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Study: Multiemployer Pension Plan Crisis Has Deepened (PDF)

"As many as 121 multiemployer pension plans covering 1.3 million workers are underfunded by $48.9 billion and have informed regulators and participants that they could become insolvent within 20 years ... Cheiron's August 2017 study found 114 multiemployer pension plans were underfunded by $36.4 billion ... Some plans have since terminated because all the employers withdrew. Even after removing these plans, the number of failing multiemployer pension plans increased by 6.1 percent ... The plans in this year's study have total assets of $40.7 billion and liabilities of $89.6 billion."

PBGC Announces 2026 Premium Rates

"Both the single-employer and multiemployer plan rates have increased. [A chart] shows the rates in effect for plan years beginning in 2024, 2025, and 2026."

DOL Issues New Model Annual Funding Notices

"The two model notices have significant differences from the prior model that go beyond incorporating the changes made by section 343 of the SECURE 2.0 Act. For example, the introductory language has been significantly revised. Plan administrators may want to consider whether they should adopt the new model notices right away or whether any notice that was about to be sent would be a reasonable alternative taking into account the latest guidance."

PBGC Premiums for 2025 Plan Year Due Earlier Than Usual

"[B]ecause of a provision in the Bipartisan Budget Act of 2015, premiums for plan years beginning in 2025 are generally due a month earlier than usual. For example, the premium filing and payment for a plan with a calendar plan year will be due September 15, 2025, instead of the normal due date of October 15, 2025. This acceleration of premium dues dates applies only for plan years that begin in 2025."

DOL Appoints New ERISA Advisory Council Members

"The 2025 appointees and their areas of expertise are as follows: [1] Actuarial Counseling: Christian Benjaminson is a vice president and principal consulting actuary at Cheiron Inc.... [2] Employee Organizations: Wendell Young is the President of United Food and Commercial Workers Local 1776 Keystone State as well as Vice President of the UFCW International Union.... [3] Employers: Jay Dorsch is the chair of the Employee Benefits and Executive Compensation practice of Cozen O'Connor ... [4] General Public: Elizabeth Hopkins is a senior partner at Kantor & Kantor LLP and head of the law firm's pension practice.... [5] Investment Counseling: Craig Wright is a founding partner at Strategic Financial[.]"

Extension of Certain Timeframes for Participants in Group Health Plans Affected by Hurricanes Helene and Milton

"In general, the items receiving extensions for participants and beneficiaries are similar to those receiving extensions that were provided with respect to COVID-19, e.g., claims filing deadlines, but begin based upon the geographic locale of the participants and beneficiaries, and the extensions all have an end date of May 1, 2025."

IRS Issues Final Regs on Minimum Required Distributions to Implement the SECURE Act

"The final regulations do not allow a defined benefit plan to provide a single uniform required beginning date of April 1, following the calendar year of attainment of age 70 ½. That means that a plan amendment would be required to change the required beginning date for those born on or after July 1, 1949.... [T]he rule facilitates in-service annuity distributions to participants, and does not require a plan to change distributions in pay status merely because the participant has attained an applicable age."

Reminder: PCORI Fee Due July 31

"Sponsors of plans subject to the PCORI fee need to determine the average number of covered lives and file IRS Form 720 by July 31, 2024, along with payment of the required fee."

2025 Maximum Out-of-Pocket Limits, HSA Parameters, and Excepted Benefit HRA Limits

"[A chart] compares this year's limits and parameters to the 2025 limits. For the first time, the maximum out-of-pocket limits for non-grandfathered health plans will decrease."

IRS Issues Updated Rules on Minimum Present Value of Benefits

"The updated regulations make it easier for a plan to change the lookback month or stability period as needed.... If a plan has employee contributions, an amendment will likely be needed to satisfy the requirement that no mortality be taken into account for the employee-derived portion of the accrued benefit.... If a plan has a Social Security level income option that does not already satisfy the minimum present value requirements, then the plan will need to be amended so that either the entire option satisfies the present value requirements or the plan provisions satisfy the implicit bifurcation rule."