Headlines about "Ret plans - amendments required, incl. EGTRRA"
Gathered from the web by the editors at BenefitsLink.com.
[Guidance Overview] The Worker, Retiree, and Employer Recovery Act of 2008 (WRERA) Provisions by Effective Date
Chart. (McKay Hochman Co., Inc.)
[Official Guidance] Summer 2009 Issue of 'Employee Plans News' from IRS (PDF)
13 pages. Excerpt: "This edition contains the following articles: . . . Two-Year Adoption/Submission Period for DC Pre-Approved Plans Expires on April 30, 2010 . . . The EPCU Insider . . . Free Phone Forums . . . A New Look for EP Large Case Program Web Page . . . Employee Plans Published Guidance . . . Calendar of EP Benefits Conferences." (Internal Revenue Service)
[Guidance Overview] Presentations by IRS at April 2008 Governmental Plans Roundtable
Powerpoint slides. 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) . . . EPCRS & Governmental Plans . . ." (Internal Revenue Service)
[Opinion] SPARK Institute Comments on Proposed 403(b) Prototype Document Program and Model Language (PDF)
14 pages. Excerpt: "The SPARK Institute believes that the most significant revision that is necessary to expand the availability of the prototype program is to permit the use of a vesting schedule in the prototype plan." (SPARK Institute)
[Opinion] ASPPA Comments on Proposed 403(b) Prototype Document Program
13 pages. Excerpt: "[T]he proposed program should much more closely mirror the current M&P/volume submitter program. Accordingly, we believe that the ?403(b) prototype program needs significant modification from its proposed form. Such changes will assist practitioners (many of whom work in both the ?403(b) and ?401(a) plan markets) by having consistent procedures and requirements. This consistency will also help the Service staff in reviewing the ?403(b) plans since the requirements will be similar to the ?401(a) program. Although we appreciate the goal of keeping the ?403(b) program simple, the quest for simplicity under the draft revenue procedure will undermine the functionality of the program." (ASPPA (American Society of Pension Professionals and Actuaries))
[Opinion] American Benefits Council Comments on Proposed 403(b) Prototype Document Program (PDF)
3 pages. Excerpt: "The Council believes that some minor changes to the prototype program [proposed in IRS Announcement 2009-34] will make it much more effective and usable by its 403(b) plan sponsor members. . . . [T]he Council recommends a few changes below that would address a wider variety of common plan designs than would be permitted under the original proposal." (American Benefits Council)
IRS Semiannual Regulatory Agenda Includes Filing Solution for Schedule SSA
Excerpt: "The IRS has released its semiannual regulatory agenda for Spring 2009, which includes pension and benefit regulations that are currently under development or review." (Wolters Kluwer)
[Guidance Overview] PBGC Semiannual Regulatory Agenda Addresses USERRA Benefits
Excerpt: "The Pension Benefit Guaranty Corporation (PBGC) has released its semiannual regulatory agenda for Spring 2009, which outlines regulations that have been selected for amendment during the next year, as well as any regulations that have been recently finalized." (Wolters Kluwer)
[Guidance Overview] IRS Auditors Provide Tips and Trends on Retirement Plan Compliance
Excerpt: "The U.S. Internal Revenue Service provides compliance trends and tips for qualified retirement plans from their Employee Plans Team Audit (EPTA) Program Web pages. These pages highlight plan mistakes that IRS plan auditors see recurring in large case audits and voluntary compliance submissions. The trends are now categorized by plan types including multiemployer plans, 401(k) plans, defined benefits plans and 403(b), 457 and other governmental plans." (International Foundation of Employee Benefit Plans)
[Guidance Overview] The IRS's Employee Plans Compliance Resolution System for Retirement Plans
Excerpt: "In a perfect world, all retirement plans would be amended on time and operated properly according to the plan terms and the law. However, we don't live in a perfect world and the IRS's Employee Plans Compliance Resolution System (EPCRS) acknowledges that fact. EPCRS lets plan sponsors correct certain common plan failures to satisfy the plan qualification requirements without suffering the severe penalty of plan disqualification. This article provides an overview of EPCRS and how you can save a retirement plan from disqualification." (Chang Ruthenberg & Long PC)
