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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 […]
21Apr

FLASHPOINT: WHAT PLAN SPONSORS SHOULD KNOW ABOUT CARES

The attached white paper by Ilene Ferenczy was commissioned by CUNA Mutual Group to help explain the advantages to both companies and their employees of the retirement plan provisions in CARES.  The article also discusses some of the ways in which sponsors can reduce or eliminate 2020 contribution obligations during this time of economic uncertainty. […]
24Dec

FLASHPOINT: NEW PENSION LEGISLATION PASSES! FEELING MORE SECURE?

Against what seemed to be all odds, Congress got together on December 19, 2019, to pass the Setting Each Community Up for Retirement Enhancement (SECURE) Act.  It was signed into law by the President on Friday, December 20. The most extensive retirement plan legislation since the Pension Protection Act of 2006, SECURE contains several of […]
30Jul

FLASHPOINT: THE DOL FINALIZES MEP REGULATIONS

As discussed in our FlashPoint dated October 25, 2018, available here: https://ferenczylaw.com/flashpoint-the-new-mep-meh-proposed-regulations/, the U.S. Department of Labor (“DOL”) previously introduced proposed regulations relating to certain defined contribution multiple employer plans (“MEPs”). These regulations were issued in final form on July 29, 2019 (the “Regulation”), and offer the ability of “bona fide” organizations, associations, and professional […]
23Apr

FLASHPOINT: CORRECTIONS MADE EASIER: THE IRS EXPANDS THE SELF-CORRECTION PROGRAM

Last year, the IRS modified its correction programs for qualification failures (the “Employee Plans Compliance Resolution System” or “EPCRS”) to significantly increase the fees for taking part in the Voluntary Compliance Program (“VCP”). (See our previous FlashPoint on this subject.) Since that occurred, the retirement plan community has responded with demands that the IRS expand its […]
04Apr

FLASHPOINT: THINGS ARE HAPPENING … FINALLY!

After a period of national quiet in relation to retirement plans, several things have occurred recently that are worth discussing. Sorry that this is a longer newsletter than we like, but we wanted to give you quick feedback on what’s finally going on. California’s State-Mandated Retirement Program Survives Preemption Challenge One of the interesting trends […]
25Oct

FLASHPOINT: THE NEW MEP (MEH!) PROPOSED REGULATIONS

The Department of Labor (“DOL”) issued proposed regulations (the “Proposal”) on October 22, 2018, that represent the first major step in changing its restrictions on multiple employer plans (“MEPs”). However, it is just the first step, and does not change the landscape for Open MEPs. The Proposal was issued in response to the President’s August […]
03Oct

FlashPoint: New EPCRS Procedure: Electronic Submission of VCP and Not A Whole Lot More

On September 28, 2018, the IRS issued Revenue Procedure 2018-52, the latest version of the Employee Plans Compliance Resolution System (“EPCRS”), the IRS’s comprehensive procedures for correcting retirement plan errors. Using this procedure, retirement plan sponsors may fix mistakes in their qualified plans, 403(b) plans, 403(a) retirement annuities, SEPs, and SIMPLEs. Although they are not […]
19Oct

FLASHPOINT – IRS ANNOUNCES 2018 COST OF LIVING ADJUSTMENTS

The IRS just released the cost of living adjustments for various retirement plan limitations that will take effect on January 1, 2018.  Many of the limits will be increasing for 2018. The Consumer Price Index, on which these limits are based, went up 2.2% during the prior twelve months.  The key limits that increased (shown […]