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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

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

5 Key Takeaways - Establishing Tax-Qualified Retirement Plans

Kilpatrick Townsend attorneys Sterling Perkinson and Peter Daines presented a Strafford webinar focused on the challenges and considerations facing a company in setting up tax-qualified retirement plans. The presentation also...more

Amendment Deadlines Extended for SECURE Act and 2020 Minimum Distribution Relief

The IRS has extended plan amendment deadlines to comply with the Setting Every Community Up for Retirement Act of 2019 (“Secure Act”) and the relief for 2020 required minimum distributions (RMDs) under the Coronavirus Aid,...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

IRS Announces Pre-Audit Compliance Pilot Program

On June 3, 2022, the IRS announced a new pre-audit compliance program for retirement plans beginning immediately in June 2022 (the “Pilot Program”). Under the Pilot Program, the IRS will send a pre-audit letter to plan...more

Understanding the Impact of Russian Sanctions on Retirement Plans

On February 24, 2022, Russia began a large-scale invasion of Ukraine. In response, the United States and other countries have imposed sanctions on a broad range of financial transactions that affect Russia. Pension and 401(k)...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

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

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 Extends Non-Enforcement Period for PTE for Investment Advice Fiduciaries

On October 25, 2021, the Department of Labor (“DOL”) released Field Assistance Bulletin 2021-02 (FAB 2021-02), which extends its non-enforcement policies regarding certain rules applicable to fiduciaries who provide...more

DOL Proposes Rules Regarding ESG Factors and Proxy Voting

One of President Biden’s first acts upon taking office was to issue an executive order requiring federal agencies to conduct a review of policies or regulations issued by the prior administration that were inconsistent with...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

Fiduciary Duty IS Coming to Privacy – Through Your Benefit Plans!

While all businesses have been grappling with cybersecurity challenges for years, cybersecurity has recently come into focus for retirement plans, health and welfare plans and other ERISA plans due to a new Department of...more

IRS Extends Remote Notarization Relief

On June 24, 2021, the Internal Revenue Service (“IRS”) released Notice 2021-40, which extended relief from the “physical presence” requirement for witnessing by plan representatives or notaries of spousal consents through...more

PTE 2020-02 for Investment Advice Fiduciaries: Overview and Checklist

Overview: In general, the prohibited transaction rules (in ERISA and the Tax Code) (1) prohibit fiduciaries that provide investment advice to plans subject to Title I of ERISA (including 401(k) plans, pension plans and...more

DOL Releases Cybersecurity Guidance

On April 14, 2021, the Department of Labor (“DOL”) issued several pieces of guidance on cyber security best practices, including: (1) a press release, (2) Online Security Tips for retirement plan participants, (3) a Tips for...more

DOL Issues Non-Enforcement Policy for ESG and Proxy Voting Rules

As 2020 drew to a close, the Department of Labor (“DOL”) finalized a number of regulations relating to the fiduciary duties that apply to ERISA plan investments, including: (1) a final rule generally restricting fiduciaries...more

Department of Labor Extends and Expands COVID-19 Regulatory Relief for Employee Benefit Plans

In May 2020, the Department of Labor jointly with the Department of Treasury and the Internal Revenue Service (the “Agencies”) released guidance delaying and extending many common deadlines for employee benefit plans. In...more

Department of Labor Issues Missing Participant Guidance for Retirement Plans

The Department of Labor (DOL) has issued long-awaited guidance on what it views as appropriate procedures for retirement plans to locate missing or nonresponsive participants. Plan sponsors and fiduciaries of all retirement...more

IRS Extends Relief for Remote Notarization of Spousal Consents

In June, the IRS provided temporary relief that allows for spousal consents for retirement plan loans or distributions to be witnessed remotely through audio visual equipment by a notary public in accordance with a state...more

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