[Guidance Overview] Detailed Description of Code Section 436 Restrictions on Single-Employer Defined Benefit Plans (PDF)
18 pages. Excerpt: "The Pension Protection Act of 2006 . . . established a new code section -- section 436 -- that imposes benefit restrictions for underfunded single-employer defined benefit plans. . . . This report examines the proposed regulations and the impact they will have on single employers that maintain defined benefit plans during 2008 and beyond. . . . Because the rules affect the plan's qualification and the sponsor's fiduciary responsibility under Title I of ERISA, they are important not only to actuaries, but to employee benefits attorneys as well." (Prof. Kathryn J. Kennedy; Reprinted by Permission of Tax Analysts; All Rights Reserved)
[Guidance Overview] Towers Perrin Monthly Retirement Regulatory Round-Up, April 2009 (PDF)
5 pages. Excerpt: "The Monthly Regulatory Round-Up is a high-level summary of legal and regulatory developments that occurred during January 2009 that may be relevant to large employers. Developments are sorted according to federal legislative developments, federal regulatory guidance, other developments (e.g., significant litigation, studies, select state law developments)." (Towers Perrin)
More 403(b) Guidance on the Way, Key IRS Official Says
Excerpt: "The IRS's Employee Plans (EP) unit will issue more guidance on how to satisfy the requirements for 403(b) plans, EP Tax Law Specialist Robert Architect stated on April 16, 2009 in an IRS phone forum. The IRS will update the EPCRS program to address 403(b) plans, Architect said. The revisions will be issued in the 'near term,' he indicated. Initially, the revised procedures will allow plans to correct operational failures." (Wolters Kluwer)
[Guidance Overview] IRS's Proposed Prototype Program for 403(b) Plans
Excerpt: "Those sponsors not electing to adopt a 403(b) prototype plan or that are otherwise unable to do so because of a complex plan design or for other reasons should continue to ensure compliance with the final 403(b) regulations, and should continue to monitor guidance from the IRS to determine whether the IRS intends to approve 403(b) plans via a program similar to the determination letter program in place for 401(k) plans. Announcement 2009-34 reiterates the IRS's intent to establish a determination letter program for individually designed 403(b) plans, but, as with prior guidance, the Announcement does not specify a date as of which such program will be established." (McDermott Will & Emery)
[Official Guidance] Text of IRS 'Employee Plans News' April 2009 Special Edition, Describing Proposed 403(b) Procedures (PDF)
2 pages. Excerpt: "This Special Edition contains the IRS's request for comments on drafts of a revenue procedure and sample plan language for ?403(b) prototype plans and highlights of the draft revenue procedure." (Internal Revenue Service)
[Official Guidance] Text of Draft Document by IRS: 403(b) Plan Listing of Required Modifications and Information Package (LRM) (PDF)
67 pages. Excerpt: "The Section 403(b) Prototype Program will operate generally in the same manner as the current Master and Prototype Program for plans qualified under section 401(a) of the Internal Revenue Code. A Section 403(b) Prototype Plan sponsor will submit a section 403(b) plan document to the IRS for review. . . . The DRAFT sample language is based on language previously developed for other IRS prototype plan programs . . . ." (Internal Revenue Service)
Listing of IRS Published Guidance for January-March 2009
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)
[Guidance Overview] Public Sector Retirement Plan Compliance Wrap-up (PDF)
Excerpt: "This Bulletin discusses the following major public sector provisions of [The Worker, Retiree and Employer Recovery Act of 2008 (WRERA)]: Rate of Return for Crediting Interest, Rollovers, Temporary Waiver of Required Minimum Distributions, and Self-Funded Plans Eligible for Special Tax Exclusion for Retired Public Safety Officers under PPA'06. This Bulletin also provides information about extensions by the Internal Revenue Service (IRS) of several important compliance deadlines for public sector retirement plans." (The Segal Group, Inc.)
