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Retirement Plans Newsletter August 31, 2020 |
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Newly Posted Retirement Policy in a Pandemic
IRA University
IRA Withholding and Getting it Right
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Discussions |
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This Newsletter:
BenefitsLink Health & Welfare Plans Newsletter:
Message Boards Digest:
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[Official Guidance]
"PBGC intends to modify its information collection to require additional information about missing participants in two categories in order to properly withhold taxes when such participants are located and their benefits claimed and paid. For DC plans that permit Roth accounts, PBGC intends to require a breakdown of qualified and non-qualified Roth amounts transferred to PBGC (if any), and if non-qualified Roth amounts are being transferred, the date the first Roth contribution was made. Where relevant for DB and DC plans, PBGC intends to require identification of the portion of a participant's benefit transfer amount treated as foreign-source income, and if so, for DB plans how that determination was made. PBGC as administrator of the Missing Participants Program relies on information provided and certified to by the plan administrator or plan sponsor as
applicable." Pension Benefit Guaranty Corporation [PBGC] |
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[Sponsored]
Virtual SPARK Forum -- Nov. 4-6 The retirement services industry's leading event for top 401(k) Plan providers, advisors, consultants, administrators & recordkeeping professionals. Join the Virtual SPARK Forum, gain expert insights and strategies to solve your most pressing challenges.
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[Guidance Overview]
"In general, a plan with a calendar plan year will have no particular need for an election to use the prior year's AFTAP as the market downturn in the spring did not affect the beginning of the year value of the plan's assets. If, however, the plan sponsor plans to make the minimum required contribution for 2019 later than September 30 and the inclusion of the contribution in the assets would be needed to avoid benefit restrictions, then the plan sponsor may desire to make the election." Cheiron |
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[Guidance Overview]
"With respect to qualified defined benefit pension plans, the CARES Act extended the deadline for making minimum required contributions until January 1, 2021, and permitted plans to use the prior year's AFTAP for purposes of any funding-based benefit restrictions. With Notice 2020-61, the IRS has provided guidance on the mechanics of this contribution and benefit restriction relief. The IRS did not provide relief, however, for the fact that January 1, 2021, is a national holiday, meaning that the actual deadline for making any required contribution is December 31, 2020." Seyfarth |
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"Because the DOL does not detail their selection process, understanding why your ESOP is under investigation remains unclear.... DOL enforcement agencies typically provide little advance notice, so knowing how to respond before an investigation begins is critical.... [T]he department does provide online access to its enforcement manual, detailing their internal audit guidelines and checklists." Findley |
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[Opinion]
"While clearly condemning social investing in ERISA plans, the DOL Secretary issued a letter on May 11 to the Thrift Savings Plan -- the retirement saving vehicle for federal government employees -- ordering it to not include equities in Chinese companies in its investment options." MarketWatch |
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Executive Compensation |
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"For some companies, it may make perfect sense to tie pay to ESG metrics. Certain industries have clearer ESG initiatives that are already measured, tracked, and disclosed, such as utilities and energy ... and consumer products companies ... [F]or other companies ... it may be too soon to consider including such metrics into pay programs. [In] either case, it is important to identify critical focus areas for your organization, understand your current state, and increase transparency, both internally and externally." Meridian Compensation Partners, LLC |
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"Equity award vesting and furloughs ... Performance-based compensation ... Compensation compliance obligations ... Pre-negotiated severance pay.... Deferred salary and pay reductions.... Trading cash for equity.... Severance plans or policies ... Option pricing and repricing." Hall Benefits Law |
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Selected Discussions |
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► It's easy to sign up and participate in discussions! Post answers, ask questions, create custom feeds and views. Join your peers (and potential referral sources or customers)—there is no charge. |
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"Short plan year 2020. Plan terminated 6/30/20. Employer wants to do PS. Has last day/500 hour rule. Does that 500 hour threshold get prorated to 250?" BenefitsLink Message Boards |
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"A 401(k) plan provides safe harbor match of 100% up to 6% deferred and permits employee after-tax contributions. In performing the ACP test can I [1] include all match and after-tax, or [2] match over 4% and after-tax? I am really looking for cites from the statutes or guidance for the first option, which I haven't been able to find." BenefitsLink Message Boards |
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Press Releases |
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Most Popular Items in the Previous Issue |
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Top Hat Plans: What Executives and Organizations Need to Know
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