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Retirement Plans Newsletter

January 26, 2024

4 New Job Opportunities 4 New Job Opportunities

 

[Guidance Overview]

IRS Employee Plans News: Long-Term Part-Time Employees in 401(k) Plans (PDF)

Jan. 26, 2024. "The SECURE Act made changes to when an employee is eligible to make deferrals to a 401(k) plan.... This new requirement generally applies to all 401(k) plans and all employees, other than certain employees covered by a collective bargaining agreement. For a 401(k) plan that uses the calendar year as its plan year, this change could require enrollment of long-term part-time employees as of January 1, 2024."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

Final IRS Regs Update Present Value Calculations for Defined Benefit Plans and Expand Anti-Cutback Relief

"The final regulations: [1] Clarify the application of pre-retirement mortality discount factors to calculate minimum present values, [2] Permit an alternative approach for how Social Security Level Income Option forms of benefit can satisfy the minimum present value rules, and [3] Expand the anti-cutback relief[.]"  MORE >>

Groom Law Group

[Guidance Overview]

IRS and DOL Issue PLESA Guidance

"A recent study shows that roughly 25% of plan sponsors are interested in adding a PLESA to their plan. However, thus far employer uptake has remained near zero, in part due to lingering regulatory questions and hesitancy on the part of service providers. To address this uncertainty, the IRS issued Notice 2024-22 and the [DOL] issued FAQs. Highlights of this new PLESA guidance are summarized below:"  MORE >>

Miller Canfield

[Guidance Overview]

IRS Provides Guidance on Roth Employer Contributions

"[Notice 2024-02] clarified that elections must be made no later than the date the contribution is allocated to the participant's account and must be irrevocable. However, participants must only be given the effective opportunity to make or change Roth employer contribution elections at least once a plan year."  MORE >>

Bricker Graydon

[Guidance Overview]

IRS Announces Rollover Relief for Maryland Prepaid College Trust Accounts

"[Notice 2024-23] allows an exception to the one rollover per 12-month period tax limitation on rollovers if [certain] criteria are met."  MORE >>

Ascensus

Could the DOL's Fiduciary Rule Hinder Advisor-Assisted Rollovers?

"[M]ore than two-thirds (70%) of retirement specialist advisors say participants in their defined contribution plans frequently ask them questions about [IRA] rollover decisions.... [As] wealth management firms continue to pursue opportunities in the ERISA-covered retirement plan space, they will need to 'navigate and overcome' existing and pending regulations imposing more stringent fiduciary requirements when recommending IRA rollovers[.]"  MORE >>

American Retirement Association [ARA]

Estimate of the Financial Effects on Social Security of Enacting the 'You Earned It, You Keep It Act' (PDF)

"The proposal [HR 7084] includes two provisions with direct effects on the OASDI program.... [1] Repeal taxation of Social Security benefits effective in 2025, but hold the OASDI and Medicare Hospital Insurance (HI) Trust Funds harmless.... [1] Apply the combined OASDI payroll tax rate on covered earnings above $250,000 paid in 2025 and later.... Assuming enactment of the proposal, the combined OASI and DI Trust Funds are expected to be able to pay scheduled benefits in full and on time for an additional 20 years, under the intermediate assumptions of the 2023 Trustees Report."  MORE >>

U.S. Social Security Administration [SSA]

PBGC Approves $16 Million in SFA for Laborers' International Local 1822 Fund

"[PBGC] has approved the application submitted ... by the Laborers' International Union of North America Local Union No. 1822 Pension Fund (Laborers' International Local 1822 Fund). The plan, based in Syracuse, New York, covers 525 participants in the construction industry. The Laborers' International Local 1822 Fund, which is in critical status, will receive approximately $16 million in special financial assistance[.]"  MORE >>

Pension Benefit Guaranty Corporation [PBGC]

[Opinion]

Impractical SECURE 2.0 'Sidecar' Emergency Savings Accounts Should Be Avoided

"The [DOL] has issued guidance clarifying several components of this emergency savings provision. The guidance highlights the complexity of creating and maintaining these accounts and should be enough to make most plan sponsors look for a better option."  MORE >>

Multnomah Group

[Opinion]

ERIC Comment Letter to IRS Requesting Transitional Relief for LTPT Rules (PDF)

"While many of the rules in the Proposed Regulation are straightforward and well-explained, there are certain complexities that may require a longer implementation period.... [ERIC asks] for a good faith compliance standard with respect to plan years that began January 1, 2024."  MORE >>