[Official Guidance] Nonamenders and the Voluntary Correction Program
Excerpt: "Voluntary Correction has written an explanation of the nonamender process under the VCP. This explanation will tell you all you need to know about filing for relief under VCP for nonamender failures, including when you can file (with examples of when Appendix D or F should be used) and when a determination letter should be filed as part of a VCP submission." (Internal Revenue Service)
[Official Guidance] Spring 2009 Issue of IRS 'Employee Plan News'; Includes Update on ERPA Program (PDF)
Excerpt: "This edition contains the following articles: * Know a Nonamender? Here's what you need to know NOW... * Final Regulations Issued for Automatic Contribution Arrangements * Sample Plan Language - Transfer of an ESOP's S Corporation Shares to Prevent a Nonallocation Year * The EPCU Insider -The Multiemployer Actuarial Certification Project ? Defined Benefit Plan Actuarial Certification Errors * ERPA - CPE Sponsor Program * Web Spins - The Retirement Plans Site * Employee Plans Published Guidance * Critical Priorities?With Monika Templeman - Today's Discussion: Update on the Enrolled Retirement Plan Agent Program * Attention All 2009 Form 1099-R Issuers * Highlights of the Retirement News for Employers * The Corner of Forms & Pubs * We're Glad You Asked! * 403(b) Phone Forum * DOL Corner * PBGC Insights * Calendar of EP Benefits Conferences" (Internal Revenue Service)
ESOP Restatements and Submissions Present Opportunities
Excerpt: "[A]ll companies sponsoring ESOPs should be aware that their plan documents must be restated and submitted to the IRS every five years for a letter of determination of their tax qualified status. What they may not realize is that the ESOP restatement process offers potentially unrealized opportunities for cost efficiency, employer protection and creative re-design." (Chang Ruthenberg & Long)
[Guidance Overview] PPA Technical Corrections to Defined Benefit Governmental Plans and Non-Electing Church Plans (PDF)
2 pages. Excerpt: "On December 23, 2008, President Bush signed into law the Worker, Retiree, and Employer Recovery Act of 2008 (WRERA), which contains technical corrections to the Pension Protection Act of 2006 (PPA). Some of the provisions of WRERA affect defined benefit governmental plans and plans sponsored by churches that do not elect to be covered by ERISA ('non-electing church plans')." (Prudential Retirement)
[Guidance Overview] Pension Protection Act Amendments that are Required in 2009
Excerpt: "It doesn't matter what Cycle your plan is on -- PPA amendments must be done this year. And for Cycle D plans, this means the amendment must be adopted by 12/31/09, not by 1/31/10, when Cycle D plans are due at the IRS." (Stevenson Keppelman Associates)
[Guidance Overview] Rev. Proc. 2008-50: Some Changes to the EPCRS Non-Amender Rules
Excerpt: "Effective January 1, 2009 (or if chosen by the employer as of September 2008), the IRS released Rev. Proc. 2008-50, updating the Employee Plans Compliance Resolution System (EPCRS). EPCRS is an IRS program that allows for plan sponsors to proactively correct mistakes, ultimately protecting a plan's tax-favored status. Included in the update are important rules regarding the process of voluntarily correcting a failure to amend a qualified retirement plan in a timely manner." (McKay Hochman Co.)
[Guidance Overview] Final IRS Automatic Contribution Regulations
Excerpt: "On February 23, 2009, the IRS released final automatic contribution regulations. The regulations cover two major changes to 401(k) rules made by the Pension Protection Act of 2006 (PPA) ? the PPA automatic contribution safe harbor and rules allowing the distribution of 'automatic' contributions where a participant elects out (within 90 days) of an automatic contribution program. Not all sponsors of automatic contribution programs will be interested in the safe harbor. Often, automatic contributions alone -- that is, without safe harbor matching contributions, vesting, etc. -- are sufficient to solve a sponsor's 401(k) nondiscrimination testing issues. But the new 90-day distribution rules are likely to be of interest to most sponsors of automatic contribution arrangements, particularly those with immediate eligibility." (JPMorgan Chase & Co.)
