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Retirement Plans Newsletter

April 17, 2024

7 New Job Opportunities 7 New Job Opportunities


[Guidance Overview]

IRS Waives 2024 RMDs for IRA Beneficiaries Subject to the 10-Year Rule

"[Notice 2024-35] adds another year of relief by waiving 2024 annual RMDs for beneficiaries of IRA owners who died in 2020, 2021 or 2022 after the RBD. It also excuses 2024 RMDs within the 10-year period for beneficiaries of owners who died in 2023 after the RBD."  MORE >>

Slott Report

[Guidance Overview]

Retirement Lost and Found: DOL Proposes Voluntary Reporting

"DOL has issued a proposed procedure to collect data directly from plan administrators on a voluntary basis via a new filing made along with, but not as part of, the Form 5500.... IRS's determination that the agency cannot share [Form 9855-SSA] data with DOL complicates the project and may lead to further regulatory action.... Administrators will need to weigh the benefits of participating against any costs and risks.... Comments are due on June 17, 2024."  MORE >>

Groom Law Group

[Guidance Overview]

DOL Asks Plan Administrators to Provide Participant Data for Lost and Found

"The [DOL] is asking plans to provide the following for vested separated participants: names and Social Security numbers, contact information, mailing address, and whether they have received an involuntary distribution already. The DOL also asked plans to indicate if a participant has been unresponsive to contact and to provide information on their designated beneficiaries, as well as the nature and amount of the benefit to which they are entitled. Administrators would provide this information to the DOL as an attachment to their Form 5500 filings."  MORE >>


[Guidance Overview]

Major Changes Coming to the QPAM Exemption

"The final amendment comes two years after the proposed amendment brought pushback from investment managers. Eligibility requirements have tightened, and QPAMs will have to be more vigilant to maintain the exemption.... While there are no immediate steps plan sponsors need to take in reaction to the final amendment, plan sponsors engaging QPAMs should be aware that QPAMs will have increased compliance requirements, which may lead to additional costs."  MORE >>

Alston & Bird

[Guidance Overview]

DOL Finalizes QPAM Exemption Amendment

"While not specifically stated in the final amendment notice, managers that currently rely on the exemption may wish to provide the Section I(k) notice by the June 17, 2024 effective date of the changes to avoid any question of the exemption's continued availability. ... Firms will want to carefully consider the potential impact of entering into an NPA or DPA, or court-approved settlements raising the types of issues described in the final amendment, on the availability of the exemption on a case-by-case basis."  MORE >>

Morgan Lewis

[Guidance Overview]

DOL Unveils Final Amendment to QPAM Exemption

"The Final Amendment significantly impacts investment managers managing Plan Asset Entities (including eliminating the ability of certain managers to qualify as a QPAM), employers/plan sponsors of Plans, IRA owners and other fiduciaries responsible for engaging or monitoring investment managers, as well as counterparties to Plan Asset Entities seeking to rely on the QPAM Exemption."  MORE >>


Alcoa Sued Over Transfer of Pension Assets to Athene

"Four Alcoa retirees have sued the company and its pension plan fiduciaries saying the defendants violated ERISA by transferring $2.8 billion in defined benefit assets to an insurance company they contend represents a riskier investment than a traditional pension fund....The Alcoa lawsuit is the third recent legal action criticizing defined benefit plan sponsors' transfer of retirement assets to Athene." [Camire v. Alcoa U.S.A. Corp., No. 24-1062 (D.D.C. complaint filed Apr. 12, 2024)]  MORE >>

Pensions & Investments

Strict Construction: Seventh Circuit Affirms Written Pension Obligations

"This decision affirms the statutory rule that pension obligations must be in writing and rejects an attempt to expand an employer's obligation through conduct. Employers can sigh in relief that their agreements won't be altered by conduct but should ensure all terms are clearly spelled out." [Bulk Transp. Corp. v. Teamsters Union No. 142 Pension Fund, No. 23-1563 (7th Cir. Mar. 22, 2024)]  MORE >>

Faegre Drinker

State-Facilitated Retirement Savings Programs and Defined Contribution Plans: A Comparative Review of Investment Design and Cost Structures

