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[Guidance Overview]
New IRS Mortality Tables: What Should Plan Sponsors Do Now?
"[E]xpected lifetimes under the IRS mortality tables for 2024 are generally shorter than those under the IRS mortality tables for 2023. Depending on the plan's demographics, this will roughly translate to a decrease in the funding target liability of about 1.0% to 2.5% and a
decrease in the target normal cost of about 0.5% to 2.5%. However, plans with younger demographics could see increases in the liability and normal cost when changing from a static table to the generational mortality table." MORE >>
Bolton
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[Guidance Overview]
IRS Issues Final Regs on Minimum Present Values
"[T]he final rules include new and welcome flexibility for DB plan sponsors to change Section 417(e) rates used for other
purposes. The changes are generally optional and unlikely to have a significant effect on participant benefits. Accordingly, many plan sponsors may simply decide to leave plan administration unchanged. However, certain contributory plans and plans that haven't been treating Social Security level-income options (SSLIOs) as subject to Section 417(e) may need to change procedures." MORE >>
Mercer
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Senate HELP Committee to Hold Hearing on Retirement Crisis Facing Working Class Americans
"The Senate Health, Education, Labor, and Pensions (HELP) Committee ... will hold a hearing on Wednesday, February 28 at 10:00 a.m. ET titled, 'Taking a Serious Look at the Retirement Crisis in America: What can we do to expand defined benefit pension plans for
workers?' " [The hearing will be livestreamed on the Committee's website.] MORE >>
Committee on Health, Education, Labor and Pensions [HELP], U.S. Senate
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A Crystal-Ball View of Retirement Plans in 2024: A Plan Sponsor Priority Checklist
"Expect more emphasis on participant services ... [L]ifetime income within defined-contribution plans on the rise ... 403(b) plans will continue influencing 401(k) plans ... [C]hanges in plan design." MORE >>
BenefitsPro; free registration required
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Multiemployer Pension Funding at 89% in Aggregate at Year-End 2023
"The rise in aggregate funding is largely the result of investment gains ... plus continued special financial assistance (SFA) under the American Rescue Plan Act. As of year-end 2023, 69 plans in total have received nearly $54 billion in SFA funding, including
$45 billion paid during 2023. Without the SFA program, the aggregate funded percentage ... would be approximately 83%." MORE >>
Milliman
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Ok, Boomer: Retirement Prospects for Younger Americans Actually Look Bright
"While it's true younger generations manage substantial student loan debt while working to establish careers and families, they have also made more progress in retirement saving than prior generations had at the same stage of life. Thanks to the increased prevalence of
401(k)s and other defined contribution retirement plans offering automatic enrollment and an attractive lineup of diversified investments, the long-term financial outlook for younger generations is promising." MORE >>
Investment Company Institute [ICI]
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[Opinion]
ARA Comment Letter to IRS on Notice 2024-2: Miscellaneous Changes Under the SECURE 2.0 Act of 2022 (PDF)
"[Regarding the] Section 414A requirement, [Notice 2024-02] left significant questions
unanswered -- particularly information necessary for an employer to accurately determine whether its plan is subject to the EACA mandate and guidance on how to comply with the mandate when an employer maintains a plan before the arrangement becomes subject to the mandate.... [T]he Notice provides that a de minimis financial incentive may only be offered to an employee who does not have a deferral election in effect. This
interpretation is far too restrictive, as the statutory language itself is not so narrow." MORE >>
American Retirement Association [ARA]
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Benefits in General |
How Two Fishing Boat Cases Pending at the Supreme Court Could Rock the Benefits Plan Boat
"If Chevron is overturned or significantly weakened, new DOL and US Department of the Treasury regulations featuring aggressive statutory interpretations (like the fiduciary rule) are likely to become rarer and more vulnerable to challenge.... [B]ecause employee benefits
cases challenging agency actions have only rarely reached the Supreme Court, employee benefit cases may be especially affected by how lower courts apply the result of Loper Bright and Relentless, which in turn may vary by federal circuit and district court." [Loper Bright
Enterprises, Inc. v. Raimondo, Sec. of Comm., No. 22-451 (S.Ct. transcript of oral argument Jan. 17, 2024); Relentless,
Inc. v. Dept. of Commerce, No. 22-1219 (S. Ct. transcript of oral argument Jan. 17, 2024)] MORE >>
McDermott Will & Emery
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EBSA Highlights Its 2023 Enforcement Results
"The monetary results reflect the breadth of the DOL's civil enforcement actions, with just over half of recoveries relating to terminated vested defined benefit plan participants and the rest (over $415 million) from other plan investigations. The specific mention of
results relating to mental health reflects that this topic is currently a high priority for the DOL." MORE >>
Thomson Reuters / EBIA
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Selected New Discussions |
457(b) Distribution Timing
"I'm looking at a 457(b) document and adoption agreement specifying that payments must commence no later than April 1 following date of termination. Obviously done back when that was the required beginning date. I just want to confirm -- for a 457(b) plan, I assume
it is still ok to retain this provision, (if they want to) even if RMD date for active participants is the new 72 or 73, depending upon DOB?"
BenefitsLink Message Boards
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Fiduciary Concerns: Free Payroll Services Offered to New TPA Clients
"Start-up payroll/TPA companies appear to be offering free payroll services to companies that move their 401(k) plans to their TPA arms. Is this a fiduciary breach by the plan sponsor? Maybe, or with certainty? If the primary (any?) decision criteria to move the plan is the
unrelated benefit to the plan sponsor and not solely in the best interest of plan participants, then that is clearly a breach, is it not? But does the mere appearance of a conflict of interest (and breach) mean that there is one? Would a participant even know? Would this even be discoverable upon a routine audit? Or are these types of arrangements littering the skies flying under the radar without scrutiny? I remember reading either
something similar a few years back, where some economic benefit is offered to the employer if plan administration is moved, and thought the opinion or consensus then was it didn't pass the smell test. Thoughts and opinions please."
BenefitsLink Message Boards
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Press Releases |
PenChecks, Inc. Hires New VP of Advisor Solutions
PenChecks Trust
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DOL Files Suit After Investigation Finds Fringe Benefit Plan Fiduciaries Misused Millions of Dollars to Pay Employer Expenses
Employee Benefits Security Administration [EBSA], U.S. Department of Labor
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Remodel Health Acquires PeopleKeep, Creating a Powerhouse in Health Benefits Solutions
Remodel Health
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Last Issue's Most Popular Items |
The Billion Dollar Typo: What Plans Need to Know Now About Scrivener's Errors Under ERISA
Boutwell Fay LLP
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IRS Provides Guidance on Self-Correcting Auto-Enrollment and Auto-Escalation Failures
Trucker Huss
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IRS Updates Final Rules on Minimum Present Value Calculations for Defined Benefit Plans
Buck
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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.
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