Author Archives: Jennifer Stokes

New IRS Procedures for Waiver of Penalties for Delinquent Form 5500 Filings

ERISA Plans.     Plan administrators who fail to timely file an annual report on Form 5500 are subject to penalties under both ERISA and the Code.  In 1995, the Department of Labor (DOL) adopted the Delinquent Filer Voluntary Compliance program (DFVC), […]

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Are You Smarter Than a Plan Administrator?

We want our employees to make healthy choices so that they will have long and healthy lives (and also to decrease the cost of health benefits).  We also want our employees to participate in the 401(k) plan so that they […]

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DOL Updates Late 5500 Correction Program

Last week, the DOL published a comprehensive update to its Delinquent Filer Voluntary Correction (“DFVC”) Program in the Federal Register.  A little background: The Secretary of Labor has the authority to asses civil penalties of up to $1,100 against a […]

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DoL Clarifies Fee Disclosures for Brokerage Windows

On May 7, 2012 the DOL issued Field Assistance Bulletin 2012-02, consisting of 38 questions and answers intended to clarify some of the issues raised since the issuance on October 20, 2010 of the final participant fee disclosure regulations (as […]

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Recent Guidance on Normal Retirement Age Regulations for Governmental Plans

The IRS and Treasury Department recently issued Notice 2012-29, which provides new guidance for the final “normal retirement age” regulations relating to governmental plans. The Notice provides that the IRS and the Treasury intend to further extend the effective date […]

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