Headlines about "Ret plans - admin"

Gathered from the web by the editors at BenefitsLink.com.
[Guidance Overview] The Supreme Court's Decision In LaRue v. DeWolff, Boberg & Associates: How It Affects You, What You Should Do, and Our Ruminations
Excerpt: "It is premature to predict . . . that LaRue will trigger a significant increase in ERISA litigation. The decision in LaRue removes one of the legal hurdles that, in some circuits (i.e., parts of the country), would have dissuaded would-be plaintiffs' attorneys from taking cases in which an individual participant, or small group of participants, have sustained damage to their plan accounts. While that legal hurdle has been removed, other practical issues will be the deciding factors for plan participants contemplating litigation." (Reish Luftman Reicher & Cohen)

[Guidance Overview] GFOA Publishes Recommended Practices on Benefit Administration for Public-Sector DB Plans (PDF)
Excerpt: "On February 22, 2008, the Executive Board of the Government Finance Officers Association (GFOA) approved new recommended practices on essential design elements for public-sector defined benefit plans, defined contribution plans, and hybrid plans. The documents can be downloaded from the GFOA website for the following types of retirement plans: . . . " (Gabriel, Roeder, Smith & Company)

Spring 2008 Regulatory Agendas Released by PBGC, IRS and EBSA
Excerpt: "Among the items in the PBGC's proposed rule stage are: . . . . Among the items in the IRS proposed rule stage are: . . . . The prerule and final rule EBSA agenda items are: . . . ." (Wolters Kluwer)

[Opinion] The Time is Now to Remedy the Inequity Applied to American Small Businesses Respecting the Late Filing of IRS Form 5500-EZ (PDF)
9 page letter to the Internal Revenue Service by attorney Alex M. Brucker. Excerpt: "The potential $15,000 penalty is more burdensome for small than large employers, especially when more than one plan and more than one plan year are involved. . . . For a one-participant plan which has been exempt from Form 5500-EZ filings because plan assets are below the $250,000 threshold, it is easy to inadvertently miss a filing when plan assets increase above the $250,000 threshold. . . . There is no justification for denying the DFVC Program to a plan covering an owner and spouse while allowing the program to be used by a plan covering an owner and a non-spouse employee." (Brucker Morra)

Why Liability-Driven Investing? A Strategy for Balancing Asset and Liability Risk for Defined Benefit Pension Plans
Excerpt: "While the primary reason for creating a defined benefit (DB) pension plan is to help employees prepare for retirement, financial stewardship issues have recently eroded their importance as part of the employer's total rewards package to attract and retain talent. Study after study of DB plans has shown that the volatility -- rather than the absolute level -- of costs has spurred employers to act." (Sibson Consulting)

[Guidance Overview] Worker Misclassification Investigations Gain Momentum
Excerpt: "Undoubtedly, some industries are both more prone to misclassify workers and more vulnerable to challenge due to the nature of the work involved. Construction, transportation and even the medical profession have proven at risk on the issue." (Attorney Roy F Harmon III in the Health Plan Law blog)

Common Errors in Qualified Plans: It's time for Spring Cleaning!
Excerpt: "I have come to realize that 'As time marches on' --- so do the errors in our client's retirement plans. So, with 'spring cleaning' in the air, I decided to clean out the garage of plan errors and list, in no particular order, some of the errors that have occurred over the past year. The type of error might not be new --- but the resulting consequences clearly explain the often used phrase: 'No Good Deed Goes Unpunished.'" (BNA Pension & Benefits Blog)

[Guidance Overview] Labor Department Clarifies and Amends Guidance on Default Investments in 401(k) Plans
Excerpt: "Plan sponsors are not required to follow the QDIA rules. However, if a 401(k) plan has a default investment, we recommend reviewing the opportunity for reduced legal exposure by implementing a QDIA." (Wilson Sonsini Goodrich & Rosati)

[Guidance Overview] 401(k) Fee Bill Reported Out of Education and Labor Committee
Excerpt: "The House Committee on Education and Labor recently approved a revised 401(k) Fair Disclosure for Retirement Security Act (H.R. 3185). The new bill is substantially different from the bill originally introduced and represents a compromise with critics of the earlier bill's detailed disclosure requirements. In this article, we review the bill, primarily focusing on describing what the bill itself says." (JPMorgan)

