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Mental Health Parity Final Rule Imposes Year-end Action Items on Group Health Plan Sponsors

On September 9th, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) issued the much anticipated final rule under the Mental Health...more

BCLP Benefits Newsletter: Summer 2021

Congress extended the availability of refundable tax credits for Eligible Employers who provide paid family leave or sick leave from April 1, 2021 to September 30, 2021 in connection with COVID-related illness. Under ARPA,...more

BCLP Benefits Newsletter: Q1 2021

ARPA provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an involuntary termination of employment or a...more

BCLP Benefits Q3 2020 Newsletter: IRS, DOL, and PBGC Guidance

In this edition of our newsletter, we have summarized key third quarter guidance from the Internal Revenue Service ("IRS"), Department of Labor ("DOL"), and Pension Benefit Guaranty Corporation ("PBGC"). As we look back on...more

BCLP Benefits Mid-Year 2020 Newsletter: Q2 2020 COVID-19 and Additional Regulatory Guidance

In the second quarter of 2020, we have seen employers faced with continued challenges as they manage the impact of the COVID-19 pandemic on their businesses and begin the process of returning to normal operations. The flurry...more

DOL Rolls Out Public Search Engine for Top-Hat Plan Statements

Top-Hat plans are unfunded plans for a select group of management or highly compensated employees that are exempt from a number of ERISA provisions (such as reporting, funding, testing, and certain fiduciary obligations). In...more

New Year’s Resolution for 403(b) Plan Sponsors

Previously we posted on our blog about a deadline looming in the distance for 403(b) plan sponsors to adopt a pre-approved plan document. Now that 2020 has arrived, the deadline is just around the corner and imminent action...more

IRS Takes Step Towards De-Risking Retiree Lump Sum Windows

On March 6, 2019, the IRS announced that it will not amend the minimum required distribution regulations under Code section 401(a)(9) to expressly prohibit lump-sum window elections for retirees who are already receiving...more

Deadline Looming in the Distance for 403(b) Plans: What Plan Sponsors Should Be Doing Now

Last year when the IRS announced that the initial remedial amendment period for 403(b) plans will end March 31, 2020, the natural reaction to this very important (but rather remote) deadline was to immediately put it on the...more

IRS Views on Self-Certification of Financial Hardship

In today’s virtual world, we suspect most plan sponsors rely upon the self-certification process to document and process 401(k) distributions made on account of financial hardship. The IRS has recently issued examination...more

ISS Updates Proxy Voting Guidelines for 2017

Last month, Institutional Shareholder Services (ISS) published updates to its proxy voting guidelines effective for meetings on or after February 1, 2017. Key compensation-related changes include the following...more

PBGC Proposed Rule May Offer DC Plans New Tool for Finding Missing Participants

For many years, the PBGC has been helping reunite missing participants with their benefits under single-employer defined benefit plans. Now, a new PBGC proposed rule may open up the program to missing participants under other...more

Department of Labor Fiduciary Rule: Employers Should Not Overlook Impact on HSAs

The new Department of Labor rule defining the scope of who is an ERISA fiduciary has caused much consternation among investment professionals. Much of the new rule is focused on reworking the outer fringes of the ERISA...more

Undermining the Goal of Expanding Coverage for Nonhighly Compensated Employees

One might be led to believe that the current administration is in favor of expanding retirement savings opportunities. After all, the DOL has somewhat apologetically subverted ERISA to allow the States to sponsor...more

The FAST Act – If You Blinked You May Have Missed It.

On December 3, 2015, the President signed into law the Fixing America’s Surface Transportation Act (the “FAST Act”) which provides for five years of funding for highway projects. If you just skimmed the news on this one, you...more

The Tax Man Cometh Not to ID Protection Recipients Either

Late last year, while you were probably busy picking out which bubbly to pop at the stroke of midnight, the IRS gave us another reason to celebrate. You may remember (as we wrote previously) the IRS said it would not require...more

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