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[Guidance Overview]

How Recent Changes to RMD Rules Apply to Puerto Rico Participants in Dual-Qualified Plans

"[B]ecause Puerto Rico participants are generally subject to the payment of Puerto Rico income tax on the distribution of retirement benefits and RMDs are ineligible for tax-free rollovers under the Puerto Rico Internal Revenue Code, for local tax purposes a purported rollover of RMDs would be a taxable distribution. When implementing the recent [IRS] guidance allowing for rollovers of 2020 RMDs, sponsors and administrators of dual-qualified plans may want to consider informing Puerto Rico participants that in their cases such rollovers may have adverse tax consequences."

Ogletree Deakins


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[Guidance Overview]

How Did Beneficiary Distribution Options Change Under the SECURE Act?

"The [SECURE Act] provisions that Congress added to the Further Consolidated Appropriations Act, 2020, affected the distribution options for retirement plan beneficiaries in 2020 and beyond. The changes are summarized in the charts [in this article]."

Retirement Learning Center, LLC

[Guidance Overview]

IRS Allows Midyear Safe Harbor Retirement Contribution Changes

"The temporary relief provided in Notice 2020-52 should make the reduction or suspension of safe harbor contributions more attractive for safe harbor plan sponsors looking for ways to cut costs and navigate the unexpected financial challenges posed by the COVID-19 pandemic.... [A]mendments taking advantage of this relief must be adopted by Aug. 31, 2020."


Editor's Pick Voluntary Transfers of Uncashed Checks from ERISA Plans to State Unclaimed Property Programs (PDF)

48 pages. "[T]he focus of the [ERISA Advisory Council] was to gain an understanding of the nature and operation of state unclaimed property programs and to evaluate the extent to which they might advance the goal of reuniting Missing Participants with their retirement savings and whether there are circumstances under which a plan fiduciary might voluntarily transfer uncashed checks to a state unclaimed property program."

Advisory Council on Employee Welfare and Pension Benefit Plans, Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]

Initial Impacts of Coronavirus on Global Defined Contribution Plans (PDF)

"This report provides a snapshot of initial policy responses related to participant access to defined contribution (DC) plans.... [A] country's policy decision may not only reflect their stance towards DC plan assets but also whether the country has a robust safety net or other significant sources of guaranteed income.... Stakeholders in DC savings programs worldwide have come to understand that providing emergency liquidity access or loans against long-term savings can instill confidence and encourage higher levels of plan enrollment and savings deferrals."

Defined Contribution Institutional Investment Association [DCIIA]


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Editor's Pick 2020 PBGC Premium Burden Report (PDF)

36 pages. "[M]any plan sponsors continue to pay much more in PBGC premiums than they should.... Missed savings in 2018 alone were $40 million.... Most employers have taken steps to manage this growing burden by settling liabilities and making voluntary contributions.... Many employers have also adopted other, simpler strategies for reducing premiums ... [T]hree Large Plans ... have paid more than $10 million between 2011 and 2018 that could have been avoided simply by recording contributions optimally."

October Three Consulting

Citing Racial Justice, Senate Dems Push DOL to Withdraw ESG Proposal

"A group of Senate Democrats is calling on the [DOL] to withdraw its proposal clarifying the investment duties of ERISA plan fiduciaries in relation to environmental, social and governance (ESG) criteria, saying the proposal would discourage financial advisors from supporting racial justice. Addressed to Labor Secretary Eugene Scalia, the July 15 letter from 13 senior Democrats ... expresses 'deep concern' with the department's proposal and urges Scalia to withdraw it."

American Retirement Association [ARA]

Selected Discussions
on the BenefitsLink Message Boards

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Life Insurance for Participant Who Is Taking In-Service Distributions

"Based on the incidental death benefit rules, a life insurance policy cannot be held beyond retirement of the employee. If an employee is still active, yet is beyond 62 and is taking in-service distributions, must the policy on this employee be distributed/converted to cash value etc. as well? Is there a difference if the one taking the in-service distributions is an owner as opposed to an employee?"

BenefitsLink Message Boards

Open MEP Form 5500 Filing Requirements

"Am I understanding correctly that basically any MEP may file just one Form 5500 and just provide the attachment regarding the participating employers, the contributions, etc.? Or do Open MEPs need to file separate Form 5500s for their participating employers? Did that change for 2019 or has it always been that way?"

BenefitsLink Message Boards

Plan Failed to Make Two Very Small 2018 and 2019 Required Minimum Distributions

"Just took over a DB plan. Prior TPA did not alert two participants of the RMD requirements for 2018 and also for 2019. The amounts are very small -- possibly between a total of $100 to $500 range for each year. What's the recommended course of action?"

BenefitsLink Message Boards

Partner Has Negative Basis -- Still OK to Take a Pension Deduction?

"Can a partner take a deduction for pension contributions to his 401k plan if he has net earned income for the year but is carrying a negative partnership basis on the books?"

BenefitsLink Message Boards

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Press Releases

Most Popular Items in the Previous Issue, 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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