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Recently issued Notice 2023-43 provides interim guidance on certain changes to the Employee Plans Compliance Resolution System (EPCRS) made by the SECURE 2.0 Act of 2022. In particular, the notice addresses how plan sponsors...more
Welcome to Spring! We hope the new season finds you ready for the upcoming benefits changes that 2023 has in store. ...more
Attorneys from our Employee Benefits and Executive Compensation practice provide insights on current issues facing various types of employee benefits programs. Topics include: - Cybersecurity - DOL Audit Initiatives -...more
In light of a new DOL audit initiative and increasing cybersecurity threats to ERISA benefit plans, ERISA plan sponsors and fiduciaries should be prepared to answer some important questions: Do the cybersecurity programs of...more
Unclaimed property audits and compliance issues will continue to be a challenge for companies in a wide range of industries. States view escheat as an important source of revenue, and contingent fee auditors will do their...more
We recently witnessed the DOL's 401K audit priorities first hand. In auditing 401K plans, the U.S. Department of Labor previously focused on determining how quickly employers could deposit employee deferral contributions...more
The recent United States Tax Court case of Jeremy Ray Summers v. Commission, T.C. Memo 2017-125, is an example of the old adage that “no good deed goes unpunished.” The case also highlights how sometimes form triumphs over...more
The Department of Labor (DOL) recently issued guidance on the Conflicts of Interest Rule it released earlier this year. The guidance, issued on October 27, 2016, is in the form of answers to frequently asked questions, which...more
The New Fiduciary Rule: What It Means To Plan Sponsors - Bottom line: what does it mean? More than a dozen years ago, there was a medical report that dental plaque could cause heart disease. I thought it was some...more
Late this summer, the Massachusetts Treasurer demanded mutual fund records on a nationwide basis as part of a multistate unclaimed property audit. Thirty-five (35) states are involved in the audit, but the Treasurer has...more