsibility for Each Investment Option

The Supreme Court today issued a succinct, unanimous opinion in Hughes v. Northwestern University. The Court affirmed that fiduciaries of retirement plans (including university 403(b) plans like Northwestern’s as well as the...more

Build Back Better Act Threatens Backdoor Roth Conversions

The Build Back Better Act, the “social infrastructure” bill that was approved by the House of Representatives on November 19, 2021, includes new restrictions on so-called “backdoor Roth” conversions. Accordingly, if the...more

Participation of Long-Term, Part-Time Employees in 401(k) Plans

One of the goals of the Setting Every Community Up for Retirement Enhancement Act (the “SECURE Act”), which was passed in late 2019, was to increase participation in 401(k) plans. In this regard, Section 112 of the SECURE...more

DOL Clarifies Timing of Lifetime Income Disclosures in Benefit Statements

Last year the Department of Labor (DOL) issued an interim final rule regarding the SECURE Act’s lifetime income disclosures, which require benefit statements to express a participant’s account balance as a single life annuity...more

DOL Issues Guidance for Including Lifetime Income Disclosures in Defined Contribution Benefit Plan Statements

As required by the SECURE Act of 2019, the U.S. Department of Labor (DOL) published an interim final rule requiring plan administrators of individual account plans (including 401(k) plans, 403(b) plans and other defined...more

Fiduciary Rule 2.0: What You Need to Know About the DOL's New Fiduciary Rule

On June 29, 2020, the Department of Labor (“DOL”) announced1 its new approach to the standards for financial institutions and investment professionals who provide investment advice on a nondiscretionary basis to 401(k) plans,...more

IRS Allows for Remote Notarizations for Retirement Plan Withdrawals

Congress acted swiftly to allow participants greater access to their retirement plan funds through special withdrawal and loan provisions in recognition of the financial impacts of the COVID-19 pandemic. See our blog post on...more

CARES Act - Provisions Applicable to Tax-Qualified Retirement Plans

Emergency Withdrawals. Participants in defined contribution plans (profit sharing, 401(k), and 403(b) plans) could access their retirement savings now if plans are amended to allow coronavirus-related withdrawals....more

Changes to Minimum Distribution Rules

The Secure Act is the most significant legislation affecting qualified retirement plans in more than a decade. (See our prior post summarizing key changes.) Changes to the minimum distribution rules are among the most...more

Congress Passes Secure Act with Significant Changes to Retirement Plans

The Setting Every Community Up for Retirement Act of 2019, or "Secure Act", has been passed by Congress as part of a large government funding bill. Upon being signed into law by the President, the Secure Act will be the most...more

Funding 401(k) Corrective Contributions with Forfeitures

The IRS has issued final regulations allowing forfeitures under a 401(k) plan to be used to fund corrective contributions. IRS rules require forfeitures under a plan to be used as soon as possible to pay administrative...more

Final Tax Legislation – Provisions Affecting 401(k) Plans

While tax reform proposals considered by Congress were rumored to include major changes like significantly lower limits on pre-tax contributions to 401(k) plans, the separate bills passed by the House and Senate included more...more

DOL Finalizes 18-Month Extension of Fiduciary Rule Transition Period

The Department of Labor (DOL) finalized the Fiduciary Rule’s transition period extension from January 1, 2018 to July 1, 2019, as it had previously announced in August. The DOL reported that it has not yet completed the...more

Tax Reform’s Impact on Qualified Retirement Plans

House Republicans this week released much-anticipated legislation to reform individual and corporate income taxation. Titled the “Tax Cuts and Jobs Act,” the legislation proposes substantial revisions to the Internal Revenue...more

2018 Benefit Limits

Retirement Plan Limits - The IRS updated very few of the retirement plan limits effective for the plan year that begins on or after January 1, 2018. Social Security Tax and Wage Base - For calendar year 2018, the...more

IRS Allows Easier Access to Retirement Funds for Hurricane Harvey Victims

The IRS issued an announcement that may allow participants and beneficiaries of 401(k) plans or 403(b) plans that have been affected by Hurricane Harvey easier access to their retirement funds until January 31,...more

DOL Extends Fiduciary Rule Transition Period, Issues FAQs on Fee Disclosures

Transition Period Extension - In an August 9th court filing, the DOL announced it will extend the transition period for three prohibited transaction exemptions relating to the fiduciary investment advice rule (the...more

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