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The SECURE Act: How This Brand New Law Affects Your Retirement Accounts
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On January 14, 2025, the DOL issued Field Assistance Bulletin (FAB) 2025-01, providing sponsors and administrators of ongoing defined contribution plans with a new option for missing participant balances of $1,000 or less:...more
IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code....more
The Internal Revenue Service (“IRS”) provided welcome relief for administrators of plans offering catch-up contributions. Notice 2023-62, issued on August 25, essentially delays the effective date of a provision under the...more
Non-ERISA 403(b) plans are still one of the stains of the retirement plan business because, without that ERISA protection, it puts participants at risk for high fees and fraud....more
This month’s Friday Five highlights both circuit and district court opinions on the scope of ERISA preemption, discretionary review and exhaustion of administrative remedies....more
Seyfarth Synopsis: The IRS released final regulations, under T.D. 9937, that generally adopt the proposed rules relating to qualified plan loan offsets issued last year, with one modification relating to the applicability...more
The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”), made sweeping changes to retirement plan rules. As described in our prior alert, certain provisions took effect immediately and were...more
The Internal Revenue Service (IRS) recently released two notices that provide additional guidance for retirement plan administrators and qualified individuals about the special distribution, plan loan, and required minimum...more
Yesterday, the IRS issued additional guidance regarding two hot topics over the last six months: the waiver of the 2020 required minimum distributions (RMDs) from retirement plans and IRAs, and the change in the required...more
Troutman Sanders and Pepper Hamilton are producing a series of podcasts to discuss employee benefits, executive compensation, and labor and employment issues that employers are confronting in light of the COVID-19 pandemic,...more
Congress recently passed the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade. Many of the provisions in the SECURE Act...more
On Thursday, December 19, the Senate passed two spending bills to fund the government through September 30, 2020, one of which (H.R. 1865, the “Further Consolidated Appropriations Act of 2020” or the “Act”) contains the...more
Employers, plan sponsors, and plan administrators ring in the New Year with new recordkeeping and administrative challenges for 2020 and beyond. After much anticipation, on December 20, 2019, Pres. Donald Trump signed into...more
The Tax Cuts and Jobs Act of 2017 (“2017 Tax Act”) includes a provision that changed the rollover rules for certain plan loan offset distributions and that may not be well known to retirement plan sponsors and participants. ...more
The IRS has issued new model notices for recipients of rollover distributions from qualified retirement plans. The updated notices reflect changes from the 2017 tax reform act, as wells as regulatory changes enacted since...more
• The recent Tax Cuts and Jobs Act of 2017 (the Act), enacted on Dec. 22, 2017, contains a few rules that will impact benefit administrators. • This client alert focuses on changes made to the tax treatment of plan loan...more
The Internal Revenue Service (IRS) has issued Revenue Procedure 2016-47, which provides for a new self-certification procedure for participants who receive retirement plan distributions but inadvertently miss the 60-day time...more
The Future Is Now For 401(k) Plan Sponsors. The future is here. When I was the head ERISA attorney at a New York based third party administrator (TPA), I left because I saw the future of the retirement plan...more
Life is a numbers game. Whether it’s business, family, or pleasure, numbers do matter. What the numbers say today, may not say tomorrow and you can often predict the future of the numbers because demographics are pointing the...more
The administrative burden of determining the validity of rollover contributions to qualified retirement plans, and the associated risk of jeopardizing the plan’s tax-qualified status, traditionally has been a significant...more
To simplify the rollover validation process, the Internal Revenue Service (IRS) has issued a new Revenue Ruling 2014-9 that provides guidance on the process for a trustee-to-trustee tax-free rollover between tax-qualified...more