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On April 3, 2025, the Department of Labor issued Field Assistance Bulletin No. 2025-02 (the FAB), providing initial guidance and updated models for defined benefit plan Annual Funding Notices that comply with the notice...more
The SECURE Act 2.0, enacted in December 2022, made several updates to what must be included in annual funding notices (“AFN”) issued by defined benefit pension plans. For large plans (as defined below) with a plan year ending...more
The Department of Labor (DOL) issued guidance earlier this month that will affect defined benefit plans’ annual funding notices. The annual funding notice requirements were amended by SECURE 2.0 and are effective for plan...more
Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more
On April 3, 2025, the U.S. Department of Labor (DOL) issued important new guidance for employers that sponsor defined benefit (pension) plans. This guidance provides new model notices and addresses several outstanding...more
On April 3, 2025, the Department of Labor (“DOL”) issued Field Assistance Bulletin 2025-02 (the “Bulletin”), which provides guidance related to certain modifications made by the SECURE 2.0 Act of 2022 (“SECURE 2.0”) to the...more
On April 3, 2025, the US Department of Labor (“DOL”) released Field Assistance Bulletin No. 2025-02 (“FAB 2025-02”), which provides guidance regarding new content requirements that apply to pension plans’ annual funding...more
Following up on our recent blog post, SECURE 2.0’s Required Changes to Annual Funding Notice Become Effective in 2025, the Department of Labor released Field Assistance Bulletin 2025-02 on April 3, which addresses compliance...more
On April 3, 2025, the Department of Labor (DOL) issued guidance on the Annual Funding Notice changes made by the SECURE Act 2.0 and provided model notices. Pension plan administrators should review and revise their annual...more
The IRS recently issued Notice 2024-73, which provides much-needed guidance on long-term, part-time (“LTPT”) employees in ERISA-governed 403(b) retirement plans. Following passage of the SECURE 2.0 Act, an employee is...more
Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by...more
The retirement plan industry has been wrestling with the changes to required minimum distribution (RMD) provisions made by the SECURE Act and SECURE 2.0. One issue in particular has caused considerable confusion....more
While the sweltering roil of temporary regulatory changes related to the COVID-19 pandemic may have cooled and the initial burst of SECURE 2.0 steam begins to dissipate, sponsors of employee benefit plans should keep their...more
The Internal Revenue Service (IRS) gave plan sponsors an early Christmas gift with the release of new guidance late last year addressing several key provisions contained in SECURE 2.0. A welcome portion of the notice was...more
The IRS recently issued Notice 2024-2, which provides Q&A guidance on many provisions of the SECURE 2.0 Act, which had left employers and practitioners asking questions. We previously summarized several of the key changes...more
The IRS released long-awaited guidance under the SECURE 2.0 Act on December 20, 2023. Notice 2024-2 (Notice) provides clarification of various provisions, including several optional features that plan sponsors have been...more
On December 20, 2023, the IRS issued Notice 2024-2, which provides question-and-answer guidance on various aspects of the SECURE 2.0 Act. This post focuses on the “de minimis financial incentives” under SECURE 2.0 Act Section...more
Together, the SECURE Act and the SECURE 2.0 Act feature numerous changes to retirement plan rules that aim to help employees achieve retirement security by ensuring that more workers have access to retirement plans, can save...more
The Setting Every Community Up for Retirement Act (the “SECURE Act”), passed at the end of 2019, adds a participant disclosure requirement that addresses a long-held concern of lawmakers that many participants are not...more
The IRS recently issued guidance on the utility of and weight to be afforded informal “frequently asked questions” (FAQs) published on its website—clarifications that became necessary given the IRS’s heavy reliance on FAQs as...more
The Internal Revenue Service (IRS) recently issued practical and helpful guidance in a question-and-answer format for tax-qualified retirement plans and for an Individual Retirement Arrangement (IRA), regarding the...more
IRS Notice 2020-51, released last week, provides additional guidance on the waiver in 2020 of required minimum distributions (RMDs) from defined contribution retirement plans and IRAs, and the interaction of this waiver with...more
The Coronavirus Aid, Relief And Economic Security (CARES) Act and the Setting Every Community Up for Retirement Enhancement (SECURE) Act both made changes to required minimum distribution rules. The SECURE Act changes the age...more