[Guidance Overview] Worker, Retiree, and Employer Recovery Act Provision of Relief for Defined Contribution Plans (PDF)
4 pages. Excerpt: "This new law applies to sponsors of and participants in qualified defined benefit and defined contribution plans, including multiemployer plans, governmental plans, and church plans that do not elect to be covered by ERISA ('non-electing church plans'). It also applies to ERISA and Non-ERISA 403(b) plans and governmental section 457(b) plans." (Prudential Retirement)
[Guidance Overview] Summary Plan Description and Summary of Material Modifications Requirements
Excerpt: "With only a few exceptions, it has been the law for more than 30 years that the plan administrators for all employee pension plans and employee welfare plans that are subject to ERISA are required to issue and periodically update SPDs for those plans. This is not news, but worth mentioning especially now that many plan sponsors have updated plans for recent law changes." (Dorsey & Whitney LLP)
[Official Guidance] Joyce Kahn, IRS Voluntary Compliance Manager, Wants Comments -- Good or Bad -- from Practitioners and Employers on the Self-Correction Program; Short Survey Request
March 20 is the last day to take the survey. Excerpt: "We are looking for feedback on the Employee Plans Compliance Resolution System. IRS Employee Plans is conducting a short, voluntary, and anonymous survey designed to gauge the relevance and usefulness of the Self-Correction Program (SCP). Your participation in this survey will greatly assist us in making our programs more responsive to the needs of plan sponsors, employees, and beneficiaries of the retirement plan system. The anonymous survey should takes less five minutes to complete. We thank you in advance for your participation and look forward to future improvements that work for you!" (Internal Revenue Service)
[Guidance Overview] Practioners' Forum Discussion on Qualified Retirement Plans: Timing of Interim and Discretionary Amendments
Excerpt: "The [target page] is a summary of an informal discussion of employee benefit practitioners held in Washington, D.C. on January 15, 2009. The topic involved the deadlines prescribed by the IRS in Rev. Proc. 2007-44, 2007-28 I.R.B. 54, for adopting interim and discretionary amendments to qualified retirement plans." (Tax Management Inc.)
[Guidance Overview] 2008 Pension Legislation and Amendment Reminders
Excerpt: "All qualified retirement plan sponsors, regardless of their remedial amendment cycle, must continue to amend their plans timely to comply with IRS 'interim' amendment requirements. For example, many plans will have to be amended by the due date for the plan sponsor's 2008 tax return to reflect applicable changes in the maximum benefit and maximum contribution limits under Internal Revenue Code Section 415. Also, amendments to reflect applicable provisions of the Pension Protection Act generally must be executed by the last day of the 2009 plan year." (Bond, Schoeneck & King, PLLC)
[Official Guidance] Text of IRS 'Retirement News for Employers' for Winter 2009 (PDF)
12 pages. Articles include: Did You Amend Your SIMPLE IRA Plan for EGTRRA? New Law Waives Required Minimum Distributions for 2009; Automatic Enrollment 401(k) Plans for Small Businesses; Fixing Common Plan Mistakes: Failure to Limit Contributions for a Participant; New Form 990 Requirements; Desk Side Chat With Monika Templeman - The Biggest Mistake. (Internal Revenue Service)
[Guidance Overview] The Employee Plans Compliance Resolution System - Updated And Improved
Excerpt: "The latest IRS updates to EPCRS (Rev. Proc. 2008‑50) became effective January 1, 2009, and result in some very real improvements to the retirement plan correction system. This article analyzes three of those changes: The guidance for correcting specific qualification failures. Correction principles applicable to all types of failures. Procedures for using EPCRS." (Chang, Ruthenberg & Long PC)
[Guidance Overview] 2009 ERISA Compliance Calendar for DB/DC/403(b) Plans
Excerpt: "Note: Plan amendments for ?provisions of the Pension Protection Act of 2006 should be retroactively effective and will not violate ?anti-cutback rules if made on or before the last day of the plan year beginning on or after January 1, 2009 (or 2011 for governmental plans)." (PLANSPONSOR.com; free registration required)
[Guidance Overview] The Worker, Retiree, and Employer Recovery Act of 2008: An Overview (PDF)
