[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
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[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
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[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
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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
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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."
PlanPILOT
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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
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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
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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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