How You Can Help Clients and Prospects Evaluate the Promises of Defined Benefit Plans
Excerpt: "How secure are the promises of DB plans on a scale of 1 to 10? . . . Now is the time to help your clients who participate in DB plans answer complex, anxiety-inducing questions. The ideas, tools and techniques in this article will help you." (Rich White on FreeERISA.com)

ASPPA Rolls Out Professional Services Directory of ASPPA Members, Available for Use by Public
Excerpt: "Please select the professional services that you require, then you may select to search by zip code and mile radius or city, state and mile radius. . . . Please select one or more services . . . : 401(K)/Defined Contribution Services; Actuarial and Defined Benefit Services; Compliance and Fiduciary Services; Investment Services' [ASPPA membership information is online at http://www.asppa.org/membership/member_join.htm] (American Society of Pension Professionals and Actuaries)

[Guidance Overview] EBSA Clarifies Fee Disclosure, Stable Value Provisions of QDIA Regs
Excerpt: "The recently issued FAB clarifies that when a plan sponsor chooses to create and manage a QDIA using a mix of the plan's available investment alternatives, the plan sponsor will not qualify for the QDIA safe harbor unless it is a named fiduciary of the plan. The plan sponsor would remain liable for the management and monitoring of the QDIA." (Wolters Kluwer)

[Opinion] Report of the Working Group on Participant Benefit Statements
Excerpt: "The Department should provide longer due dates for defined benefit plan benefit statements, dates that recognize the time it takes to accumulate details of participant data necessary to calculate all participants' accrued benefits, and that recognize differences in accumulating data." (Employee Benefits Security Administration, U.S. Department of Labor)

[Guidance Overview] IRS Issues Plan Valuation Regulations For Single-Employer Defined Benefit Plans (PDF)
6 pages. Excerpt: "This Pension Analyst discusses the new funding requirements that apply to single-employer and multiple employer defined benefit plans in an effort to help plan sponsors determine the future actions needed to keep their plans in compliance with ERISA and the Internal Revenue Code." (Prudential's Pension Analyst)

[Guidance Overview] DOL Corrects and Clarifies Qualified Default Investment Guidance; What Employers Should Do Now (PDF)
2 pages. (Milliman)

Financial Advisors Have New Reasons to Review Fiduciary Practices and Liability Insurance
Excerpt: "The [LaRue v. DeWolff Supreme Court] case adds to the litigation concerns that threaten to chill growth of advisor-sold 401(k) plans to small- and mid-sized businesses, an increasingly productive area for many financial advisors. At Fidelity alone, total record-kept assets in such plans stood at $21.2 billion at the end of 2007, an increase of 26% from the previous year. Several factors are helping to drive the growth in advisor-sold 401(k) plans, including the Pension Protection Act of 2006, which provided guidelines necessary to encourage plan sponsors to retain qualified fiduciary advisors and to define safe harbor procedures to insulate them from the liability associated with the advice. " (Financial Advisor)

[Guidance Overview] Weighted Average Interest Rate Table, Updated for May 2008
Weighted average interest rate: 4.76 (Internal Revenue Service)

[Guidance Overview] Winter 2008 Edition of IRS 'Retirement News for Employers' (PDF)
10 pages. Articles include 'Keeping Your Plan in Compliance' and 'Using a Plan Amendment for Correction in the Self-Correction Program." (Internal Revenue Service)

DOL FAB Addresses QDIA Issues
Excerpt: "The Department of Labor (DOL) has issued Field Assistance Bulletin (FAB) 2008-03 to respond to a number of questions practitioners have raised regarding the final regulations on qualified default investment alternatives (QDIAs) . . . . The FAB is in question and answer format, addressing 22 'most frequently asked' questions regarding the QDIA regulations. Here are highlights of the new guidance: . . . " (SunGard Relius)

Pension Take-Back by PBGC is 'Nightmare' for Steel Plant Retirees, Some Say
Excerpt: "Dec. 1, 2099. That's the date Rick Wyers was told he will be finished paying back what he owes the Pension Benefit Guaranty Corp., the federal agency that took over pensions from Republic Technologies International after it went bankrupt in 2002. . . . Wyers, of Florence Township, is one of more than 1,000 steel plant retirees who have learned that their pension benefits were overpaid for years by the Pension Benefit Guaranty Corp. The overpayment will be collected by a 10 percent reduction in their benefit rate . . . ." ([Lorain OH] MorningJournal.com)

