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Retirement Plans Newsletter
June 5, 2026
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💼 New Job Opportunity Today
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[Official Guidance]
Text of IRS Publication 4810: Specifications for Electronic Filing of Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits (PDF)
56 pages, rev. May 2026 "What's New for Tax Year 2025 ... [1] Due to the planned retirement of the Filing Information Returns Electronically (FIRE) System, the IRS will no longer accept new Information Returns (IR) Applications for Transmitter Control Codes
(TCCs) beginning July 21, 2026. Existing applicants can continue to update their applications through December 2026, after which they will become read-only and retained for historical reference. [2] Current FIRE users must complete an Information Returns Intake System (IRIS) Application for TCC and transition to IRIS for electronic filing beginning with the 2027 filing season. IRIS will be the only information returns
electronic filing system, including current year, prior year, or corrections, after January 1, 2027." MORE >>
Internal Revenue Service [IRS]
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[Guidance Overview]
IRS Issues List of Required Changes for Cycle 4 Defined Benefit-Qualified Pre-Approved Plan Document Restatements
"Notice 2026-34 identifies recent changes in plan qualification requirements that the IRS will
consider when reviewing defined benefit-qualified (DB-qualified) pre-approved plans for the fourth remedial amendment cycle (Cycle 4).... DB-qualified pre-approved plan document providers seeking Cycle 4 IRS opinion letters for the updated pre-approved plans they will ultimately offer for adoption by plan sponsors may submit applications from August 1, 2026, through July 31, 2027." MORE >>
Milliman
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[Guidance Overview]
Did the SEC Crack Open a Window for PEPs?
"[The SEC Staff Statement] acknowledges that PEPs were intended to fit within the framework that allows retirement plan trusts
to avoid being treated as investment companies -- and says that while they don't fit neatly in the single trust exemption, the staff won't object if an otherwise compliant ERISA-covered PEP treats itself as a single trust.... The SEC essentially signals that while the exemption doesn't quite fit, they aren't looking for PEPs to start registering." MORE >>
American Retirement Association [ARA]
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[Guidance Overview]
401(k)ology: IRC §415(c) Annual Additions Limitation
"[This article breaks] down the Section 415 limits, how they work, and why they matter, especially if participants work for more than one employer in a year, for related companies, or for companies that become related through a merger or acquisition ... how age 50+ catch up
contributions factor into the equation ... [and] the correction method for excess annual additions." MORE >>
Newfront
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Outdated Assumptions, New Exposure: What a Recent Eleventh Circuit Decision Means for Defined Benefit Plans
"The Eleventh Circuit's ... decision ... highlights growing litigation risk for defined benefit pension plans that rely on outdated 'legacy' actuarial assumptions, particularly outdated interest rates.... Pre‑1980s tables and fixed interest rates tied to older
economic conditions are increasingly difficult to defend." [Drummond v. Southern Company, No. 24-12773 (11th Cir. May 26, 2026)] MORE >>
Nelson Mullins
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New Clearinghouse Offers Solution for Missing Participant Retirement Accounts
"The National Association of Unclaimed Property Administrators (NAUPA) would create a centralized reporting portal [called SURCH (States Unclaimed Retirement Clearing House)] for these plans to report any missing retirement funds. NAUPA would then take the data, the last known address of record, and the funds, distribute that to the appropriate state unclaimed property office, which would then take it from there and attempt to identify and remit the funds to the appropriate owner.... Once the funds are transferred ... retirement plan
administrators and recordkeepers are relieved of responsibilities for those funds[.]" MORE >>
American Retirement Association [ARA]
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AI Is Not the Future, It Is the Operating Model: A TPA Case Study
"Artificial intelligence is often framed as an emerging capability. For organizations focused on long-term growth, it is increasingly becoming part of the operating model.... Work that used to take hours each month has been reduced to minutes. Not through a single tool, but
through connected automations that remove friction at each step." MORE >>
The Retirement Advantage
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Roundup of Selected Federal Retirement Legislation, 2025-2026 (PDF)