"While their statutory frameworks, eligibility requirements, and features differ, state auto-IRA programs and DC plans reflect the industry's move to innovate for the benefit of participants through adoption of auto-features, use of target retirement date funds, cost-effectiveness, and fee transparency."  MORE >>

Georgetown University Center for Retirement Initiatives

House Subcommittee Hearing on the Windfall Elimination Provision and Government Pension Offset

Video of Apr. 16 hearing, with testimony by: [1] Jason Fichtner, Ph.D., Bipartisan Policy Center; [2] Rachel Greszler, Economic Policy Innovation Center; [3] Nancy Altman, Social Security Works; [4] Charles Blahous, Ph.D., Mercatus Center at George Mason University.   MORE >>

Social Security Subcommittee of the Committee on Ways and Means, U.S. House of Representatives


Remembering Daniel Kahneman: Psychological Behavioral Insights to Retire Smarter

"The recent death of Nobel laureate Daniel Kahneman ... marks a great loss for psychology and economics. His groundbreaking work on cognitive biases and decision-making offered invaluable wisdom for retirees navigating the investment landscape while preserving wealth and generating income.... Here are four key lessons to consider from Kahneman's research, along with actionable tips designed to help retirees invest more confidently and resiliently.... [1] Beware of overconfidence ... [2] Combat loss aversion ... [3] Recognize the availability bias ... [4] Embrace slow thinking."  MORE >>


Employee Benefits Jobs

View job as RP-Client Service Associate for Greenline Wealth Management

RP-Client Service Associate

Greenline Wealth Management

FL / Hybrid

View job as RP-Client Service Associate for Greenline Wealth Management

View job as Retirement Plan Consultant for Great Lakes Pension Associates, Inc.

Retirement Plan Consultant

Great Lakes Pension Associates, Inc.


View job as Retirement Plan Consultant for Great Lakes Pension Associates, Inc.

View job as Combo Plan Administrator for Pollard & Associates

Combo Plan Administrator

Pollard & Associates


View job as Combo Plan Administrator for Pollard & Associates

View job as Senior Plan Administrator for Retirement Planners and Administrators (RPA)

Senior Plan Administrator

Retirement Planners and Administrators (RPA)


View job as Senior Plan Administrator for Retirement Planners and Administrators (RPA)

View job as Retirement Plan Consultant for TPA Experts

Retirement Plan Consultant

TPA Experts


View job as Retirement Plan Consultant for TPA Experts

View job as Client Service Specialist for U.S. Retirement & Benefits Partners

Client Service Specialist

U.S. Retirement & Benefits Partners

Wayne PA / Hybrid

View job as Client Service Specialist for U.S. Retirement & Benefits Partners

View job as Group Benefits Sales Representative for The Standard

Group Benefits Sales Representative

The Standard

Pittsburgh PA / Hybrid

View job as Group Benefits Sales Representative for The Standard

Selected New Discussions

Form 5500 for Terminating Solo 401(k)

"We have a plan where only 1 person (100% owner) was a participant. The plan's assets never exceeded $250k, so no Form 5500 has been filed in the past. The plan terminated on 12/31/2023 and the owner took a full distribution in April of 2024. We'll file one Final Form 5500-EZ -- for 2024. I have a couple questions: [1] Since the owner technically has a termination date of 12/31/2023 (plan's termination date), is 8955-SSA form required for 2023? Is the 8955-SSA form required for 2024? [2] The SAR is not required for any year (including 2024) because this is a Solo 401(k), correct?"

BenefitsLink Message Boards

Press Releases

Ascensus to Acquire Vanguard Individual 401(k), Multi-SEP, and SIMPLE IRA Plans


Stephanie Lao and Stephanie Platenkamp Join the Trucker Huss Team

Trucker Huss

Last Issue's Most Popular Items

Text of IRS Notice 2024-35: Certain Required Minimum Distributions for 2024 (PDF)

Internal Revenue Service [IRS]

DOL Proposes Information Collection to Build Online Search Tool to Help Workers Find 'Lost' Retirement Savings

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

IRS Fine-Tunes Auto-Enrollment Exemption, Explains New Correction


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

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