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14Dec

FLASHPOINT: NEW SECURE SAFE HARBOR 401(K) PLAN RULES: YOU CAN DO THE SAFE HARBOR NONELECTIVE HOKEY POKEY!

In brand new Notice 2020-86, issued on December 9, 2020, the IRS provides some additional guidance on the post-SECURE safe harbor 401(k) plan rules.  One of the items addressed in the Notice demonstrates the IRS’s holiday season generosity!  As this can help employers for the 2020 plan year end, we thought it was important to […]
18Aug

FERENCZY FLASHPOINT: USER FEES GOING UP AND CARES UPDATE

Updated User Fees for IRS Filings The IRS just issued the user fees for 2021 in Announcement 2020-14.  Unlike in 2018, when the IRS increased user fees overnight with no advance notice (yes, we hold a grudge), the IRS is letting us know several months in advance so that we can take some preemptive action […]
05Aug

FLASHPOINT: SEP, MEP, OR PEP IDENTIFYING THE KEY DIFFERENCES IN RETIREMENT PLANS

The attached white paper by Alison Cohen and Ilene Ferenczy was commissioned by Transamerica Retirement Solutions, LLC to help explain the differences between single-employer, multiple-employer, and pooled-employer plans, as well as other group programs for offering retirement benefits. Please feel free to download the paper and share it with your friends, colleagues, and clients. If […]
30Jun

FLASHPOINT: IRS STILL CARES SUSPENSION OR REDUCTION OF SAFE HARBOR CONTRIBUTIONS FOR 2020

In Notice 2020-52 (the “Notice”), issued on June 29, 2020, the IRS continues providing relief for employers during the COVID pandemic.  In particular, the Notice permits employers to suspend or reduce safe harbor contributions in 401(k) and 403(b) plans after March 13, 2020, for the balance of the year, regardless of whether the employer is […]
24Jun

FLASHPOINT: WAIT! THERE’S MORE! IRS ISSUES CARES RMD GUIDANCE

Under the heading of “No Good Deed Goes Unpunished,” we were just patting ourselves on the back for getting out the Notice 2020-50 FlashPoint so quickly when the IRS laughed in our face.  A mere two working days later, on June 23, 2020, the IRS issued Notice 2020-51 (the “Notice”), providing guidance in relation to […]
22Jun

FlashPoint: The IRS CARES! (Who’d Have Thunk?) Expanded List of Qualified Individuals and More Info!

On Friday, June 19, 2020, the IRS issued Notice 2020-50 (the “Notice”), which provides expanded guidance on Coronavirus-Related Distributions (“CRDs”) and the CARES participant loan rules. Expansion of Definition of Qualified Individual You may recall from the prior Flash, “Coronavirus Relief from Congress – The CARES Act,” that the following individuals were considered to be […]
02Jun

FLASHPOINT: RIDERS, FEET ON THE PEDALS! DC TRICYCLE RESTATEMENTS ARE ABOUT TO BEGIN!

The IRS has just announced (Announcement 2020-07) the key details for the third cycle (“Tricycle”) of restatements for preapproved defined contribution plans. Document providers submitted their draft documents in 2018, and the IRS anticipates completing its review and issuing opinion letters for these preapproved plans on June 30, 2020. This will begin the formal restatement […]
28May

FLASHPOINT: THE DOL EDISCLOSURE REGULATIONS: REDUCTION IN PAPER AND MAILING COSTS (BUT NO GUARANTEE THAT THE DOCUMENTS HAVE BEEN READ UNDER INTEL)

On May 21, 2020, the U.S. Department of Labor (“DOL”) published the final rule on Electronic Disclosure Safe Harbor options for retirement plans (“eDisclosure Regs”).  It is important to note that these new eDisclosure Regs don’t replace the original eDisclosure Regulations issued on April 9, 2002 (“2002 Regs”), but rather prove additional options for plan […]
05May

FLASHPOINT: DEALING WITH THE PANDEMIC: IRS AND DOL AUTHORIZED DELAYS

Both the Internal Revenue Service (IRS) and the Employee Benefits Security Administration (EBSA) (the section of the U.S. Department of Labor (DOL) with jurisdiction over employee benefit plans) recently issued guidance delaying certain plan-related deadlines while the COVID pandemic is ongoing.  Some of these delays apply to the participants, generally giving them more time to […]