13 pages. Excerpt: "In December of 2008, Congress unanimously enacted the Worker, Retiree, and Employer Recovery Act of 2008 (WRERA) (P.L. 110-455), which makes several technical corrections to the Pension Protection Act of 2006 (P.L. 109-280) and contains provisions designed to help pension plans and plan participants weather the current economic downturn. This report highlights the provisions of WRERA relating to the economic crisis, such as the temporary waiver of required minimum distributions and provisions that temporarily relax certain pension plan funding requirements. This report also discusses certain technical corrections to the Pension Protection Act made by WRERA, and certain other notable provisions of the Act affecting retirement plans and benefits." (Congressional Research Service)
[Guidance Overview] PPA Technical Corrections Affecting Defined Benefit Plans
Excerpt: "This article is focused on technical corrections that relate to defined benefit plans." (Deloitte LLP via BenefitsLink.com)
[Guidance Overview] Pension Funding Relief and Technical Corrections to PPA
Excerpt: "The Worker, Retiree and Employer Recovery Act (WRERA), signed into law on Dec. 23, 2008, provides some funding relief to defined benefit (DB) sponsors affected by recent market declines, as well as temporarily waiving the minimum distribution rules for seniors. The act also makes permanent technical corrections to the Pension Protection Act of 2006 (PPA). [This article includes charts of both temporary and key permanent provisions.]" (Watson Wyatt Worldwide)
Registration Deadline Extended to Friday, January 9 for Enrolled Retirement Plan Agent Designation Exams
Examinations are now being offered for retirement plan practitioners who are not eligible to act as clients' agents pursuant to IRS Form 2848 and who seek the new IRS-blessed Enrolled Retirement Agent Designation. The examinations are being offered during 'window' periods; the first window has opened and will remain open (i.e., the exam can be taken) through a date in mid-February. Registration to take the exam during this initial window period now can be made as late as Friday, January 9, according to an announcement on January 5 (the original deadline was January 6). As of Tuesday morning the text of the ERPA web site had not been updated to reflect the extension but practitioners can follow our hypertext link for immediate registration and more information. (American Institute of Retirement Education, a Partnership of ASPPA & NIPA)
[Guidance Overview] Key Provisions of the 'Worker, Retiree, and Employer Recovery Act of 2008' (PDF)
5 pages. Excerpt: "The . . . memorandum describes the key provisions of the Worker, Retiree, and Employee Recovery Act of 2008. This memorandum focuses on the provisions dealing with required minimum distributions, the funding requirements for defined benefit pension plans, and a handful of other provisions likely to be of interest to sponsors and administrators of private pension plans." (Groom Law Group)
[Official Guidance] Winter 2009 Issue of IRS 'Employee Plan News' (PDF)
Excerpt: "This edition contains the following articles: * Adopting a Pre-Approved Plan? No Need for a Determination Letter Application; * Under Consideration: Determination Letters without Amendment Dates; * Form 8905 - Certification of Intent to Adopt a Pre-Approved Plan; * Has Your Client's Plan Merged with Another Plan? Keep All Plan Documents! * New Address for EP Determination Applications; * Common Plan Language Errors; * Tips for Quick Processing of Employee Plans Determination Letter Applications; * Sound Off about the Self-Correction Program . . . ." (Internal Revenue Service)
[Guidance Overview] Extension of Deadline for 403(b) Plan Document Compliance
Excerpt: "However, in that operational compliance under the 'reasonable interpretation' standard is required as of January 1, 2009, 403(b) plan sponsors should still be considering the following open issues . . . ." (Groom Law Group)
[Guidance Overview] 403(b) Plan Document Delay
Excerpt: "The relief is very welcome, but advisors and employers need to know what it REALLY means. It DOES NOT mean there is a delay in the compliance rules, it merely delays the requirement that a plan document be signed by January 1. When you think about it, the plan document was the most manageable of the new 403(b) risks that the employers were facing. This does not delay the requirement that the employer monitor contribution limits, loans and distributions. It only means that the plan document outlining all of this doesn't have to be in place until the end of next year. It buys time to do that in a sane way." (National Benefit Services, Inc.)
[Guidance Overview] Compliance Dates for Employee Benefits (PDF)
Chart. 3 pages. (Swerdlin & Company)
[Guidance Overview] 403(b) Updates
Excerpt: "[T]he IRS issued Notice 2009-3 in which the deadline for adopting a written plan for a 403(b) was changed to December 31, 2009, provided the 403(b) plan operates under the final 403(b) regulations for the 2009 calendar year and adopts a written plan effective as of January 1, 2009 by December 31, 2009." (McKay Hochman Co., Inc.)
