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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

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

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 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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