Seven Out of Ten Employers Offer Retirement or Financial Planning to Employees
Excerpt: "A new survey from the International Foundation of Employee Benefit Plans (IFEBP) has found that 70% of respondents offered some type of retirement or financial planning initiative, education or program for employees or participants." (Wolters Kluwer)

[Guidance Overview] Special Edition of IRS 'Employee Plan News': Overview of Governmental Plans Roundable Held 4/22/2008 (PDF)
Excerpt: "The roundtable was the first step in establishing a dialogue between the IRS and the governmental plans community in an effort to ensure that governmental entities understand the tax qualification requirements applicable to their plans and are aware of the tools and resources available to assist them in ensuring ongoing compliance. IRS representatives acknowledged that there is very little history examining governmental plans. They want to better understand the issues and barriers these plans face in attempting to satisfy tax qualification requirements." (Internal Revenue Service)

[Guidance Overview] Prison Sentences Upheld for Unpaid Plan Contributions Under ERISA Theft Statute
Excerpt: "Over a two-year period, the corporate executives in this case (a CEO and CFO) failed to make required contributions to the company's retirement plans and failed to use employee health plan contributions to pay benefits under that plan (almost $1.4 million in contributions was involved). The executives were convicted of various federal crimes (including ERISA theft and false statements) and given ten- and seven-year prison terms." (Employee Benefits Institute of America (EBIA))

The Effect of Conflicts of Interest on the Scope of Discovery
Excerpt: "As discussed in a prior article, the federal judiciary has permitted limited discovery beyond the 'administrative record' as the inquiries may bear upon the question of a structural conflict of interest as, for example, where the administrator and the insurer are the same entity. Another level of conflict of interest may exist, namely, that of 'third parties', such as consultants, who review the record and advise the administrator." (Health Plan Law blog by Attorney Roy F. Harmon III)

PLANSPONSOR 2008 Ultimate Buyer's Guide: 403(b)
Excerpt: "Sponsors who decide to search for new plan vendors or a vendor that will take on the monitoring or recordkeeping function should look for providers that have 'best-in-class' investment choices . . . . Sponsors also should ask what services the providers offer and what fees they charge for the services. Finally, . . . sponsors should look for providers that are committed to the 403(b) business and the retirement readiness of participants." (PLANSPONSOR.com; free registration required)

Retirement Firms Consolidate
Excerpt: "The retirement services market has been consolidating quickly in the past two years. In addition to ING's deal for CitiStreet, MassMutual bought First Mercantile Trust's retirement plan business this year, and in December Hartford Financial Services Inc. bought Sun Life Financial Inc.'s U.S. defined contribution plan administration business; Princeton Retirement Group; and Top Noggin, which offers data management, administration, and benefit calculation tools for sponsors of defined benefit plans." (American Banker via On Wall Street)

[Official Guidance] May 2008 Pension Funding Segment Rates
Generally for plan years beginning after 2007, the rates in the tables . . . apply for minimum funding requirements under section 430 of the Code. (Internal Revenue Service)

[Official Guidance] IRS 30 Year Treasury Securities Rate Updated for April 2008
30 Year Treasury Securities Rate for April 2008: 4.44% (Internal Revenue Service)

[Official Guidance] IRS Composite Corporate Bond Rate Table Updated for May 2008
Corporate Bond Weighted Average Interest Rate = 6.00 for May 2008 (Internal Revenue Service)

Plan Sponsors Focus on Investment Monitoring and Decision Making
Excerpt: "The Pension Protection Act has changed patterns in savings and reporting, reports Grant Thornton LLP in its 2008 Plan Sponsor Retirement study. Plan sponsors are placing a greater emphasis on using investment policy statements. More than 80% of organizations have one in place, and 40% are reviewing their IPS consistently, indicates the Chicago-based consulting firm." (Employee Benefit News; free registration required)

PBGC's Pension Benefits Take-Back 'Nightmare' for Steel Plant Retirees
Excerpt: "[More than 1,000 steel plant retirees] have learned that their pension benefits were overpaid for years by the Pension Benefit Guaranty Corp. The overpayment will be collected by a 10 percent reduction in their benefit rate, further decreasing their monthly check." (The Morning Journal)

