On May 2, the CFPB published a blog post demonstrating its commitment to “a fair, transparent, and competitive auto lending market” by calling attention to add-on products for which auto dealers and finance companies “often...more
In IRS Notice 2019-18, the IRS announced that it no longer intends to issue regulations that prohibit pension plans from offering to retirees who have already begun annuity payments the choice to receive the value of the...more
Due to an Internal Revenue Service (IRS) change in course published in Notice 2019-18, plan sponsors may now offer retirees lump-sum windows as another pension “de-risking” option. Plan sponsors considering pension de-risking...more
One de-risking tool for employers with defined benefit pension liabilities is to allow participants to receive lump-sum distributions. Although lump sums result in a short-term cash drain, they reduce the plan’s long-term...more
Pension plan sponsors have been looking for opportunities to manage their growing pension liabilities for many years now. In 2015, the Internal Revenue Service (IRS) closed the door on sponsors who were considering offering...more
On March 6, 2019, the Internal Revenue Service (IRS) issued Notice 2019-18 (Notice), announcing that it is retracting its previous position that prohibited pension plan sponsors from offering lump-sum cashouts to retirees who...more
As a litigation consultant with an academic background, I am in a unique position: I stay abreast of the social science research (the blog schedule makes sure of that), but I also spend my days working with trial lawyers on...more
On September 29, 2015, the U.S. District Court for the Southern District of New York issued a decision that emphasizes the importance of accurate communications to employees regarding changes in qualified retirement plan...more
The Internal Revenue Service (IRS) recently issued two significant notices for employers that sponsor defined benefit pension plans, particularly those considering lump-sum windows as a “de-risking” option for their plans....more
On July 9, 2015, the IRS announced that it intends to amend the required minimum distribution regulations under Section 401(a)(9) of the Internal Revenue Code to prohibit plans from offering voluntary lump-sum cashouts to...more
The Internal Revenue Service (IRS) has surprisingly issued a notice of its intention to amend the required minimum distribution (RMD) regulations under the Internal Revenue Code (Code) to limit the use of lump sum payments to...more
Yesterday, the IRS issued Notice 2015-49, which abruptly announced the IRS’s intention to prohibit lump-sum cashout windows for pension plan retirees already in pay status. In recent years, many pension plan sponsors have...more
The practice of offering lump-sum distributions has become increasingly popular among defined benefit plan sponsors looking to decrease volatility or other defined benefit plan risks. In some situations, plan sponsors offer...more
A make-whole premium is a lump-sum payment that becomes due under a financing agreement when repayment occurs before the stated maturity date, thereby depriving the lender of all future interest payments bargained for under...more