Deadline Looming in the Distance for 403(b) Plans: What Plan Sponsors Should Be Doing Now
Last year when the IRS announced that the initial remedial amendment period for 403(b) plans will end March 31, 2020, the natural reaction to this very important (but rather remote) deadline was to immediately put it on the to-do list, […]
Revised VCP Fees – Simple Isn’t Always Better
The Internal Revenue Service (“IRS”) has described its recent changes to its Voluntary Correction Program (“VCP”) user fees as “simplification.” This simplification is achieved by significantly changing the way user fees are determined and by eliminating alternative and reduced fees […]
IRS Views on Self-Certification of Financial Hardship
In today’s virtual world, we suspect most plan sponsors rely upon the self-certification process to document and process 401(k) distributions made on account of financial hardship. The IRS has recently issued examination guidelines for its field agents for their use […]
ISS Updates Proxy Voting Guidelines for 2017
Last month, Institutional Shareholder Services (ISS) published updates to its proxy voting guidelines effective for meetings on or after February 1, 2017. Key compensation-related changes include the following: Non-Employee Director Compensation Programs In the case of management proposals seeking shareholder […]
PBGC Proposed Rule May Offer DC Plans New Tool for Finding Missing Participants
For many years, the PBGC has been helping reunite missing participants with their benefits under single-employer defined benefit plans. Now, a new PBGC proposed rule may open up the program to missing participants under other terminated plans. Under this proposed […]
Department of Labor Fiduciary Rule: Employers Should Not Overlook Impact on HSAs
The new Department of Labor rule defining the scope of who is an ERISA fiduciary (see our prior post here) has caused much consternation among investment professionals. Much of the new rule is focused on reworking the outer fringes of […]
The FAST Act – If You Blinked You May Have Missed It.
On December 3, 2015, the President signed into law the Fixing America’s Surface Transportation Act (the “FAST Act”) which provides for five years of funding for highway projects. If you just skimmed the news on this one, you may not […]
The Tax Man Cometh Not to ID Protection Recipients Either
Late last year, while you were probably busy picking out which bubbly to pop at the stroke of midnight, the IRS gave us another reason to celebrate. You may remember (as we wrote previously) the IRS said it would not […]
The Tax Man Commeth Not to Data Breach Victims
The IRS has issued some favorable guidance on the tax treatment of identity protection services provided to data breach victims. In Announcement 2015-22, the IRS indicated that when an organization experiences a data breach, and it provides identity protection services […]
Undermining the Goal of Expanding Coverage for Nonhighly Compensated Employees
One might be led to believe that the current administration is in favor of expanding retirement savings opportunities. After all, the DOL has somewhat apologetically subverted ERISA to allow the States to sponsor employer-based savings plans. And the President’s recently […]