[Guidance Overview] Former Participants Have Standing to Pursue Equitable, But Not Legal Remedies With Respect to IRA Rollovers (PDF)
2 pages. Excerpt: "Plaintiffs are former participants in 401(k) plans, who allege that in rolling over their plan accounts to IRAs, defendants violated ERISA. On April, 21 2008, a federal judge in Iowa ruled that former participants in a 401(k) plan lacked standing to pursue legal remedies under ERISA, despite the Supreme Court's recent ruling in LaRue v. DeWolff, Boberg & Assoc., Inc., 128 S. Ct. 1020 (2008), but held that standing was proper to pursue equitable relief under ERISA. Young v. Principal Financial Group, Inc., S.D. Iowa., No. 4:07-cv-386." (Sutherland Asbill & Brennan LLP)

Unpaid Contributions Constitutes ERISA Theft
Excerpt: "The 4th U.S. Circuit Court of Appeals has affirmed the conviction of two retirement plan administrators for Employee Retirement Income Security Act (ERISA) theft due to unpaid plan contributions." (PLANSPONSOR.com; free registration required)

[Guidance Overview] Listing of IRS Published Guidance for January - April 2008
The target page links to guidance published by the Service relating to retirement plans: Treasury Regulations; Revenue Rulings; Revenue Procedures; Notices; and, Announcements. (Internal Revenue Service)

[Official Guidance] Internal Revenue Bulletin No. 2008-17, April 28, 2008, Containing Notice 2008-45 (PDF)
44 pages. Excerpt: "This notice contains updates for interest rates for funding requirements under sections 412(b)(5)(B) and 430(h)(2) of the Code applicable for April 2008, and updates for interest rates for minimum present value determinations under 417(e)(3) of the Code for March 2008." (Internal Revenue Service)

[Guidance Overview] DOL Proposal of Safe Harbor for Deposits to Small Plans
Excerpt: "The proposed seven-day safe harbor for deposits to small plans is welcome relief from a confusing requirement. EBSA indicates that it is open to extending the safe harbor to larger (100 or more participant) plans, if it receives compelling arguments during the comment period for the proposed regulations. In the meantime, employers and plan trustees should review the timeliness of deposits and take action to correct any delinquencies discovered." (Bond, Schoeneck & King, PLLC)

[Guidance Overview] DOL Guidance on Compliance for Wellness Programs and Safe Harbor for Deposit of Employee Contributions
Excerpt: "The Department of Labor recently issued guidance on two issues that will help many employers navigate its regulations." (Winston & Strawn LLP)

[Guidance Overview] Contribution Timing and Collection Responsibility, a Q&A
Excerpt: "When must 401k deposits be made? Who's responsible when contributions are not made? The Department of Labor is flexing its regulatory and advisory muscle to clarify any misunderstanding that may exist and at the same time is asking the benefit's community to suggest alternative solutions." (James Farley via 401khelpcenter.com)

[Opinion] ASPPA Comments on Proposed Regulations Relating to Definition of 'Plan Assets' – Participant Contributions (PDF)
5 pages. Excerpt: "The American Society of Pension Professionals & Actuaries (ASPPA) appreciates this opportunity to comment on the proposed amendments to the regulation defining when contributions that are made by participants in an employee benefit plan are 'plan assets' for purposes of Title I of the Employee Retirement Income Security Act of 1974, as amended (ERISA) (the Proposed Regulation)." (American Society of Pension Professionals & Actuaries)

[Opinion] American Benefits Council/ICI Comment Letter on Participant Contribution Regulation Safe Harbor (PDF)
3 pages. (American Benefits Council)

[Official Guidance] 'Fact Sheet' from EBSA on Rules for Qualified Default Investment Alternatives
Excerpt: "The final regulation provides the following conditions that must be satisfied in order to obtain safe harbor relief from fiduciary liability for investment outcomes: . . ." (Employee Benefits Security Administration, U.S. Department of Labor)

[Official Guidance] EBSA Field Assistance Bulletin 2008-03: Guidance Regarding Qualified Default Investment Alternatives
22 Q&As. Excerpt: "Since publication of the QDIA regulation, a number of issues have been raised concerning the scope and meaning of various provisions of the QDIA regulation. This Bulletin is intended to supplement the QDIA regulation by providing guidance, in a question and answer format, on a number of the most frequently asked questions." (Employee Benefits Security Administration, U.S. Department of Labor)

