Retirement Plans Newsletter

September 17, 2015

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401(k)/Pension Sales Consultant
Farmer & Betts
in FL, NC, TN

Conversion Consultant
Aspire Financial Services LLC
in FL

Account Manager 403(b)-457 Markets
Aspire Financial Services LLC
in FL

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Aspire Financial Services LLC
in FL

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Transamerica
in VA

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Webcasts and Conferences

Cadillac Tax Round Two: IRS Notice 2015-52 Addresses More Issues
RECORDED
(Thomson Reuters / EBIA)

2015 Reinsurance Contributions: Form Completion, Submission, and Payment
September 23, 2015 WEBCAST
(Centers for Medicare & Medicaid Services [CMS])

2015 Reinsurance Contributions: Form Completion, Submission, and Payment
September 28, 2015 WEBCAST
(Centers for Medicare & Medicaid Services [CMS])

ACA Information Returns (AIR)
September 29, 2015 WEBCAST
(IRS [Internal Revenue Service])

2015 Reinsurance Contributions: Form Completion, Submission, and Payment
September 30, 2015 WEBCAST
(Centers for Medicare & Medicaid Services [CMS])

Recognizing and Addressing COBRA
November 11, 2015 WEBCAST
(Lorman Education Services)

IRA Basics
November 17, 2015 WEBCAST
(Ascensus)

Understanding Your Summary Plan Descriptions
December 3, 2015 WEBCAST
(Lorman Education Services)

2016 NTSA 403(b) Masters Summit
January 21, 2016 in AZ
(National Tax-Deferred Savings Association [NTSA])

View All Webcasts and Conferences


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[Guidance Overview]

PBGC Provides Premium Reminders
"For plan years starting in 2015, Small Plans are subject to the same Normal Due Date rules as all other plans.... For plan years starting in 2014, the transition due dates for Small Plans still apply.... We expect high filing activity leading up to October 15, 2015 (many plans have an October due date), so please file as soon as practicable. Be sure to use only the current Premium Payment Addresses for checks and electronic payments made outside of My PAA.... For small plans that had the opportunity to opt out of the Lookback Rule in the past but chose not to, PBGC permission is required to opt out." (Pension Benefit Guaranty Corporation [PBGC])  


[Advert.]

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PBGC Releases Updated Reportable Event Regs (PDF)
9 pages. "PBGC's final regulations include an array of waivers, many of which are continued from the prior regulations. Many waivers from the old regulations are gone -- primarily the alternative funding-based waivers. Four key waivers are expected to reduce the overall number of events that are required to be reported. The four waivers apply to five of the six events that accounted for over 90 percent of filings between 2012 and 2014." (Buck Consultants at Xerox)  

PBGC Reportable Events Rule Focuses on Plans Most at Risk
"The rule will change existing regulations and guidance for pension plans and their sponsors on requirements they face on the reporting to the PBGC of various corporate events, such as loan defaults and controlled group changes, and plan events, such as big drops in the number of active plan participants, missed plan contributions or insufficient funds." (Bloomberg BNA)  

Participant Distribution Decisions Have Implications for Plan Design
"The tendency of participants to preserve plan assets at retirement supports the notion of 'through' glide paths in target-date fund (TDF) design, Vanguard suggests. In other words, target-date designs should encourage an investment strategy at retirement that recognizes assets are generally preserved for several years post-retirement. Also, with the rising importance of lump-sum distributions, participants will need assistance in translating these pools of savings into a regular income stream. Based on current retirement-age participant behavior, most of these retirement income decisions will be made in the IRA marketplace, not within employer-sponsored qualified plans[.]" (PLANSPONSOR)  

Auto-Enrollment for Some Non-ERISA Plans
"[The City of Los Angeles] is relying on an exception contained in California Labor Code section 224 that provides that a wage deduction for pension plan contributions should not violate section 221 as long as it is expressly approved in a collective bargaining agreement. This strategy/technique appears to open the possibility of auto-enrollment to a much larger potential audience including sponsors of non-ERISA plans like state and local governments, public agencies and churches." (Chang Ruthenberg & Long PC)  

Are You Running Your 401(k) Plan on Faulty Facts?
"It's been wrongly assumed that by switching [from a defined benefit plan] to a defined contribution plan all of the risk is transferred to the participants. While the risk for making ongoing contributions goes away, the risk of investment oversight increases. Poor investment returns on a pension plan mean that the plan sponsor has to kick in more dollars. In a defined contribution pension plan aka 401(k) plan, the risk shifts to investment and plan fee oversight.... Arguably the 401(k) plan increases complexity and the need for investment fiduciary literacy." (Envision 401k Advisors)  

