"For most plans, the new amendment deadline is December 31, 2025.... [T]his is a fixed date which does not depend on the plan year or the employer's tax year. It applies to union and nonunion plans. There are several important exceptions."  MORE >>

"The IRS expects that certain SECURE Act guidance will be included on the 2023 Required Amendments List for individually-designed plans, which would keep the amendment timing in line with [the new] deadlines.... [Notice 2022-33] does not address an extension for coronavirus-related distributions and loans ... [A]mendments for those provisions remain due by the end of first plan year beginning on or after January 1, 2022."  MORE >>

"[A]ffected plans will still need to ensure operational compliance with the law changes prior to the amendment deadline. The longer plan sponsors wait to adopt these amendments, the greater the chance for compliance errors. And extending the deadline also doesn't provide additional help for plans terminating before 2025 which may not have the benefit of the additional IRS guidance."  MORE >>

"Depending on the circumstances, some failures may require obtaining formal approval from the IRS through its Voluntary Correction Program, while others may be eligible for self‑correction.... If failing to timely restate a pre-approved plan results in any interim or discretionary amendments being defective, the plan may be corrected through the IRS Employee Plans Compliance Resolution System (EPCRS). "  MORE >>

"An internal review of plan operations can be pretty daunting. The IRS's announcement is incredibly broad and completely devoid of references to common errors or specific areas of focus. ... [D]iligent plan sponsors will begin with a provision-by-provision review of the plan document or adoption agreement, much like the plan design review that occurs within a recordkeeper transition."  MORE >>

"Elderly American adults did not adjust their retirement expectations significantly, including planned retirement age and Social Security benefit claiming age, despite many respondents indicating that the COVID-19 pandemic had impacted their work and financial situations in the 2020 HRS."  MORE >>

"The funded status of the 100 largest corporate defined benefit pension plans decreased by $19 billion during July ... Pension liabilities soared due to a decrease in the benchmark corporate bond interest rates used to value those liabilities. As of July 31, the funded ratio dropped to 104.5%, down from 105.9% at the end of June. Despite the decline, July is the sixth consecutive month in which 'full funding' has been achieved."  MORE >>

"The stock buyback plan, proposed as a compromise by Sen. Kyrsten Sinema (D-AZ), is facing blowback from the U.S. Chamber of Commerce. The group said the tax proposal, which envisions a 1% excise tax on corporate buybacks, would filter down and have a deleterious effect on average investors."  MORE >>

"[Attorney Carol McClarnon] points out that, in the nearly four decades since the QPAM exemption framework was first established, the financial services world has become far more interconnected. 'In today's industry, you just have a lot more complexity, with larger conglomerates and highly sophisticated international entities that do business with U.S. retirement plans,' McClarnon says. 'The proposed framework, if it is not adjusted after the comment period, will make it very difficult for these types of entities to reliably and efficiently use the QPAM exemption.' "  MORE >>