[Official Guidance] Text of Amendments to Final EBSA Regs on QDIAs (Default Investment Alternatives Under Participant Directed Individual Account Plans) (PDF)
8 pages; to be published in the April 29, 2008 Federal Register. Excerpt: "The Department published in the Federal Register of October 24, 2007 . . . a final regulation providing relief from certain fiduciary responsibilities for fiduciaries of participant directed individual account plans who, in the absence of directions from a participant, invest the participant's account in a qualified default investment alternative . . . . The Department has determined that two paragraphs in the final regulation, and one statement in the Supplementary Information, require correction. Accordingly, this document corrects the final regulation by revising these paragraphs." (Employee Benefits Security Administration, U.S. Department of Labor)

Pitfalls of Working Past Retirement Age
Excerpt: "[W]orkers with defined-benefit pensions and those who already have tapped Social Security benefits might not realize is that there are significant financial disincentives that make working into retirement age a tricky proposition." (The Wall Street Journal)

Bill Would Require Employee Representatives on Trust Boards for Pension Plans
Excerpt: "Rep. Peter Visclosky (D-IN) has proposed politicizing the administration of pension plans by requiring joint boards of trustees with elected employee representatives. The Employees' Pension Security Act of 2008 (H.R. 5754) would also establish new requirements for plan terminations and require companies that have terminated plans to pay for the amounts not covered by the Pension Benefit Guaranty Corporation." (HR Policy Association)

[Opinion] 'Bad Boy' Clauses Aren't Passe After All - But Sometimes It Takes a Judge to Do the Right Thing
Excerpt: "ERISA's prohibition against bad boy clauses generally precluded a court being able to order the retirement plan to pay out a participant's benefits to a third party as restitution, even for a crime committed against the employer. But what if a crime was committed against the plan? Under these circumstances the Department of Labor or a Federal court could order the Plan Administrator to offset the plan's losses against the participant's account." (The Retirement Plan Blog)

[Guidance Overview] Fourth Circuit Rejects Validity of Assignments Taken in Claims Settlement
Excerpt: "In this recent opinion, the Fourth Circuit considered the issue of derivative standing in the context of an ERISA claim for benefits action. . . . The Fourth Circuit affirmed the district court, holding that the assignments presumably taken by the original PEO defendant (Sikora) in a claims for benefit case through settlement were insufficient to create ERISA standing in a subsequent claim by the PEO against third parties (Fidelity Group) allegedly responsible for the defalcation in benefit funding." (Health Plan Law blog by Attorney Roy F. Harmon III)

[Guidance Overview] No Fiduciary Liability for Employer or HR Representative Who Gave Participant Inaccurate Benefit Information
Excerpt: "EBIA Comment: This case puts a new spin on the DOL regulations regarding fiduciary responsibility. While other courts appear to have taken the position that delegating responsibility for benefit estimates is generally a fiduciary act that may be subject to fiduciary liability . . ., this court concluded that providing estimates is not a fiduciary function, so there could be no fiduciary liability for improper delegation of that responsibility." (Employee Benefits Institute of America)

[Guidance Overview] Overview: PBGC Implements Variable-Rate Premium Changes
Excerpt: "On March 21, 2008, PBGC published a final rule . . . that, among other things, implements the statutory changes to the variable-rate premium (VRP) that go into effect starting with the 2008 plan year. The final rule, according to PBGC, is 'nearly the same' as the proposed rule published May 31, 2007 . . . . This article briefly summarizes key provisions of the final rule . . . ." (Keightley & Ashner LLP)

[Guidance Overview] ERISA - Erroneous Pension Estimates
Excerpt: "Where a plaintiff brought suit under the Employee Retirement Income Security Act, arguing that the defendant employer must pay him the amount of the erroneous benefit estimates he received before he left the defendant's employ instead of the lesser amount he was entitled to under the defendant's employee benefit plan, a judgment for the defendant must be affirmed because of the plaintiff's failure to show any fiduciary breach." (Lawyers Weekly, Inc.)