Retirement Update: Market Results, Key Interest Rates in August 2015 (PDF)
7 presentation slides. Topics: [1] What happened in August 2015? [2] Market Summary -- total returns through August 2015; [3] Penbridge pension risk transfer index; [4] Ryan labs index; [5] Charts showing key interest rates for DB plans; and [6] Upcoming regulatory due dates. (P-Solve LLC)  

A Moderate Retirement Saver Portfolio
"How different should your portfolio look when you're in your 40s versus how it was positioned when you were just starting out? Not all that different, it turns out." (Morningstar)  

IRA Asset Allocation in 2013, and Longitudinal Results from 2010 to 2013 (PDF)
"54.7 percent of the assets were in equities, 10.1 percent in balanced funds, 15.3 percent in bonds, 11.6 percent in money, and 8.4 percent in other assets ... When combining the equity share of balanced funds to the equity allocation, the total equity exposure of IRA owners was 60.7 percent of the assets.... For IRAs owned by those ages 25 or older, the percentage allocated to bonds increased with the age of the owner ... The percentage of IRA assets in equities had no clear pattern across the ages of the owners." (Employee Benefit Research Institute [EBRI])  

Federal Employers Address Phased Retirement, Consider Automatic Escalation of TSP Contributions
"[T]he Environmental Protection Agency has started a program allowing most retirement-eligible, full-time employees to ease into retirement gradually ... The Housing and Urban Development Department also has notified employees ... that a partial retirement program is on the way ... [The Thrift Savings Plan is] discussing the possibility of legislation to automatically increase TSP contribution levels ... Increasing contributions annually until they reach 5 percent would allow participants to take full advantage of agency matching contributions." (Government Executive)  

[Opinion]

Text of ASPPA Comments to IRS Requesting Filing of Form 5500-SUP Be Made Voluntary for the 2015 Reporting Year (PDF)
"[As] of this date, no official guidance is available to the public that would enable service providers to take decisive action. The draft forms and instructions, together with the governmental responses to issues identified at the EFAST2 developers meeting in June 2015, are not yet final and continue to raise numerous questions.... Because of the considerable time and expense involved in meeting the requirements of the SUP-data collection proposed by the IRS, ASPPA respectfully requests that filers be permitted to provide such information for the 2015 reporting year on a completely voluntary (optional) basis." (American Society of Pension Professionals & Actuaries [ASPPA])  

Benefits in General; Executive Compensation

[Official Guidance]

Text of IRS Notice 2015-63: 2015-2016 Special Per Diem Rates (PDF)
"This annual notice provides the 2015-2016 special per diem rates for taxpayers to use in substantiating the amount of ordinary and necessary business expenses incurred while traveling away from home, specifically [1] the special transportation industry meal and incidental expenses (M&IE) rates, [2] the rate for the incidental expenses only deduction, and [3] the rates and list of high-cost localities for purposes of the high-low substantiation method." (Internal Revenue Service [IRS])  

Social Security and Medicare Lifetime Benefits and Taxes
"Benefits from government retirement programs -- Social Security and Medicare -- vary over time, but the trend has been toward higher lifetime benefits for each successive cohort. Expansion derives mainly from increases in real annual benefits, more years of benefits through longer lifespans, and better and more expensive health care. In 1960, a couple where each spouse earned constant 'average' wages over a career beginning at age 22 and retired on his or her 65th birthday would receive about $300,000 in health and retirement benefits; today, that figure is over $1 million in health and retirement benefits. The expected benefits for couples turning 65 in 2050 -- age 30 today -- are scheduled to rise under current law to almost $2 million." (Urban Institute)  

Pay vs. Performance Disclosure Issues for Your Upcoming Proxy
"Companies/Committees that don't currently use relative TSR as a metric in executive pay will have two options. One is to switch to TSR as a performance measure, despite its many flaws. The other is to explain in the Compensation Disclosure & Analysis section why the performance metric the Committee uses to determine executive pay is better.... [It] may be a challenge to get proxy statement readers to continue reading the Committee's explanation of the unique performance measures it actually uses. (Charts will be preferable to text.)" (Winston & Strawn LLP)  

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