News & Analysis as of

403(b) Plans Internal Revenue Code (IRC) Benefit Plan Sponsors

Bricker Graydon LLP

Act 3: To Roth or Not to Roth - That Is No Longer the Question for Some Catch-Up Eligible Individuals

Bricker Graydon LLP on

The IRS this past Friday issued proposed regulations regarding mandatory Roth catch-up contributions. SECURE 2.0 amended the catch-up contribution provisions of the Code....more

The Wagner Law Group

IRS Provides Guidance on Application of SECURE 2.0 Act’s Coverage of Long-Term, Part-Time Employees

The Wagner Law Group on

In Notice 2024-73, the Internal Revenue Service (“IRS”) issued guidance on the application of certain non-discrimination rules to long-term, part-time employees in Internal Revenue Code (“Code”) Section 403(b) plans subject...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (3): Automatic Enrollment (3)

SECURE 2.0 was enacted on December 29, 2022. Among its provisions is a requirement that “new” 401(k) plans and private sector 403(b) plans must automatically enroll their eligible employees, but not until the first plan year...more

Nelson Mullins Riley & Scarborough LLP

IRS Reminder: Deadlines Extended for Retirement Plan Amendments but Compliance Still Required

On September 12, the IRS reminded plan sponsors to review and comply with IRS Notice 2024-02 (the “Notice”), which extended and consolidated deadlines for employers and others sponsoring 401(k), 403(b), 457(b) and other...more

Carlton Fields

2024 IRS Guidance on Employee Benefits

Carlton Fields on

Employee benefits or employee benefit issues can arise anytime you are providing employees something of value other than direct cash compensation. Engagement is very important. I hear it talked about a lot at 401(k) committee...more

Patterson Belknap Webb & Tyler LLP

Does Your Retirement Plan Need a 'PLESA'?

Pension-Linked Emergency Savings Accounts (“PLESAs”) are a special retirement plan feature created under SECURE ACT 2.0. PLESAs were first permitted to be made available to participants as of January 1, 2024. PLESAs, which...more

Bricker Graydon LLP

403(b) Plans - Not Your Average Salary Deferral Plan

Bricker Graydon LLP on

Congress continues to pass laws that move 403(b) plans ever closer to 401(k) plans, but 403(b) plans remain distinct. Understanding these differences allows you to maintain a compliant plan that best serves the needs of your...more

Davis Wright Tremaine LLP

New IRS Guidance on Long-Term, Part-Time Employee Retirement Plan Participation

New proposed regulations clarify how employers should implement retirement plan eligibility rules for long-term, part-time ("LTPT") employees. While some questions remain, the proposed regulations provide a number of welcome...more

McDermott Will & Emery

Opportunity Knocks: At Long Last, IRS Determination Letter Program Opens for 403(b) Plans

McDermott Will & Emery on

The IRS has long permitted sponsors of individually designed pension and 401(k) retirement plans qualified under Section 401(a) of the Code to obtain a favorable determination letter on the status of their tax-qualified...more

Harris Beach Murtha PLLC

Enhancing Retirement Readiness Using Employer Matching Contributions on Qualified Student Loan Payments

Harris Beach Murtha PLLC on

Many employees who have had to resume repaying their federal student loans this month may find it harder to continue contributing to their employers’ retirement plans. For some employees, there simply is no room in the family...more

Foley & Lardner LLP

Diving Into SECURE 2.0: New DOL Lost and Found, Updates to EPCRS, and Delayed Implementation of Roth Catch-up Requirement

Foley & Lardner LLP on

The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more

Harris Beach Murtha PLLC

SECURE 2.0 Act of 2022 - What it Means for 403(b) Plans

The SECURE 2.0 Act of 2022 (“SECURE 2.0”), enacted on December 29, 2022, as Division T of the Consolidated Appropriations Act, 2023 (Public Law No. 117-328), builds upon many changes made earlier by the Setting Every...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Plan sponsor taken off 403(b) lawsuit, advisor isn’t so lucky

A plan sponsor was spared from a 403(b) lawsuit, but the advisor is still on the hook. Two plaintiffs filed a complaint in Texas federal court against their employer, Legacy Counseling Center, Inc. the plan’s manager,...more

Verrill

Next Steps for Making Collective Investment Trusts Available to More Retirement Plans

Verrill on

Collective investment trusts (“CITs”) have become an increasingly popular choice for 401(k) plan investment menus over the past decade, consistent with a trend toward lower-cost investment options that has been driven, in...more

Troutman Pepper Locke

IRS Expands Determination Letter Program to Include Individually-Designed 403(b) Plans

Troutman Pepper Locke on

In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination...more

Eversheds Sutherland (US) LLP

Unlocking the process: Guide to ERISA individual prohibited transaction exemptions

Since 1996, the US Department of Labor granted more than 1,200 individual exemptions from the ERISA prohibited transaction rules. One of the distinctive features of ERISA is its prohibition, in ERISA section 406 as a...more

Morgan Lewis - ML Benefits

IRS Issues Important Reminder on Application of IRC Section 415(c) Limit to 403(b) Plans

The Internal Revenue Service (IRS) issued an important reminder of the unique application of the limit under Internal Revenue Code (IRC) Section 415(c) to 403(b) plans on August 20, 2021. The IRS’s “Issue Snapshot”...more

Verrill

December 31 Sunset of Safe Harbor Correction Method for Certain Elective Deferral Failures Benefits Law Update

Verrill on

A special IRS-approved correction method available for elective deferral failures in 401(k) and 403(b) plans with automatic contribution features will sunset on December 31, 2020, meaning it will not be available to correct...more

Harris Beach Murtha PLLC

The March 31, 2020 Deadline to Amend 403(b) Plan Documents Looms Large, and Other Remedial Plan Amendment Deadlines Will Follow

The March 31, 2020 deadline to correct form defects in individually-designed 403(b) plan documents seemed a tiny speck on the distant horizon when the IRS announced it in early 2017. But now, March 31, 2020 looms large and...more

Foley & Lardner LLP

The SECURE Act: Top 3 Issues to Consider Now

Foley & Lardner LLP on

Hundreds of articles have been published over the last two weeks about the SECURE Act (“Act”), which was signed into law in late December as part of the most recent budget bill. As you are certainly aware by now, the Act...more

Groom Law Group, Chartered

SECURE Act and Spending Bills – Impact on Plan Sponsors

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade, was enacted on December 20, 2019.  Many of the provisions in the...more

Vedder Price

The SECURE Act and Its Impact on Retirement Plans

Vedder Price on

On December 20, 2019, after months of uncertainty, the Setting Every Community Up for Retirement Enhancement (“SECURE”) Act finally became law. The SECURE Act makes numerous changes to both the Internal Revenue Code (IRC) and...more

Flaster Greenberg PC

New Retirement Plan Hardship Distribution Rules: What You Need to Know

Flaster Greenberg PC on

The IRS recently amended the rules applicable to hardship distributions from 401(k) and 403(b) plans. The new hardship distribution regulation relaxes some of the restrictions on the availability of hardship distributions...more

Verrill

Final Regulations on 401(k) Hardship Withdrawals

Verrill on

In September, the Treasury Department issued final regulations governing hardship withdrawals from 401(k) plans. The final regulations update the existing 2004 regulations to reflect recent statutory changes made to the...more

Kilpatrick

IRS Issues Rules for Correcting 403(b) Plan Document Defects

Kilpatrick on

Nonprofit or governmental employers that sponsor 403(b) plans generally have until March 31, 2020, to correct any defects in their 403(b) plan documents by adopting a pre-approved plan document or by amending their...more

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