News & Analysis as of

Plan Documents Retirement Plan Employee Retirement Income Security Act (ERISA)

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Tips for 401(k) Plan Providers (From Someone Who’s Seen the Industry From the Inside Out)

Fifteen years ago, I walked away from the law firm treadmill, overhead, politics, billable hours, all of it, and went out on my own. I wanted to practice ERISA law in a way that actually added value, not just racked up hours....more

Morris, Manning & Martin, LLP

A Friendly DOL Amicus Brief on Forfeitures

On July 9th, the Secretary of Labor filed an amicus brief with the Ninth Circuit relating to the appeal of Hutchins v. HP, Inc. In that case, a participant claimed that forfeitures should have been used to offset plan...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The problem of free or cheap plan documents

As an ERISA attorney who drafts plan documents at a flat fee, my biggest competitors are not other ERISA attorneys, but third-party administration (TPA) firms. ...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Get those participation agreements done

It’s been happening a lot lately: a plan sponsor with several participating employers, not realizing that participation agreements for some of these employers weren’t done. This is just a silly mistake to make....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Get a scanner

Being a plan sponsor is a tough job and the amount of paperwork that goes with it can be overwhelming. The paperwork includes plan documents, summary plan descriptions, amendment, valuations, trusts statements, and payroll....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

You need to read the plan document

Being an ERISA attorney for a couple of third-party administration (TPA) firms when I first started helps you develop a sense of humor because there are too many people I was associated with who had absolutely zero training...more

Dentons

Retirement Plan Amendments During COVID-19

Dentons on

As employers consider the financial impact of COVID-19, some are considering eliminating employer contributions to 401(k) and 403(b) plans. Notice 2020-52 addresses many employer concerns regarding mid-year amendments to safe...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The problem with plan investments and audits

Retirement plans with more than 100 participants require a CPA audit for their Form 5500. However, small plans with less than 100 participants may sometimes require an audit. This often happens when more than 5% of the Plan’s...more

Burr & Forman

The Brave New World of Fiduciary Responsibility for Benefit Plans

Burr & Forman on

Most blog entries focus on new developments or recent legislation. This one’s a bit different. Its subject matter, fiduciary responsibility, is as old as ERISA itself. In today’s environment of increased litigation risks for...more

Holland & Hart - The Benefits Dial

I Want to Know, Have You Ever Seen…your plan documents?

Owners and employees of smaller organizations often find themselves stretched in many directions. With all of the demands on one’s time associated with operating a business, it is not uncommon to see attention to the...more

Seyfarth Shaw LLP

Beware of the “Overshare”: Construe Requests for ERISA Plan Documents Narrowly!

Seyfarth Shaw LLP on

Seyfarth Synopsis: Administrators of ERISA plans frequently receive requests from participants, beneficiaries, and their representatives for plan-related documents. A recent decision from the Court of Appeals for the Fifth...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Make sure clients check plan document vs. practice

I’ve spent 21 years as an ERISA attorney and took some classes when I was getting my LLM and I learn something new about retirement plans every day. As a financial advisor, you likely didn’t have the training to be an ERISA...more

Proskauer - Employee Benefits & Executive...

Best Practices in Administering Benefit Claims #1 – Know (and Read) Your Plan Document

Our ERISA Practice Center blog posts often discuss many complex, and sometimes esoteric, substantive and procedural ERISA issues, as well as related agency guidance and case law. In this new ten-part blog series, however, we...more

Pillsbury Winthrop Shaw Pittman LLP

A Ninth Circuit Ruling Repaves the Intersection of ERISA and Arbitration Law

Dorman v. The Charles Schwab Corp. narrows the options of employees asserting breach of fiduciary duty in retirement plans. Breach of fiduciary duty claims that “arise out of” and “relate to” a 401(k) plan—including those...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

What all good 401(k) plans have

There are so many articles for plan sponsors (I’ve written quite a few) where they go on and on about what plan sponsors need for a successful 401(k) plan. Rather than go into a whole diatribe, here is a Reader’s Digest of...more

Eversheds Sutherland (US) LLP

IRS formalizes and provides relief for section 403(b) “once-in-always-in” part-time rule – immediate action required

In Notice 2018-95, released on December 4, 2018, the Internal Revenue Service (IRS) formally announced a “once-in-always-in” interpretation of the section 403(b) participation exclusion for part-time employees and provided...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Keep it Simple, Stupid

When it comes to drafting plan documents, I always say K.I.S.S.: keep it simple, stupid....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Managing Your Plan is all about a process and not a result

We’ve been conditioned in life that everything is about results. I know from law school the hard way how much that first job relied so much on what grades I got. Businesses are so concerned with the bottom line and we know...more

BCLP

A Mistake a Day: Top 5 401(k) Compliance Mistakes & Best Practices

BCLP on

Mistakes are all too easy to make, but fortunately, they are also easy to prevent! This week, we are discussing the five most common compliance mistakes made by 401(k) plan administrators and fiduciaries, the potential...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Rosenbaum Law Firm Review - April 2018

Plan Sponsors Need To Fix Their Plan Errors Now! You can't wait, fix it now! For most of us, when we don't feel well, we go to the doctor. We don't wait until things get worse, we take care of things because there...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Read the plan document

Being an ERISA attorney for a couple of third party administration (TPA) firms when I first started helps you develop a sense of humor because there are too many people I was associated with who had absolutely zero training...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Rosenbaum Law Firm Review - June 2016

The New Fiduciary Rule: What It Means To Plan Sponsors - Bottom line: what does it mean? More than a dozen years ago, there was a medical report that dental plaque could cause heart disease. I thought it was some...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

No such thing as assembly line Retirement Plans

Henry T. Ford is considered the father or the pioneer of the modern day assembly line of manufacturing. His development of the Model T and its way of manufacturing is considered one of the great developments in 20th century...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Advisors Advantage - April 2016

The Struggles Of Being A Retirement Plan Provider And How To Manage It. What you have to deal with. Being a retirement plan provider is like any other business in the sense that it has to be managed in a way...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Rosenbaum Law Firm Review - March 2016

Things About Plan Providers That Shouldn't Impress Plan Sponsors. Don't get bamboozled. There are certain things in life we really should be impressed by, but we always end up being impressed by the wrong...more

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