PODCAST: Williams Mullen's Benefits Companion - Can Employers Impose a Health Insurance Surcharge on Plan Participants Not Vaccinated for COVID-19?
SECURE 2.0 provided employees better access to liquid assets during a major life crisis. We have previously discussed the domestic abuse victim distribution exemption and the emergency personal expense distribution exemption...more
To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article includes some tips for drafting a best-in- class...more
Cryptocurrencies and digital assets—such as bitcoin, ether and non-fungible tokens (NFTs)—have become some of the hottest investment products in recent years. The growing interest has inevitably led to retirement plan...more
On July 16, 2021 the IRS issued Revenue Procedure 2021-30, which modifies and supersedes Revenue Procedure 2019-19, expanding the Employee Plans Compliance Resolution System (“EPCRS”). EPCRS is a program for correcting...more
As previewed in our prior blog post, the recently enacted SECURE Act includes many changes that affect employer-sponsored benefit plans and require the attention of plan administrators. Among these changes, effective for...more
A financial advisor called me and asked me if there was a problem that an insurance policy paid by a 401(k) plan had the policy in the name of the participant. Considering it was a plan asset, I thought so. If the participant...more
....One More Thing For Plan Providers, Some points to ponder. When Steve Jobs would lead an Apple press conference, he would always end it with "one more thing," which was an important announcement of a new Apple product....more
Health and Welfare Plan Update - It is 9:00 p.m., do you know where your health plan data is? As IT systems continue to expand, and data is accessed, moved and stored in many new and different ways, the Office for Civil...more
The IRS released a private letter ruling on August 17, 2018, in which it approved a student loan repayment benefit that was connected to an employer’s contributions to its 401(k) plan. Though the IRS’s ruling applies only to...more
The Internal Revenue Service (IRS) issued a private letter ruling which allowed an unnamed employer (some say it’s pharmaceutical giant Abbott) to make 401(k) contributions to participants who are repaying their student...more
In Teufel v. Northern Trust Co. (April 11, 2018), the US Court of Appeals for the Seventh Circuit confirmed that a prospective change in the benefit formula for a defined benefit pension plan constituted neither an...more
Since at least 2010, the IRS has publicly stated that forfeitures must be used by the end of the plan year in which the forfeiture occurred, or as soon as possible thereafter. Some IRS pre-approved prototype or volume...more
Mid-year changes to safe harbor 401(k) plans have long been thought to be available in only very limited circumstances. However, the IRS recently released guidance in Notice 2016-16 that significantly increases the scope of...more