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Retirement Plans Newsletter

August 31, 2023

2 New Job Opportunities 2 New Job Opportunities

 

[Guidance Overview]

Matching Contributions for Qualified Student Loan Payments Under SECURE Act 2.0

"Here's an overview of student loan matching plan design, why employers would consider offering, what is known about implementation and what regulatory guidance is expected."  MORE >>

International Foundation of Employee Benefit Plans [IFEBP]

[Guidance Overview]

Draft Rule Issued for Maine Retirement Savings Program

"This rule addresses [1] the procedures and requirements for covered employers to register with the program, [2] the establishment of and investment in such accounts for covered employees and individual program participants, [3] the procedures covered employers must follow to comply with the underlying legislation, and [4] the information required for program account holders."  MORE >>

American Retirement Association [ARA]

Measuring UVBs for Variable-Rate Premiums: The Alternative vs. Standard Method Election Due October 16, 2023

"The combination of [1] an unprecedented gap between standard and alternative interest rates due to the sharp increase in rates since 2021 and [2] the steep increase in the premium rate, from 0.9% of UVBs in 2013 to 5.2% in 2023, means that the dollar amounts at stake with respect to the VRP calculation dwarf all past years. For a typical $100 million plan, the decision could easily be worth $1 million or more."  MORE >>

October Three Consulting

Pension Risk Transfers Headed for Record Year in U.S., U.K.

"In the U.S., the PRT market 'appears poised to set another record' with an estimated $22 billion in total transaction volume through June ... That is 31% higher and $4 billion more than a previous record set in the first half of 2022, and well above the $8.7 billion in transactions in the first half of 2021[.]"  MORE >>

Pensions & Investments

Fiduciary Duty a Factor in Pension Risk Transfers

"In its settlor capacity, the plan sponsor may be focused on getting a good price in a transfer transaction. But a plan sponsor engaging in a pension risk transfer, it is still an ERISA fiduciary, and is required to act prudently and in the best interests of the plan's participants and beneficiaries[.]"  MORE >>

American Retirement Association [ARA]

PBGC Approves $75 Million in SFA for Ironworkers Local 16 Plan

"[PBGC] has approved the application submitted ... by the Ironworkers Local Union No. 16 Pension Plan. The plan, based in Baltimore, Maryland, covers 996 participants in the construction industry. On October 1, 2018, the [Plan] implemented a [MPRA] benefit suspension ... [and] reduced benefits of about 680 plan participants.... The plan will receive $75.8 million in SFA[.]"  MORE >>

Pension Benefit Guaranty Corporation [PBGC]

Winding Down a ROBS Corporation and Its Plan

"Several steps are required to get from Point A to completely closed down.... [1] Locate all plan records.... [2] Locate all corporate records.... [3] Get in touch with the plan's various service providers.... [4] decide how (and where) to take your distribution."  MORE >>

KLB Benefits Law Group

[Opinion]

A Simple Solution to the Looming Retirement Security Crisis

"The outlook is grim as a comfortable retirement seems further and further out of reach for most Americans. And at the same time, employers are struggling with employee retention in a particularly tight labor market. While the solution to these massive challenges will ultimately require a multifaceted approach, the long-term answer may be simple: Make pension plans mainstream again."  MORE >>

Pensions & Investments

Benefits in General

[Official Guidance]

Text of IRS Disaster Relief Announcement FL-2023-06, for Those Impacted by Idalia in Florida

"Taxpayers affected by the storm that began on Aug. 27. 2023, now have until Feb. 15, 2024, to file various individual and business tax returns and make tax payments.... [I]ndividuals and households affected by Idalia that reside or have a business in Alachua, Baker, Bay, Bradford, Calhoun, Charlotte, Citrus, Clay, Collier, Columbia, DeSoto, Dixie, Duval, Flagler, Franklin, Gadsden, Gilchrist, Gulf, Hamilton, Hardee, Hernando, Hillsborough, Jefferson, Lafayette, Lake, Lee, Leon, Levy, Liberty, Madison, Manatee, Marion, Nassau, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns, Sumter, Suwannee, Taylor, Union, Volusia and Wakulla counties in Florida qualify for tax relief."  MORE >>