12 pages. "This roundup highlights noteworthy bipartisan and partisan retirement-related bills pending in Congress, listed in chronological order based on their date of introduction, describing their content and status, and indicating where a more in-depth GRIST on the
legislation is available." MORE >>
Mercer
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Supportive Comment Letters Urge Refinements to DOL Investment Rule
"Comment letters from the business, finance, and employee benefits communities have been broadly supportive of the [DOL's] Investment Selection Proposal, though many of these letters have also recommended various improvements and clarifications. In particular, industry letters urged the DOL to clarify the status of outside fiduciary advisers, the duty to monitor and to reconsider the DOL's wording regarding 'maximizing' returns." MORE >>
Plan Sponsor Council of America [PSCA]
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U.S. House Committee Probes Whether CalPERS 'Radical' ESG Threatens Pension Fund's Tax-Exempt Status
"Recently, [the U.S. House Education and Workforce Committee] began probing whether 'radical' environmental, social,
and governance (ESG) investments at CalPERS could threaten the fund's tax status.... The Committee noted that CalPERS claims significant tax benefits under Code section 401(a), which applies only to plans maintained 'for the exclusive benefit of [an employer's] employees or their beneficiaries.' However, the instances cited [by the Committee] do not appear to be consistent with this rule. To the extent that CalPERS is
using plan assets for the benefit of social or political causes, the plan's qualified tax status is no longer valid, according to the Committee." MORE >>
Edward Siedle
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Benefits in General |
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[Guidance Overview]
DOL's ERISA Enforcement: Spring 2026 Updates
"The Department's current leadership continues to state that it intends to move away from 'regulation by enforcement.' The Department recently announced updates to its official enforcement priorities, and some of the changes reflect material shifts. The Department
updated its statistics on its enforcement accomplishments. By examining trends related to these, it is possible to extrapolate some sense of how active enforcement has been, and likely future DOL priorities. The statistics suggest some slowing down of enforcement activities (or at least recoveries)." MORE >>
Morgan Lewis
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Executive Compensation and Nonqualified Plans |
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[Official Guidance]
Text of IRS Notice 2026-36: Notice of Intent to Issue Regulations Under Section 4960 (PDF)
"This notice announces that the Department of the Treasury and the [IRS] intend to issue proposed regulations under section 4960 of the Internal Revenue Code (Code)1 pertaining to the tax on excess tax-exempt organization executive compensation. It is anticipated that the
proposed regulations will address the effective date of the amendment to the definition of covered employee made by section 70416 ... the One, Big, Beautiful Bill Act (OBBBA) and will also propose exceptions to the definition of covered employee that are similar to the limited hours and nonexempt funds exceptions in the existing section 4960 regulations. This notice also solicits public comments on the matters addressed in
this notice." MORE >>
Internal Revenue Service [IRS]
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To Pay Now or Pay Later: The Fundamentals of Nonqualified Deferred Compensation Plans
"[Nonqualified deferred compensation plan (NDCP)] benefits only remain tax-deferred until a future date if the underlying NDCP is structured to provide what is essentially an unfunded and unsecured promise to pay benefits in the future. How an NDCP sponsor company chooses to set
aside assets to 'fund' these liabilities -- or whether it funds them at all -- has significant implications for its cash flow, taxes, and balance sheet health. Here is a summary of the primary methods used to manage these future obligations." MORE >>
Milliman
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Employee Benefits Jobs
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Press Releases |
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Voya Investment Management Launches New Multi-Manager Alternative CITs
Voya Financial
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Last Issue's Most Popular Items |
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Required Retirement Plan Amendments and Pre-Approved Plan Restatements: Action Required by December 31
Husch Blackwell
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Text of IRS Notice of Public Hearing on Proposed Regs for Trump Accounts
Internal Revenue Service [IRS]
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Reading the Tea Leaves, Part 2: Practical Risks in the DOL's Proposed Fiduciary Rule
American Retirement Association [ARA]
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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.
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