Retirement Plans Newsletter

April 25, 2017 logo logo
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[Official Guidance]

PBGC Updates My PAA, for Online Premium Filing
"For each plan that is in your My PAA account, you can now view the following information via the Plan Page for all successfully submitted comprehensive premium filings for all e-filing methods: the filing receipt ... and the status of each submitted filing ... For in-process filings that were screen-prepared or imported ... Some of the data may be prepopulated on the screens for your review ... Additional validations and warnings may be displayed[.]"
Pension Benefit Guaranty Corporation [PBGC]


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[Guidance Overview]

DOL Charts a New Course for ERISA's Fiduciary Rule
"[C]ompliance with the Fiduciary Rule and the related PTEs is generally not required until June 9, 2017.... Compliance with the remaining conditions of the [BIC Exemption] and with the amendments to [PTE 84-24] ... will not be required until January 1, 2018.... [A chart] provides a high-level summary and timeline of the applicability of the various aspects of the fiduciary rulemaking, and identifies a few discrete issues that industry participants might consider in anticipation of the June 9 applicability date[.]"

[Guidance Overview]

Oregon Moves Ahead with State-Run IRA Program
"Starting Nov. 15, 2017, Oregon employers with 100 or more employees must begin to register with the program, either certifying that they already offer their workers access to a qualified retirement plan or automatically enrolling them into OregonSaves, the state-run auto-IRA program for private sector workers.... [By] May 15, 2020, all employers that either: [1] employ one or more individuals 18 years or older for 18 separate weeks during the year; or [2] whose quarterly payroll is $1,000 or more, will have to register with the program." [See also the text of the Permanent Rules approved by the Oregon Retirement Savings Board, Apr. 18, 2017.]
National Tax-Deferred Savings Association [NTSA]

[Guidance Overview]

2017 ERISA Requirements Calendar
"The 2017 Expanded Reporting and Disclosure Requirements Calendar provides who, what, when and where reporting and disclosure information for single-employer pension plans under [ERISA]. Plan administrators can access concise instructions for filing reports with the [DOL], IRS and [PBGC], and for disclosing tax and benefit information to U.S. plan participants, beneficiaries and alternate payees."
Willis Towers Watson

IRS Drops New Form 5500 Compliance Questions (For Now)
"[DOL recently filed with OMB] draft copies of the 2017 Form 5500, including the related schedules and instructions.... [T]he 2017 form does not include the new IRS 'compliance' questions.... [This] is a strong indication that the new questions will only be implemented in the future in conjunction with the Form 5500 modernization proposal.... Although slated to be effective for the 2019 plan year, it is quite likely that schedule will be slowed down."
American Society of Pension Professionals & Actuaries [ASPPA]


Form 5500 Reporting Update

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Apr. 26 webinar. Learn when you need to file a Form 5500 and what you need to file, with focus on some recent changes that may impact your filings.

Reasons to Consider Unbundled Providers for Small 401(k) Plans
"[1] Data reliability.... [2] Costs may not be that much higher.... [3] Unbundled providers ... usually offer higher quality services in their area of expertise.... [4] Partnering with a best-in-class investment advisor who has good working relationships with recordkeepers and TPAs can allow you to find other providers who work well together on your behalf.... [5] An unbundled provider has a lot more flexibility with plan design and consulting to allow you to customize to your needs."
Buddy Horner, of Bronfman E.L. Rothschild, via

401(k) Fiduciaries: Is It Time to Hone Your Processes? Part One
"The litigation has widened and deepened the scope of the threat. Processes, as good as they have been in the past, may not be good enough now. Something more may be required that requires plan sponsors to look at a hard look at their existing practices and to improve them if necessary."
Fiduciary Plan Governance, LLC

Flurry of Pension Rescue Filings May Indicate Renewed Confidence
"Four more financially beleaguered multiemployer pension plans are ... seeking Treasury Department permission to cut benefits.... The filings show 'increased trustee and adviser confidence' that plan trustees now 'know what standards will be applied and that approval is possible,' Dominic DeMatties, a partner with Alston & Bird, [said] ... That's in the wake of the first approval of a request to cut benefits and as plans have digested final regulations issued a year ago[.]"
Bloomberg BNA

Addressing the Unique Investment Challenges of Multiemployer Defined Benefit Plans
"Across asset classes, active management and the relentless pursuit of alpha are crucial to generating needed returns. Private investments could be the single biggest driver of asset return for many plans ... [I]ndividual investment strategies and the entire portfolio should be tailored to each plan's specific participant demographics, economic conditions, and risk tolerances. Use of these sophisticated strategies can introduce heightened illiquidity, volatility, and drawdown risks. Long-term success requires effective approaches to designing, executing, and monitoring these strategies, and diligently managing their risks."
Cambridge Associates


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The 411 On Your 401(k): What You Should Know About Your Retirement Savings
"[1] How much money am I saving? ... [2] Do my contributions automatically increase? ... [3] Do I have a Roth option in my 401(k) plan? ... [4] Can I access my money while I am working? ... [5] How do I take my money out when I retire?"

Who Contributes to Individual Retirement Accounts?
"Today, IRAs hold nearly half of all private retirement assets, but most of these funds are rollovers from 401(k)s, rather than contributions. The 14 percent of households who do contribute to IRAs include: higher-income dual-earners who also save in a 401(k); moderate-income singles or one-earner couples, often with a 401(k); and higher-income entrepreneurs with no current 401(k)."
Center for Retirement Research at Boston College

The Dangers of Planning on Working Longer
"[N]early two-thirds of retirees left the workforce earlier than expected because they were laid off, reorg-ed out of a position, or due to general unhappiness with a job.... [On] a company-wide level, delayed retirement can increase overall workforce costs by 1 percent to 1.5 percent.... [That] goes a long way in explaining why employers may be more inclined to focus on 'financial wellness' strategies to get workers ready to retire sooner than programs to help workers delay retirement."


The Invisible Hand Did Wonders for 401(k) Plans, but Now Washington Should Lend a Hand
"The process that has successfully guided the growth of the 401(k) system appears to have run its course.... The 401(k) industry now faces three challenges that are unlikely to be resolved without Washington's assistance. One is the difficulty of signing up smaller companies.... Another snag is the high costs paid by smaller companies that do adopt a plan.... The third problem lies with larger companies. They are beset by class-action lawsuits from legal firms seeking to profit from the settlements."
John Rekenthaler, in Morningstar

Discussions on
the BenefitsLink Message Boards

Handling 'Late' Matching Contributions Under the Terms of a Plan
"Under the terms of the 401(k) plan, the matching contributions should be made by the time for filing of the employer's tax returns, including extensions. And of course, under Code section 404(a)(6), they have to be made by then in order to be deductible on the prior year's tax return. In this case, the calculation of the matching contributions for 2016 got bogged down, and still hasn't happened. But over in finance, they got very efficient and actually filed the corporate return on March 15, without ever requesting an extension. So, it would appear we may have two problems."
BenefitsLink Message Boards

Press Releases

Anna Rappaport Receives PSCA Lifetime Achievement Award
PSCA [Plan Sponsor Council of America]

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BenefitsLink Retirement Plans Newsletter, ISSN no. 1536-9587. Copyright 2017, Inc. All materials contained in this newsletter are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

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