Internal Revenue Service [IRS]

Executive Compensation and Nonqualified Plans

Split-Dollar Life Insurance Plans Can Be a Useful Way to Attract and Retain Key Hires

"In times of a tight and competitive hiring market, employers may consider split-dollar life insurance as one of many diverse strategies to attract and retain desired employees. These plans are best established for key employees as a fringe benefit ... This split-dollar plan may not only accomplish an employee's wealth-transfer goals, but also may establish a business's replacement fund for a valuable employee. These split-dollar arrangements can vary depending on the interests of the employer and employee[.]"  MORE >>

Faegre Drinker

Employee Benefits Jobs

View job as Division Leader
for Nova 401(k) Associates

Division Leader

Nova 401(k) Associates

Remote

View job as Division Leader for Nova 401(k) Associates

View job as Retirement Account Administrator, Senior
for Alerus

Retirement Account Administrator, Senior

Alerus

Remote

View job as Retirement Account Administrator, Senior for Alerus

Selected New Discussions

NRA Age 50

"Takeover. Many issues. DB with document stating NRA age 50. This would violate Section 401(a)(14) and Section 1.401(a)-1(b)(2). We can correct late restatements under SCP, but can we also change the NRA to 62 under SCP as well? This appears to me to be a document issue, which cannot be corrected under SCP. Thoughts? Also, assuming we have to do this from inception, would we also have to redo the actuarial valuations using the correct NRA (likely resulting in some past non-deductible contributions) or just look at open years?"

BenefitsLink Message Boards

Brokerage Accounts and Plan Sponsor Responsibility

"When a Plan chooses to allow brokerage accounts, is it acceptable for the Plan Sponsor to expect the participants to get them a copy of the statement(s) at the end of the year? Should the Plan Sponsor be receiving a copy of each individual statement monthly or at least quarterly? What are the consequences if they are not keeping copies themselves?"

BenefitsLink Message Boards

PBGC Termination Issues for Non-Compliant Floor-Offset Plan

"If a DB plan is non-compliant (either a discriminatory benefit formula or failed 401(a)(4)) may it still terminate under PBGC if the assets are sufficient? We understand that a plan may potentially be disqualified, but does the PBGC care or is it only concerned with sufficiency? Case in point floor/offset plan, but the sponsor did not correctly fund the DC plan to meet aggregated testing. They want to terminate the DB plan. We are reluctant until they get the combo compliant. They dispute the need for additional contributions to the DC plan in order to terminate the otherwise sufficient DB plan. If we warn the sponsor of consequences, will the PBGC allow the termination without regard to testing?"

BenefitsLink Message Boards

Press Releases

Legal Opinion Letter Released by Business Climate Finance Affirms Companies' Ability to Consider ESG Factors in Employer-Sponsored Retirement Plan Selection Process

Business Climate Finance Initiative [BCF]

Strongpoint Partners Announces Partnership with Pension Financial Services (Pfs)

Strongpoint Partners

DOL Obtains Federal Court Judgment to Recover $153k in Retirement Funds for Former Employees of Defunct Bay Area Company

Employee Benefits Security Administration [EBSA], U.S. Department of Labor

New Title! Plan Distribution eSource: The Who, When, and How Much of Plan Disbursements

ERISApedia

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

The Keys to a Successful Retirement Plan for Law Firms

September 26, 2023 WEBINAR

CAPTRUST Financial Advisors

Last Issue's Most Popular Items

IRA Beneficiary Payout Rules: The Madness Continues

Slott Report

Social Security Replacement Plan Participants May Be Exempt from SECURE 2.0 Roth Catch-Up Contribution Requirement

Ice Miller LLP

IRS Delays SECURE 2.0's Roth Catch-Up Mandate Until 2026

Mercer

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

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