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DOL Issues Guidance Implementing SECURE Act Changes to Defined Benefit Plan Annual Funding Notices

On April 3, 2025, the Department of Labor (DOL) issued Field Assistance Bulletin No. 2025-02 to assist defined benefit pension plan administrators with deciphering the requirements of the SECURE 2.0 Act of 2022 as to annual...more

IRS Gives Guidance on Student Loan Payment Matching Contributions

IRS Notice 2024-63, published Aug. 19, 2024, provides interim guidance for plan sponsors on the SECURE 2.0 Act provision permitting employers to offer matching contributions to their retirement plans — including 401(k) and...more

IRS Issues Interim Guidance Under Expanded EPCRS

Recently, the IRS released Notice 2023-43, providing interim guidance on Section 305 of the SECURE 2.0 Act of 2022, which expanded the Employee Plans Compliance Resolution System (EPCRS), the system through which plan...more

IRS Announces New Audit Program for Retirement Plans

On June 3, 2022, the IRS announced it is launching a pilot pre-examination retirement plan compliance program, which generally will be effective immediately (June 2022). This pilot program essentially gives plan sponsors a...more

Updated IRS Correction Principles and Changes to Voluntary Correction Program

The IRS recently issued Revenue Procedure 2021-30 (2021 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) — the system through which plan sponsors can correct errors in the form and...more

COVID-19 and Employee Benefits #5: IRS Allows Midyear Safe Harbor Retirement Contribution Changes

The IRS recently issued Notice 2020-52 providing flexibility to employers wishing to reduce or suspend safe harbor contributions to safe harbor 401(k), 401(m) and 403(b) plans in light of the economic and business challenges...more

IRS Updates Correction Program for Retirement Plans

The IRS recently issued Revenue Procedure 2019-19 (the 2019 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) – the system through which plan sponsors can correct errors in the form...more

IRS Proposes Changes to Hardship Distribution Regulations

Earlier this month, the IRS proposed changes to existing rules governing distributions from 401(k) and 403(b) plans on account of certain financial hardships. The proposed regulations reflect several statutory changes enacted...more

IRS Updates Retirement Plan Correction Program

The Internal Revenue Service recently issued Revenue Procedure 2018-52 (the 2018 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) — the system through which plan sponsors can...more

DOL Proposes 18-Month Fiduciary Rule Delay; Issues New Guidance

Last week, the Department of Labor (DOL) announced additional delays to major aspects of its fiduciary rule by proposing to extend certain transition period deadlines and applicability dates by 18 months. If finalized, full...more

Labor Department’s Fiduciary Rule Impacts Investment Managers

The fiduciary rule issued by the Department of Labor (DOL) is one of the major developments in employee benefits law in recent years. The rule aims to reduce and regulate conflicts of interest related to paid investment...more

DOL Finalizes 60-Day Delay of Fiduciary Rule Applicability

On April 7, the Department of Labor (DOL) formally adopted its previously proposed 60-day delay of the applicability date of its fiduciary conflict-of-interest rule and related prohibited transaction exemptions (PTEs). The...more

IRS Issues Substantiation Guidelines for Safe-Harbor Hardship Withdrawals

Earlier this year, the IRS issued a memorandum setting forth substantiation guidelines for IRS auditors examining whether a 401(k) plan hardship distribution is “deemed to be on account of an immediate and heavy financial...more

DOL Issues First Wave of Fiduciary Rule Guidance

Last week, the U.S. Department of Labor (DOL) issued long-awaited guidance in the form of answers to 34 frequently asked questions (the FAQs) on its final rule (the Rule) for determining when a party is a fiduciary, by virtue...more

IRS Updates Correction Program for Retirement Plans

The IRS recently issued Revenue Procedure 2016-51 (the 2016 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) – the system through which plan sponsors can correct errors in the form...more

DOL Delivers Final Fiduciary Investment Advice Rule

Last week, the U.S. Department of Labor (DOL) issued a final rule revamping the standards for determining when a party is a fiduciary with respect to an ERISA retirement plan or an individual retirement account (IRA) by...more

Central States Pension Fund Submits Plan for Reducing Benefits

On Sept. 25, 2015, the Central States, Southeast and Southwest Areas Pension Plan (Central States), submitted to the Department of the Treasury a plan for reducing benefits under the Multiemployer Pension Reform Act of 2014...more

The DOL’s New Proposal on ERISA Fiduciary Status for Investment Advisers

Last week, the U.S. Department of Labor (DOL) issued its widely anticipated re-proposed rules for defining fiduciary status under the Employee Retirement Income Security Act of 1974 (ERISA) for providers of investment advice...more

IRS Provides New Flexibility to Correct Retirement Plan Errors

The IRS recently issued important updates to its Employee Plans Compliance Resolution System (EPCRS). The updates are contained in Revenue Procedures 2015-27 and 2015-28. ...more

Patent Infringement Lawsuit Reminds ERISA Fiduciaries to Monitor Service Providers

In August 2014, GRQ Investment Management, LLC (GRQ) sued Financial Engines, Inc. and Financial Engines Advisors, LLC (collectively, Financial Engines), alleging that Financial Engines’ sale of account management and advisory...more

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