[Guidance Overview] 403(b) Deadline Extension
Excerpt: "The IRS has extended the written plan document deadline for 403(b) plans. On December 11, 2008, the IRS published Notice 2009-3 providing 501(c)(3) organizations and educational institutions additional time to adopt a written plan document for their 403(b) plans. According to this notice, 403(b) written plan documents must now be adopted on or before December 31, 2009. The notice also describes programs the IRS intends to establish to facilitate ongoing 403(b) compliance." (Blank Rome LLP)
[Official Guidance] Technical Explanation of H.R. 7327, the 'Worker, Retiree, and Employer Recovery Act of 2008,' As Passed by the House on December 10, 2008 (PDF)
43 pages. Excerpt: "The bill makes technical corrections to the Pension Protection Act of 2006 (the 'Act'), and provides for additional amendments to the Act, the Internal Revenue Code (the 'Code'), the Employee RetirementIncome Security Act of 1974 ('ERISA'), and the Age Discrimination in Employment Act of 1967 ('ADEA')." (U.S. Joint Committee on Taxation)
[Guidance Overview] Extension of 403(b) Written Plan Document Deadline
Excerpt: "Pursuant to Notice 2009-3, the IRS will treat 403(b) plans as meeting the requirements of the final regulations during the 2009 calendar year if: The plan sponsor has adopted a written 403(b) plan document by December 31, 2009 that is intended to satisfy the requirements of Code section 403(b) and the final regulations. The plan sponsor operates the plan during 2009 in accordance with a reasonable interpretation of Code section 403(b) and the final regulations. The plan sponsor makes its best effort by the end of 2009 to retroactively correct any operational failure during the 2009 calendar year to conform to the written plan." (Ballard Spahr Andrews & Ingersoll, LLP)
Key Technical Corrections in the Worker, Retiree, and Employer Recovery Act (PDF)
1 page. The document lists six key provisions. (American Benefits Council)
EBSA Semiannual Regulatory Agenda Addresses Plan Assets
Excerpt: "The Employee Benefits Security Administration (EBSA) has released its semiannual regulatory agenda for Fall 2008, which outlines regulations that have been selected for review or development during the next year, as well as any regulations that have been finalized during the last six months." (Wolters Kluwer)
IRS Offers Relief on 403(b) Written Plan Requirement
Excerpt: "The IRS issued a notice on Thursday announcing relief for 403(b) plans that do not have a written plan in place by January 1, 2009. Notice 2009-3 says the IRS will treat plans as meeting the requirements of 403(b) and the regulations during the 2009 calendar year if: By December 31, 2009, the plan sponsor has adopted a written 403(b) plan that is intended to satisfy the requirements of 403(b) and the regulations; During 2009, the plan sponsor operates the plan in accordance with a reasonable interpretation of 403(b) and the related regulations; and By the end of 2009, the plan sponsor makes its best effort to retroactively correct any operational failure during the 2009 calendar year to conform to the written plan." (PLANSPONSOR.com; free registration required)
Text of IRS Notice 2009-3: 403(b) Written Plan Document Not Required by End of 2008; Prototype Program Coming (PDF)
2 pages. Excerpt: "The Service will not treat a ? 403(b) plan as failing to satisfy the requirements of ? 403(b) and the final regulations during the 2009 calendar year, provided that: (1) on or before December 31, 2009, the sponsor of the plan has adopted a written ? 403(b) plan that is intended to satisfy the requirements of ? 403(b) (including the final regulations) effective as of January 1, 2009; (2) during 2009, the sponsor operates the plan in accordance with a reasonable interpretation of ? 403(b), taking into account the final regulations; and (3) before the end of 2009, the sponsor makes its best efforts to retroactively correct any operational failure during the 2009 calendar year to conform to the terms of the written ? 403(b) plan, with such correction to be based on the general principles of correction set forth in the Service's Employee Plans Compliance Resolution System (EPCRS) . . . ." (Internal Revenue Service)
[Guidance Overview] Cycle D 2008 Cumulative List of Changes for ERISA Qualified Plans