The ERISA Industry Committee [ERIC]

Benefits in General

[Guidance Overview]

Possible Impact of New DOL Employee Classification Rule on Employee Benefits

"The Final Rule goes into effect on March 11, 2024 and applies only to FLSA wage and hour requirements.... The definition of who is an 'employee' under ERISA and the Code does not track the definition of 'employee' for purposes of the FLSA. However, confusion over the new rule and its scope may cause workers and their advisors to make claims for benefits. Thus, it is important for employers to be aware of the Final Rule, and anticipate how worker classification under the FLSA could potentially impact employee benefits."  MORE >>

Groom Law Group

Executive Compensation and Nonqualified Plans

[Guidance Overview]

Corporations with ISO or ESPP Reporting Obligations Should Take Notice of Revised Electronic Filing Requirements

"The change in electronic filing requirements may cause some corporations to scramble to comply. In addition to ensuring that the corporation has accurate listings of employees who completed the ISO and/or ESPP exercises in the prior calendar year as well as their tax ID numbers, full names and addresses, the corporation will need to ensure that it has a transmitter control code (TCC) and an account with the IRS to file online through the IRS’ Filing Information Returns Electronically (FIRE) system."  MORE >>

Mintz

Set Your Executive Incentive Compensation Program for Success

"An organization's refined annual operating plan and longer-term strategic plan in a new year spark conversations in the C-suite and boardroom about executive incentives.... Before acting on these topics of conversation, organizations must revisit their executive incentive program's performance measurement framework: performance categories, performance metrics, and relative weightings across both STI and LTI."  MORE >>

Willis Towers Watson

Employee Benefits Jobs

View job as Plan Administrator for The Benefits Consulting Group, Inc.

Plan Administrator

The Benefits Consulting Group, Inc.

Remote

View job as Plan Administrator for The Benefits Consulting Group, Inc.

View job as Sr. Benefits Attorney for Air Line Pilots Association

Sr. Benefits Attorney

Air Line Pilots Association

Mc Lean VA

View job as Sr. Benefits Attorney for Air Line Pilots Association

View job as Director of Operations/ Client Success Officer for NPPG

Director of Operations/ Client Success Officer

NPPG

Shrewsbury NJ

View job as Director of Operations/ Client Success Officer for NPPG

View job as Senior Retirement Analyst for Dunbar, Bender & Zapf, Inc.

Senior Retirement Analyst

Dunbar, Bender & Zapf, Inc.

Remote / Pittsburgh PA

View job as Senior Retirement Analyst for Dunbar, Bender & Zapf, Inc.

Selected New Discussions

Auto Enrollment for Plans That Join a PEP or MEP Which Was Established After 12/29/2022

"In a recent webcast on the 'IRS grab bag' regarding automatic enrollment, it was noted that for plans joining a PEP or MEP -- 'remember -- the determination is based on the participating employer and not the MEP/PEP original effective date'. In this case, I believe that if a plan with an original effective date of 1/1/2020 joins a PEP on 1/1/2023, they are 'grandfathered' and would not be subject to automatic enrollment. The webcast did not address when the PEP was established.

"However, in a recordkeeper's summary, it is noted 'A pre-enactment single employer plan that merges into a MEP established on or after December 29, 2022 (a post-enactment MEP) will lose its pre-enactment / grandfathered status.'

"These seem to be contradictions. When I look through Notice 2024-2, I do not find any references to PEPs or MEPs. Is anyone aware of a site that addresses the PEP / MEP establishment date trumps a plan's original effective date?"

BenefitsLink Message Boards

Press Releases

Fidelity’s® Guaranteed Income Direct Solution Available Nationally, Enabling Employees to Convert Retirement Savings Into Lifetime Income

Fidelity Investments

Betterment at Work Launches Industry-First Small Business Student Loan 401(k) Matching Solution

Betterment

Top Benefits Lawyer, Gretchen Harders, Joins Cohen & Buckmann

Cohen & Buckmann P.C.

Last Issue's Most Popular Items

The Psychology Behind Starting Social Security at 62

Center for Retirement Research at Boston College

Employers Need to Get 'Control' of IRS Controlled Group Rules (PDF)

Davis & Gilbert LLP, via Employee Relations Law Journal

DOL's Final Independent Contractor Rule Contains Important Potential Impacts for Employee Benefit Plans

Winston & Strawn LLP

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

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