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Retirement Plans Newsletter

July 29, 2021

4 New Job Opportunities


[Guidance Overview]

IRS Issue Snapshot: Fully Insured 412(e)(3) Plans

"This Issue Snapshot discusses requirements applicable to fully insured plans under IRC Section 412(e)(3). The IRS issued guidance in 2004 and 2005 to stop abuses involving the use of certain specially designed life insurance policies in retirement plans. See Rev. Rul. 2004-20, Rev. Rul. 2004-21 and Rev. Proc. 2005-25.... The issues from the guidance also form the basis of some of the issue indicators or audit tips."  MORE >>

Internal Revenue Service [IRS]

[Sponsor] -- Qualified Plan eSource: Major Update

Ilene H. Ferenczy, JD has completely re-written the 401(k) chapter in the Qualified Plan eSource. 260+ pages of new material, 220 examples supplemented by 400 Q&As from our Ask the Author service. Contact us at: or 612-605-2266

Sponsored by Burrmont Compliance Labs LLC

[Guidance Overview]

Updated IRS Correction Principles and Changes to VCP Outlined in EPCRS Revenue Procedure 2021-30

"Rev. Proc. 2021-30 updates EPCRS, making several major changes and other revisions to the correction programs. [This page provides] highlights of some of these changes.... The Treasury Department and the IRS invite comments from the public on how we can improve EPCRS."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

IRS Issues Update to Qualified Plan Correction Procedures

"[T]he most significant changes to EPCRS relate to the correction of plan overpayments.... [T]he Revenue Procedure has been revised and reformatted to include helpful clarifications relating to the long-standing return of overpayment method, as well as two new correction methods that plan sponsors may use to correct defined benefit plan overpayments."  MORE >>

Seyfarth Shaw LLP

[Guidance Overview]

Relaxed IRS Self-Correction Rules Provide Opportunity to Correct Failures Now

"The increased flexibility of this retroactive plan amendment self-correction option, coupled with the extension of the two-year self-correction period for significant operational failures to a three-year period, is a boon for plan sponsors looking to correct operational failures under their plans and that ... otherwise would have been required to submit a formal application to the IRS under the Voluntary Correction Program (VCP) -- including the payment of a VCP user fee of up to $3,500 -- to obtain the IRS's approval of a proposed correction."  MORE >>

Morgan Lewis

[Guidance Overview]

IRS Goes for Gold with EPCRS Expansion

"[A chart] shows the key changes from the prior version of EPCRS that are effective beginning July 16, 2021, except as otherwise noted."  MORE >>

Eversheds Sutherland

Senate Finance Committee Hearing: Building on Bipartisan Retirement Legislation: How Can Congress Help?

Video of July 28 hearing, with links to witness testimony: [1] Aliya Robinson, The ERISA Industry Committee; [2] Brian H. Graff, American Retirement Association; [3] David Certner, AARP; and [4] The Honorable Tobias Read, Oregon State Treasurer.  MORE >>

Committee on Finance, U.S. Senate

The Mega Backdoor Roth: Here We Go Again

"The Mega Backdoor Roth comes into play in one of two ways. The individual either takes an in-service withdrawal and rolls it to a Roth IRA or utilizes an in-plan Roth rollover feature to convert to Roth within the plan. This may sound like a complicated cool investment strategy, but it RARELY works."  MORE >>


What Empower's Purchase of Pru Retirement Business Means for Advisers

"What is the value of an adviser to record keepers? The overwhelming answer is that advisers sell the plan. They represent a sales force of almost 300,000 with personal relationships with plan sponsors. Providers do not have to recruit, manage or pay these advisers directly. Everything else is ancillary."  MORE >>

Fred Barstein, via RPA Convergence

Benefits in General

Cybersecurity Best Practices for Employer-Sponsored Benefits

"Begin with a solid working knowledge of the current cybersecurity threat landscape.... Develop and document a formal cybersecurity program.... How does your service provider selection process investigate an entity's ability to adequately protect data it will create, receive, transmit, or maintain on behalf of your employee benefits program? ... What level of oversight do your service provider agreements allow so that you can ensure the providers' security policy and procedure compliance? ... Train (and retrain) your employees at least annually."  MORE >>


Employee Benefits Jobs

View job as ERISA Attorney - Qualified Plan Associate
for Trucker Huss, APC ERISA Attorney - Qualified Plan Associate

Trucker Huss, APC

San Francisco CA / Los Angeles CA

View job as ERISA Attorney - Qualified Plan Associate
for Trucker Huss, APC

View job as Plan Document Contracts Administrator - Employee Health Benefits
for Health Plans Inc Plan Document Contracts Administrator - Employee Health Benefits

Health Plans Inc

Westborough MA / FL / ME / NH / NJ / SC / WI

View job as Benefits Program Strategic Analyst 4
for University of California Office of the President Benefits Program Strategic Analyst 4

University of California Office of the President

Oakland CA

View job as General Attorney - EXC
for Pension Benefit Guaranty Corporation [PBGC] General Attorney - EXC

Pension Benefit Guaranty Corporation [PBGC]

Remote / Washington DC

Selected New Discussions

40 Former Employee-Participants Didn't Get a Blackout Notice

"We found out recently that when we changed plans we did not provide the blackout notice to non-employee participants (former employees). By the time we corrected the error the new plan was up and running. Do you have experience with this or could you recommend any steps to take? I've seen the $131/day penalty which gets a little pricey when there were about 40 people who didn't get the notice!"

BenefitsLink Message Boards

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

IRA Fundamentals

September 28, 2021 WEBCAST


Last Issue's Most Popular Items

DOL Issues FAQs on the Interim Final Rule on Lifetime Income Illustrations Under the SECURE Act

Thomson Reuters Practical Law

Form 5500 and New Audit Standard SAS 136

Belfint Lyons Shuman

Escalating Litigation of Actuarial Equivalence in Taft-Hartley Plans: No End in Sight

Cohen Milstein

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

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