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Retirement Plans Newsletter

August 12, 2024

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[Official Guidance]

Text of DOL Corrections to PTE 84-14: Transactions Determined by Independent Qualified Professional Asset Managers (The QPAM Exemption)

29 pages. "This document gives notice of a technical correction to the [DOL's] final amendment to class [PTE] 84-14 (the QPAM Exemption), which was published in the Federal Register on April 3, 2024.... The corrections in this document fix a typographical error and make a minor clarification to a provision to reflect the Department's original intent for the effect of the amendment. These technical corrections are consistent with the amended exemption's intended scope and the analysis and data relied upon in the Department's final regulatory impact analysis (RIA)."  MORE >>

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

[Sponsor]

Cycle 4 DC Enrollment at ASC is Open - IRS Deadlines Approaching - Enroll Today!

Enroll for Cycle 4 Defined Contribution Plans with ASC. Enrollment is quick and easy with ASC’s online enrollment system. IRS deadlines are approaching; Enroll Today!

Sponsored by ASC

[Guidance Overview]

Is Your Individually Designed 403(b) Plan Eligible for a Determination Letter?

"In June, the IRS determination letter program became available to a second group of 403(b) plans -- those with plan sponsors that have EINs that end in 4, 5, or 6. The IRS rollout of this qualified plan determination letter program for 403(b) plans began in June 2023 [for] plans sponsored by employers with EINs that end in 1, 2, or 3 and will continue in June 2025 for plans sponsored by employers with EINs that end in 7, 8, 9, or 0. Currently there is no deadline for applying for an initial determination once your plan becomes eligible."  MORE >>

Proskauer

A Primer on Pooled Employer Plans

"In addition to its collective buying power, which typically reduces overall plan costs for each participating employer, the PEP model provides several advantages over stand-alone plans.... The PEP model eases plans' administrative burden ... Employee communications is another specialized area that is managed by the pooled plan provider, or PPP, along with the record keeper.  ... A more robust investment menu is another key reason that employers are turning to PEPs[.]"  MORE >>

Pensions & Investments

Auto-Escalation Opt-Out Provides Greater Participation Than Opt-In

"Retirement plans offering auto escalation can use the opt-out strategy, or they can tell participants they must opt in.... For the opt-in group, participant usage was only 11% last year -- an annual rate that has been consistent since 2014, never rising higher than 13% in any year. By contrast, 61% participated in auto escalation via the opt-out approach last year. Since 2014, the annual peak usage was 67% in 2017 and again in 2018."  MORE >>

Pensions & Investments

Why Do Employers Establish Retirement Savings Plans? Evidence from State 'Auto-IRA' Policies

"Several states have recently attempted to boost retirement saving by adopting 'auto-IRA' policies that require employers not currently offering an employer-sponsored retirement plan (ESRP) to either [1] establish an ESRP or [2] enroll employees in state-facilitated Individual Retirement Accounts (IRAs).... Using U.S. tax microdata, [the authors] estimate that at least 30,000 firms have been induced to offer an ESRP by these policies ... This effect is large considering that, for employers, establishing and maintaining an ESRP is more costly than utilizing the state-facilitated IRAs."  MORE >>

National Bureau of Economic Research [NBER]; purchase required for full document

Employing the Proper Definition of Compensation

"[This] article is intended to briefly highlight some of the issues that can occur when the incorrect definition of compensation is employed as well as to provide an explanation of some of the differences between the most commonly employed definitions of compensation."  MORE >>

Legacy Retirement Solutions

Why Do Roth Conversions in Peak Earnings Years?

"[1] Pessimism about future tax rates.... [2] Significant savings in pre-tax accounts.... [3] Your heir's tax rate is higher than yours."  MORE >>

Kiplinger

Account Balances and Contributions Growing for Public-Sector Defined Contribution Plan Participants

"Overall, the average plan balance rose from $43,839 in 2019 to $61,886 at year-end 2021 while the median balance rose from $10,365 to $16,864.... Among the participants who contributed each year, the average employee contribution increased from $2,405 in 2019 to $2,778 in 2020 and $3,012 in 2021.... Participants' exposure to equities and the other asset classes remained relatively constant over the 2019 -- 2021 timeframe.... the utilization rate of target-date funds remained steady, with 36.6% of the consistent sample participants allocating their entire portfolio to target-date funds every year from 2019 to 2021."  MORE >>

Employee Benefit Research Institute [EBRI]

[Opinion]

The Biggest 401(k) Rollover Mistake

"28% of rollover investors stayed in cash for at least 12 months, with minimal changes after the first three months following the contribution ... [A]mong rollovers conducted in 2015, 28% remained in cash for at least seven years ... [Y]ounger investors, women, and those with smaller balances are especially prone to staying in cash for years following a rollover."  MORE >>

Data 'Points'

Benefits in General

[Official Guidance]

IRS Relief Now Available to Hurricane Debby Victims in All of South Carolina, Most of Florida and North Carolina, Part of Georgia

"The [IRS] announced tax relief for individuals and businesses in four states affected by Hurricane Debby. Affected taxpayers in South Carolina, North Carolina, Florida and Georgia now have until Feb. 3, 2025, to file various federal individual and business tax returns and make tax payments.... Currently, this applies to: All 46 counties in South Carolina [SC-2024-07] ... 61 counties in Florida [FL-2024-07] ... 55 counties in Georgia [GA-2024-06] ... 66 counties in North Carolina [NC-2024-07]."  MORE >>

Internal Revenue Service [IRS]

Plan Sponsors: What Not To Do

"EBSA offers this list of failures to steer away from: [1] Failing to operate the plan prudently and for the exclusive benefit of participants; [2] Using plan assets to benefit certain related parties to the plan ... [3] Failing to properly value plan assets at their current fair market value, or to hold plan assets in trust; [4] Failing to follow the terms of the plan ... [5] Failing to properly select and monitor service providers; [6] Taking any adverse action against an individual for exercising his or her rights under the plan ... [7] Failure to comply with ERISA Part 7 and the [ACA] ."  MORE >>

Colonial Surety Company

DOL, General Services Administration to Centralize Government Benefits Information

"The [DOL] and the General Services Administration [on August 7] announced a collaborative effort to centralize government benefits information on USA.gov and USAGov en Español, which will offer a new benefits experience for the public in English and Spanish. Benefits.gov, a website managed and hosted by the department since 2002, will shut down in September 2024."  MORE >>

Office of the Assistant Secretary for Administration & Management, U.S. Department of Labor [DOL]

Employee Benefits Jobs

View job as VP Consulting OPEB Actuary for American Trust Retirement

VP Consulting OPEB Actuary

American Trust Retirement

Remote

View job as VP Consulting OPEB Actuary for American Trust Retirement

Press Releases

Lincoln Financial Group Expands Suite of In-Plan Guaranteed Lifetime Income Products to Offer More Flexibility, Choice and Customization in Retirement

Lincoln Financial Group

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

Mastering IRC 457(f): Guidance for ERISA Counsel in Structuring Deferred Compensation Plans for Nonprofit Entities

September 25, 2024 WEBINAR

Strafford

Last Issue's Most Popular Items

Retirement Plan Design: Bona Fide Job-Based Exclusion or Impermissible Service Condition?

Morgan Lewis

New DOL Fiduciary Rule Stayed: What Advisors and Insurance Agents Recommending Rollovers Should Do Now

Faegre Drinker

Plan Records: What Are They, How Long to Keep Them, and Security Considerations

Blue Ridge ESOP Associates

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

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