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May 11, 2020 logo logo
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View Coronavirus (COVID-19) News and Resources

[Guidance Overview]

Coronavirus-Related Distributions: Requirements and Practical Considerations

"Some vendors implemented an 'opt-out' approach for the plans they administer, while others implemented a more conservative 'opt-in' approach. Accordingly, it is possible that CRDs were permitted in operation from a retirement plan before a plan sponsor had time to consider whether to adopt this optional provision.... [In] many cases there will be very little effective oversight as to whether the employee truly meets the criteria of a qualified individual, making this an in-service distribution option that could be exercised by potentially any employee."

Ice Miller LLP

[Guidance Overview]

IRS FAQs Provide Coronavirus Relief for Retirement Plans and IRAs

"Even if a qualified individual repays a coronavirus-related distribution in the same year, the coronavirus-related distribution must be reported by the plan on Form 1099-R.... Employers are not required to make changes to plan loan limits or loan repayment schedules that satisfy the provisions of Section 2202 of the CARES Act."

Husch Blackwell

[Guidance Overview]

IRS Issues FAQs on Coronavirus-Related Retirement Plan Distributions and Loans

"[P]lans generally are not required to accept rollover contributions, so the FAQs indicate that a plan that does not accept any rollover contributions will not be required to change its terms or procedures to accept these repayments.... [T]he CARES Act does not provide any exception to the joint and survivor annuity rules."

Calfee, Halter & Griswold LLP

[Guidance Overview]

Suspension of Required Minimum Distributions: Details and Practical Considerations

"[N]ot all retirement plan vendors are giving plan sponsors a choice as to how to implement the RMD waiver. Rather, some vendors have made decisions as to when they will suspend and when they will continue RMD payments, and plan sponsors cannot deviate from those decisions. Accordingly, plans with multiple vendors may in actual operation be implementing the RMD waiver in different ways."

Ice Miller LLP

Editor's Pick Current Summary of States Permitting Remote Notarization

"The chart lists states with temporary remote notarization procedures. It does not list states with pre-existing remote notary statutes and states requiring use of a third-party remote online notarization service."


DOL to Issue RFI on Pooled Employer Plans

"For aspiring pooled plan providers and industry groups representing financial services companies or potential adopting employers, this RFI may provide a valuable opportunity to help shape future DOL guidance on fiduciary and potential prohibited transaction issues confronting PEPs."

Morgan Lewis

Evaluating Your Plan's Recordkeeper

"By keeping this four-factor framework in mind, you will be in a strong position in evaluating a recordkeeper or to find the right recordkeeper for your plan. Do not be afraid to ask tough questions of any prospective candidates; in today’s turbulent market, doing your due diligence as a plan sponsor has gained new importance."


Markets 2020: Settling DB Plan Liabilities

"[1] Lump sum valuation rates generally are more favorable than current market rates.... [2] Savings in PBGC premiums may be considerable.... [3] Many participants need cash now and may be eligible for favorable tax treatment.... [4] The one wild card facing sponsors is the direction of future interest rates."

October Three Consulting

Markets 2020: Effect on DC Plan Participants, Assets, Interest Rates, and Retirement Income

"The effect of asset gains/losses is obvious.... [I]nterest rate declines represent an increase in the cost of retirement income ... Mandatory lifetime income disclosure -- adopted in the SECURE Act -- is intended to make this relationship explicit[.]"

October Three Consulting

Should You Add a Gold Fund to Your 401(k) Plan?

"Reasons to consider adding a gold fund ... Reasons not to add a gold fund ... What you should do if you wish to add a gold fund to your 401k."

Lawton Retirement Plan Consultants

Selected Discussions
on the BenefitsLink Message Boards

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Transaction Privilege, Use, and Severance Tax Return for Arizona Dept. of Revenue (TPT-EZ)

"One of our CPA contacts, for a client NOT located in Arizona but in Northeastern U.S., received this form from the Arizona Department of Revenue. We don't administer the plan, but the CPA has never seen such a form, and asks whether we know anything about it. Is this a 'normal' thing that actually applies to a defined benefit or other qualified plan in Arizona, perhaps similar to the (often ignored) loan document fee in Florida?"

BenefitsLink Message Boards

Safe Harbor Mid-Year Change to Immediate Eligibility and Full Vesting

"Can a safe harbor plan change to immediate eligibility and vesting mid-year? I believe they can with notice, because it's an increase in benefits. But does that then mean anyone not previously vested would become 100% vested?"

BenefitsLink Message Boards

Auto Increases Under an EACA -- Any Maximum Amount?

"There is no maximum auto escalate number on an EACA like there is on a QACA, correct? So I could auto escalate to 20% if I wanted to?"

BenefitsLink Message Boards

Pooled Account -- Amend to Make an Immediate Distribution?

"All of our plans having pooled trustee directed accounts allow for distribution during the first plan year following termination of employment. Client has a terminated participant whom they want to pay out immediately, and is considering amending to allow immediate distributions. How many plans out there allow for immediate distribution from a pooled plan? Are there any drawbacks to be considered?"

BenefitsLink Message Boards

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Press Releases

Minnesota Center for Employee Ownership Officially Opens
National Center for Employee Ownership [NCEO]

Most Popular Items in the Previous Issue

Steps Plan Sponsors Should Take to Implement the FFCRA and the CARES Act
International Foundation of Employee Benefit Plans [IFEBP], Inc.
1298 Minnesota Avenue, Suite H
Winter Park, Florida 32789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

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BenefitsLink Retirement Plans Newsletter, ISSN no. 1536-9587. Copyright 2020, 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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