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SunGard Relius Advises Practitioners to Skip Existing Forms, Wait for New Forms 8955-SSA and 5558

At a recent ASPPA actuarial conference (ACOPA), an IRS official made several announcements .... While the IRS prefers for practitioners to wait for the new Form 8955-SSA, the IRS will continue to accept the old Schedule SSA. This conflicts with printed, official guidance in Announcement 2011-21, stating that the IRS would accept the old Schedules through April 20, 2011.... Our recommendation is that practitioners continue to wait for the new [form and for a new Form 5558,] which we expect the IRS to issue shortly.

Update on 'Relative Value' Regulations and SunGard Relius Forms

Excerpt: The postponement of the regulations with respect to QJSA explanations will apply to all defined contribution plans and to most defined benefit plans. The postponement does not apply to QJSA explanations for defined benefit plans where the plan permits distributions that are subject to IRC §417(e)(3) (e.g., lump-sum distributions) and the present value of such distributions are less than the value of the QJSA.

SunGard Relius Publishes Updated Summary of Material Modifications for Plan Expenses

Excerpt: An updated version of our sample Summary of Material Modifications(SMM) regarding the payment of plan expenses is posted on our Web site. This SMM takes into account the DOL guidance issued in Field Assistance Bulletin 2003-3, which permits a plan to charge the account of a particular participant for certain plan expenses incurred by or attributable to that participant.

SunGard Relius Technical Update Addresses Amendment of New Comparability Plans

Excerpt: We are providing the following information for the benefit of subscribers to the Corbel, PPD and FDP volume submitter cross-tested plan documents [concerning] options for amending an employer's plan to provide ... the 'minimum gateway' allocations generally required under [the cross-tested regulations, if the plan is top-heavy or uses a 3% nonelective contribution to qualify a 401(k) plan as a safe harbor plan].

SunGard Relius Publishes EGTRRA Good Faith Defined Benefit Amendment

Excerpt: We have posted an EGTRRA good faith amendment for defined benefit plans on our Web site.... If you sponsor one of our prototype plans (Corbel, PPD, or FDP), a separate e-mail is being sent EARLY NEXT WEEK with the EGTRRA good faith amendments that can be adopted at the sponsor level.... IMPORTANT NOTE: In many cases the amendment may need to be adopted by May 31, 2002. See IRS Notice 2001-42.

2009 End-of-Year Update on Required Retirement Plan Amendments

The article is written for users of Relius documents, but includes links to documents that contain lists of general interest to qualified retirement plan sponsors.

GUST Pre-Approved Plan Program Will Close June 15, 2005

Excerpt: IRS Announcement 2005-36 also sets a deadline of October 31, 2005 for the submission of EGTRRA 'lead' defined contribution prototype and volume submitter plans by mass submitters. This only impacts SunGard Relius (and other mass submitters). It does not impact the deadline by which submissions must be made on behalf of entities using these plans (the deadline for the submission of plans based on these plans is still January 31, 2006).

Interim Valuations in a Volatile Market: Important Considerations for Balance-Forward Retirement Plans

"The recent volatility in the financial markets has prompted increased attention to the possibility and appropriateness of daily valued defined contribution retirement plans performing interim valuations prior to making participant distributions.... Plan fiduciaries responsible for making decisions about plan valuations and distributions will want to review their plan documents carefully and consider the following with their legal counsel. [1] Plan documents ... [2] The anti-cutback rule  ... [3] Additional fiduciary considerations  ... [4] Participant communications  ... [5] Other actions to consider."

Final Hardship Regs: What You Need to Know

"[1] How did we get here? ... [2] What hardship provisions were modified as part of the Final Regulations? ... [3] Can Plan Sponsors rely upon their adoption of administrative changes implementing the proposed hardship regulations? ... [4] When does the hardship amendment need to be adopted? ... [5] Will document providers be able to sign the amendment on behalf of their employer-clients?"

DOL Provides Form 5500 Transition Relief for MEP Filings

"For plans that satisfy the requirements of the transition relief, the DOL will not reject the Form 5500 (or Form 5500-SF) or seek to assess penalties with regard to those filings solely due to the failure to comply with the Section 103(g) reporting requirements. Form 5500/5500-SF filings for 2014-2017 do not have to be amended to take advantage of this relief."