Excerpt: "According to the IRS, this list is principally to be used by plan sponsors of individually designed plans which are considered Cycle D plans. Generally, a plan is considered a Cycle D plan if the plan sponsor's EIN ends in either 4 or 9, or if it is a multiemployer plan under ?414(f)." (Aiken & Aiken)
[Guidance Overview] 2008 Cumulative List of Changes in Plan Qualification Requirements for Cycle D Plans
Excerpt: "All sponsors of Cycle D plans and their advisors should carefully review the 2008 Cumulative List to ensure that their submissions address the issues the IRS has specifically identified for review in the determination letter process. While most of the 'new' items applicable to 401(k) plans relate to PPA changes that were separately listed (but not required) in prior lists, the 2008 Cumulative List adds recent PPA guidance that will need to be taken into account as well. Of course, to be qualified, plans must comply with all relevant qualification requirements, even those that are not on the list." (Employee Benefits Institute of America)
[Guidance Overview] Year-End Checklist for Benefit Plan Sponsors (PDF)
3 pages. Retirement Plans, 403(b) Plans, Deferred Compensation Plans, and Health and Welfare Benefit Plans are covered on a checklist of compliance actions and design decisions that benefit plan sponsors should make before the end of the year." (Venable LLP)
[Guidance Overview] 2008 Plan Year: Year-End Compliance Reminders for Defined Contribution Plans Subject to ERISA (PDF)
4 pages. Excerpt: "This information applies to qualified defined contribution plans and 403(b) plans that are subject to Title I of ERISA. Every year, plan sponsors must make sure their plans meet certain compliance requirements, including those listed . . . . This publication identifies the materials you need to review and will help you prepare for year-end." (Prudential Retirement)
[Guidance Overview] 2008 Year-End Compliance Reminders - for Defined Contribution Plans Not Subject to ERISA (PDF)
2 pages. Excerpt: "This information applies to defined contribution plans, such as qualified governmental plans (including 'grandfathered' 401(k) plans), qualified church plans that do not elect to be covered by ERISA ('non-electing church plans'), 403(b) programs, and section 457 plans that are not subject to Title I of ERISA. Every year, defined contribution plan sponsors should make sure their plans meet certain compliance requirements, including those listed . . . . This publication identifies the materials you need to review and will help you prepare for year-end." (Prudential Retirement)
[Official Guidance] Listing of IRS Published Guidance for January - November 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)
[Guidance Overview] IRS Releases Cumulative List for Cycle D Plans
Excerpt: "This Cumulative List states that the IRS, when reviewing determination letter applications for Cycle D plans, will not consider any: '(1) guidance issued after October 1, 2008; (2) statutes enacted after October 1, 2008; (3) qualification requirements first effective in 2010 or later; or (4) statutory provisions that are first effective in 2009, for which there is not guidance identified in this notice.'" (Pension Protection Act Blog)
[Guidance Overview] Speakers' Presentations to the 2008 Conference of the Public Pension Financial Forum
Topics include 'IRS Roundtable on Voluntary Compliance,' 'The Future of Public Sector Retirement Plans,' and '[Investment] Performance Calculations 101." (Public Pension Financial Forum)
[Guidance Overview] IRS Modifes Remedial Amendment Cycle Rules for Governmental Plans (PDF)
2 pages, but they're cherce, as Spencer Tracy might say. Excerpt: "What if the plan sponsor has already filed during Cycle C? . . . . Are there any drawbacks to filing in Cycle E? . . . . Are there any benefits to filing in Cycle C?" (Pension Analyst by Prudential)
[Official Guidance] IRS Notice 2008-108: 2008 Cumulative List of Changes in Retirement Plan Qualification Requirements (PDF)
16 pages. Excerpt: "The 2008 Cumulative List is to be used primarily by plan sponsors of individually designed plans that are in Cycle D. An individually designed plan is in Cycle D if it is a single employer plan where the last digit of the employer identification number of the plan sponsor is 4 or 9, or it is a multiemployer plan under ? 414(f). The list of changes in section VI of this notice does not extend the deadline by which a plan must be amended to comply with any statutory, regulatory, or guidance changes." (Internal Revenue Service)
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