Governmental Plans Roundtable, April 22, 2008
See under 'Recent News. 'Excerpt: "The following sessions were presented at the Roundtable: Navigating the Staggered Remedial Amendment Period; Requirements Relating to Section 414(d) Governmental Plans; EPCU and Examinations Efforts; Federal State and Local Governments (FSLG) – An overview of the IRS Federal State and Local Government division, including a brief explanation of how FSLG interacts with the IRS Employee Plans. EPCRS & Governmental Plans." (Internal Revenue Service)

[Guidance Overview] Employee Plans Compliance Resolution System Update Expected 'Soon'
Excerpt: "An updated version of Rev. Proc. 2006-27 . . . will not be a major overhaul of the old procedure, . . . but will contain a number of smaller changes that taken together will have a significant effect on the program." (Wolters Kluwer)

[Guidance Overview] IRS Proposes Regs on Minimum Funding Contributions for Single-Employer Plans
Excerpt: "The Internal Revenue Service has issued proposed regulations that provide guidance on the determination of minimum required contributions for purposes of the funding rules that apply to single-employer defined benefit plans. The proposed regulations appeared in the April 15 Federal Register." (Wolters Kluwer)

[Guidance Overview] IRS Proposed Regs on Minimum Required Contributions Under PPA
Excerpt: "The IRS has issued proposed regulations under Code Sec. 430 which provide guidance on the minimum contribution rules applicable to single-employer defined benefit plans. These are the fourth in a series of proposed regulations issued by the IRS that implement the new funding rules enacted by the Pension Protection Act of 2006 . . . ." (Wolters Kluwer)

Retirement Plans Industry Outlook, April 16, 2008
Word document. Excerpt: "Retirement plan providers, TPAs, retirement plan specialists, generalists and B-Ds are all facing different scenarios. Individual providers, advisor practices and retirement plans could continue to grow. Individual plan participants will also continue to benefit, but overall employer sponsored plan asset 'growth' now appears to be limited." (Center for Due Diligence)

[Guidance Overview] CRS Report for Congress: Survivor Benefits for Families of Civilian Federal Employees and Retirees (PDF)
6 pages. Excerpt: "Federal employees with permanent appointments are eligible for retirement and disability benefits under either the Civil Service Retirement System (CSRS) or the Federal Employees Retirement System (FERS). . . . Both FERS and CSRS provide survivor benefits for spouses and dependent children of employees and retirees. . . . The federal government pays compensation to dependent survivors of federal civilian employees who are killed while performing their duties; however, a survivor eligible for both an annuity under CSRS or FERS and for survivor compensation cannot receive both." (Congressional Research Service, U.S. Library of Congress)

[Guidance Overview] DOL Guidance on Fiduciary Responsibility for the Collection of Delinquent Plan Contributions (PDF)
Pages 5-6 of 8 pages. Excerpt: "In light of FAB 2008-01, it is unlikely that plan trustees or investment managers will agree to be assigned or allocated the responsibility of monitoring and collecting plan contributions under a trust agreement. Therefore, plan sponsors and other named fiduciaries of ERISA-covered plans should be aware that they may be held liable for plan losses arising from the failure to collect delinquent contributions." (White & Case LLP)

Court Affirms no Fiduciary Breach in Miscalculated Benefit Estimates
Excerpt: "The 1st U.S. Circuit Court of Appeals has affirmed a district court's determination that miscalculations of pension benefits by a human resources employee and a plan's online payment calculator did not constitute a fiduciary breach under the Employee Retirement Income Security Act . . . ." (PLANSPONSOR.com; free registration required)

Large 401(k) Sponsors Want Expert Advisers, According to Survey
Excerpt: "A new Spectrem Group survey of large 401(k) plan sponsors found that the sponsors are looking for advisers with expertise in a particular service and will bring on more than one if they need to. The Spectrem report . . . said that might mean a sponsor might hire an investment consultant (including one familiar with a particular asset class) as well as a separate adviser with administrative expertise." (PLANSPONSOR.com; free registration required)

[Guidance Overview] DOL Correspondence on Late Deposit of Elective Deferrals
Excerpt: "Recently, the Department of Labor (DOL) has been automatically generating letters to plan sponsors who answer line 4a (Schedule H or I) with a 'yes.' Line 4a asks if the plan sponsor failed to transmit elective deferrals to the plan within the time period described in the plan asset regulations. Apparently, the DOL generates the letter even though the plan sponsor has included an attachment (or a footnote) in which it indicates that the late deposit has been corrected." (SunGard Corbel LLC)

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