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If the Deadline for Self-Correcting Retirement Plan Errors Is Indefinite, Why Do I Have to Hurry?

Section 305 of SECURE 2.0 added rules for self-correcting a new category of retirement plan errors under the Employee Plans Compliance Resolution System (“ECPRS”). Specifically, Section 305 allows an “eligible inadvertent...more

DOL Final Regulations on ESG Investing: “It’s All ‘Bout the Money”

Whether it is appropriate for institutional investment decision-makers to take into account environmental, social, or governance (“ESG”) factors or invest to promote ESG objectives, has become a divisive political issue and a...more

401(k) Plan Sponsors – It Doesn’t Pay to Ignore Your Plan’s Definition of Compensation

One of the most common errors in 401(k) plan administration continues to be a mismatch between a plan’s definition of compensation and the actual compensation taken into account for plan purposes despite this problem being...more

Knowledge is Power: Information Available to Contributing Employers in Multiemployer Fringe Benefit Plans

Employers that contribute to multiemployer fringe benefit plans are generally aware of the financial risks associated with these plans. In addition to making regular contributions to these plans required by their collective...more

Does the Tail Know What the Head is Doing? – The Importance of Internal Communication Between Management and Employee Benefits...

Employers who sponsor employee benefits plans are used to providing ongoing communication to plan participants.  The communications range from legally required disclosures (e.g., summary plan descriptions) to legally required...more

Hey Employers, Can You Prove You Don’t Owe Multiemployer Fringe Fund Contributions?

Employers who sponsor employee benefits programs understand the importance of maintaining accurate records of benefit eligibility, elections, claims, payments, and other data. Besides complying with ERISA’s record keeping...more

401(k) and 403(b) Fund and Fee Litigation: Employers, Can You Answer These Four Questions?

Most employers sponsoring 401(k) and 403(b) plans are well aware of the large number of lawsuits filed over the past decade or so alleging breach of ERISA fiduciary duty related to plan investment funds and service providers....more

Summary of Employee Benefits Provisions in CARES Act (As Passed by U.S. Senate)

On March 25, 2020, the Senate passed the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, as a follow-up to the Families First Coronavirus Response Act. The Act contains a number of employee benefits related...more

Employer Actions for 401(k) Plans Sickened by Coronavirus

The realities of the Coronavirus (Covid-19) pandemic have quickly and dramatically changed the way we work, shop, seek health care, and interact with each other. ...more

Early Holiday Gift for Employers – IRS Extends 2019 ACA Reporting Deadline

As it has done in past years, the IRS has extended the Affordable Care Act (“ACA”) deadline for health plan sponsors to furnish individuals IRS Forms 1095-B and 1095-C by 30 days (IRS Notice 2019-63). ...more

Pay Attention to Requests for ERISA Plan Documents or Risk the Con$equence$

Every so often an employer sponsoring an ERISA employee benefit plan will receive a written request from a participant or beneficiary (or their legal counsel) to provide plan related documents....more

Another Multiemployer Pension Fund Cautionary Tale: Employer Does Not Owe Withdrawal Liability, But May Still Owe An "Exit Fee"

Employers that completely or partially withdraw from underfunded multiemployer pension funds are well aware that they may owe the fund withdrawal liability—an assessment against the employer of its allocable share of the...more

A Written Fee Policy Can Help Employers Answer the Question: Who Pays for Your 401(k) or 403(b) Plan’s Administrative Costs and...

Most employers are familiar by now of the many lawsuits (more than 100) filed against 401(k) and 403(b) plan sponsors and their employee fiduciaries responsible for selecting the plans’ record keepers and investment line-ups,...more

Don’t Believe Everything You Hear – You Can Terminate Your 401(k) Safe Harbor Match Formula Mid-Year (Usually)

I have recently had two separate employers tell me that they wanted to stop making safe harbor matching contributions to participants in their 401(k) retirement plans in the middle of a plan year. ...more

Buyers Beware: Sixth Circuit Holds That Asset Purchaser Can Be Sued for Predecessor’s Unpaid Pension Liability

In a typical asset sale transaction, the purchaser takes great care to disclaim any responsibility for the seller’s business debts. When the seller is a sponsor of a defined benefit pension plan, this typically includes a...more

Changes to Retirement Plan Hardship Distribution Rules

As Congress negotiated the legislation that ended up as The Tax Cut and Jobs Act (“Jobs Act”) and the Bipartisan Budget Act of 2018 (“Budget Act”), it considered significant changes to employer based retirement plan rules. ...more

It’s Official - Implementation of Final Rule on Disability Claims Procedures Formally Delayed

On November 24, 2017, the Department of Labor (“DOL”) Employee Benefits Security Administration (“EBSA”) formally delayed the applicability date of previously issued final regulations imposing new claims procedures to...more

The Department of Labor Confirms June 9th as the Effective Date of the Fiduciary Rule: What Employers Need to Know Now

On May 22, 2017, Secretary of Labor Jim Acosta announced that, after having been delayed 60 days, the Department of Labor’s (“DOL”) Conflict of Interest Rule (“Fiduciary Rule”) will largely apply on June 9, 2017. At that...more

The IRS Overhaul of the Determination Letter Process: What Plan Sponsors Need to Know

Last summer, the Internal Revenue Service (IRS) announced that its periodic review of individually designed retirement plans to determine the plans’ qualified status will end effective January 31, 2017. In January 2016, the...more

The U.S. Supreme Court Rules Defense Of Marriage Act Unconstitutional: Significant Implications For Employee Benefit Plans

On June 26, 2013, in U.S. v. Windsor, the US Supreme Court held the federal Defense of Marriage Act (“DOMA”) unconstitutional as a violation of the right to liberty found in the due process clause of the 5th Amendment to the...more

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