Many years ago, I was contacted by a bank that had an issue. For 20 years, they didn’t include bonuses as part of their plan’s compensation, even though it was supposed to be included. I told them that the only option was an...more
One of the biggest strikes against multiple employer plans (MEPs) may go the way of bellbottoms and Betamax. The Internal Revenue Service is proposing an exception to the one bad apple rule, which means that the action of...more
The last two times I was in Las Vegas, I didn’t gamble a penny. I didn’t gamble because I hate to lose. Yet I see so many plan sponsors and plan providers gamble by not correcting a glaring compliance issue and play that...more
It should be the simplest thing to do, yet so many plan sponsor fails to do it. What I’m talking about is the late deposit of deferrals and it’s been the biggest reason I’ve seen why the Department of Labor (DOL) are auditing...more
On April 3, 2018, the U.S. Department of Labor’s (DOL) Wage and Hour Division (WHD) released additional information concerning its Payroll Audit Independent Determination (PAID) program. The information can be accessed on a...more
A new pilot program announced by the U.S. Department of Labor just last week provides employers with renewed hope that the agency is changing its approach from one of strict regulatory enforcement to one that seeks to...more
That Fiduciary Warranty Is Not Worth The Paper it's Printed On. They are pretty much worthless. A 401(k) plan sponsor is also a plan fiduciary and they have the responsibility to prudently run their plan. One major...more
I used to have this recurring dream that I was back in college and it was my last semester. The dream was that there was this one class that I didn’t attend all semester and the finals were around the corner. Someone pointe...more
Having shaken the prospect of a merger with EEOC, and facing a smaller budget, the OFCCP offers a glimpse into its priorities and invites contractors to suggest changes. - Takeaways - Compliance letters have been...more