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Retirement Plans
Department of Labor proposes guidance on participant advice
The Department of Labor recently released a proposed regulation implementing the statutory exemption under the Pension Protection Act (PPA) for the provision of investment advice to participants in participant-directed individual account plans (such as 401(k) plans). Additionally they’ve released a proposed class exemption, expanding the statutory exemption in two respects. In this article we review the proposed regulation and (briefly and in passing) the class exemption, focusing on the key issues for plan sponsors.
Options for transitioning to PPA lump sums
The Pension Protection Act of 2006 (PPA) changed the minimum basis for calculating lump sums. IRS Notice 2008-30, issued in March 2008, provides helpful guidance for transitioning from “old law lump sums” to “PPA lump sums.” In this article, we explore the paths a plan sponsor may take as they transition to the new “PPA lump sums.”
Senator Obama's pension proposals
Senator Barack Obama (D-IL) has made a number of (relatively) concrete pension reform proposals. In this article we evaluate them. Our focus in this article is on Senator Obama's proposals that will affect private pension plans. Thus, we will not be addressing, for example, Senator Obama's Social Security proposals. With respect to private pension policy, we identify three major Obama-supported initiatives.
What pension policy issues are at stake this November?
As the 2008 presidential election draws near, in this article we discuss the major pension policy issues that will confront Congress and the next president, observing, where the issues may become polarizing, how Democrats and Republicans may line up.
IRS rules on frozen plan buyouts
On August 6, 2008, the IRS published Revenue Ruling (RR) 2008-45, holding that, under current rules, frozen pension plan “buyouts” would generally violate the Internal Revenue Code's “exclusive benefit” rule. In connection with the ruling, the Bush administration also published a press release subtitled "Agencies Offer Framework for Possible Legislative Change," which outlines rules the administration believes should be part of any legislation that would allow for the transfer of frozen pension plans. In this article, we review the ruling and the "Framework" and then discuss some of the policy issues at stake.
HEART Act provides special benefits for active duty military
On June 17, President Bush signed into law the Heroes Earnings Assistance and Relief Tax Act (HEART Act) of 2008. This bill, originally passed in a nearly unprecedented 410-0 vote by the US House of Representatives, provides certain qualified plan and other tax benefits for members of the military on active duty (or who become disabled or die while on active duty). In this article, we’ll discuss briefly the benefit plan issues raised by the HEART Act.
DOL proposes sponsor-participant disclosure regulations
On July 22, 2008, the DOL released proposed regulations under section 404(a) of ERISA revising the rules for disclosure of fee and other information to participants in directed individual account plans – plans in which participants choose from a menu of investment funds. The proposal requires disclosure of "plan-related" and "investment-related" information. In this article we review the proposal and its implications for plan administrators.
DOL publishes further guidance on 5500 fee reporting rules
In 2007, the DOL finalized a new Form 5500 Schedule C (Service Provider Information), adding a requirement for detailed disclosure of fees paid directly or indirectly to plan service providers. The new requirements would generally be effective for the 2009 reporting year. On July 14, 2008, the DOL published "FAQs [frequently asked questions] About The 2009 Form 5500 Schedule C," providing further guidance on how Form 5500 fee reporting is to work. In this article we review the FAQ guidance.
Managing PPA DB contributions and the September 15, 2008 due date
It’s the summer of 2008 and defined benefit plan sponsors have unique opportunities with regard to funding their plans. Have you thought about this? Do you know what you can accomplish by funding before September 15 has come and gone?
This article should have relevance to anyone involved in financial decisions around pensions, no matter what their specific role. In the article, we’ll review those opportunities in a way that should be relevant to you whether your plan is well-funded or not as well-funded, whether you have lots of cash available or not as much cash available. And, we’ll discuss why, as a result of the Pension Protection Act of 2006 (PPA), this may be the best opportunity you’ll ever have.
Financial reporting of pension and postretirement benefit plan assets
In March, the Financial Accounting Standards Board (FASB) proposed a FASB Staff Position that would amend FASB Statement No. 132(R), Employers’ Disclosures about Pensions and Other Postretirement Benefits. In this article we review the proposal and discuss the issue of alternative asset valuation generally, with respect to both DB and DC plans.
The next 401(k) policy initiative: adequacy
The Government Accountability Office released a report titled "Private Pensions – Low Defined Contribution Plan Savings May Pose Challenges to Retirement Security, Especially for Many Low-Income Workers." In this article we review the GAO report and various policy initiatives being considered to improve 401(k) plan "adequacy."
"Greater of" formulas and the IRS backloading position
In September 2007 we discussed the Wheeler v. Boeing decision, in which a federal district court rejected the IRS's application of defined benefit plan “backloading” or accrual rules to a "greater of" formula in a cash balance plan conversion. Since then, the IRS issued Revenue Ruling 2008-7 and has now proposed regulations providing relief from the application of its anti-backloading analysis in the case of multiple formulas.
PPA funding targets
The JPMorgan PPA funding target exhibit describes in detail the calculation and application of the various PPA funding targets.
Getting plan terminations right
If a sponsor is no longer committed to the defined benefit (DB) system, if a decision has already been made to freeze or terminate the DB plan, what is the best way to wind things up? That issue – of DB "exit strategy" – is more complicated than it sounds. In this article we review the exit strategy process and considerations plan sponsors should be aware of.
PBGC premiums after PPA
PPA not only overhauled the funding rules for DB plans, but also changed the way premiums are assessed for the mandatory benefit guaranty insurance coverage provided by the PBGC. In this article, we discuss the changes to the premium calculations and touch on funding strategies to minimize these premiums.
Current pension legislative and regulatory outlook
In this article we survey current pension policy initiatives both in Congress and in the government agencies.
401(k) fee bill reported out of Education and Labor Committee
The House Committee on Education and Labor recently approved a revised 401(k) Fair Disclosure for Retirement Security Act (H.R. 3185). The new bill is substantially different from the one originally introduced and represents a compromise with critics of the earlier bill's detailed disclosure requirements. In this article, we review the bill, primarily focusing on the language in the revised bill.
Getting PPA funding right
The Pension Protection Act (PPA) requires a fundamental change in how sponsors think about pension funding. In this article, we discuss the new strategies that apply under PPA. We identify the key issues you should consider when you approach the PPA funding challenge.
Quarterly contribution requirements and credit balances
In this article, we review the IRS quarterly contribution proposal, focusing on the effect of credit balances on the obligation to make quarterly contributions and the use of credit balances to satisfy them. Critically, we address 2008 compliance issues, which, with respect to quarterly contributions, are particularly difficult.
DOL proposes new FMLA regulations
On February 12, the Department of Labor (DOL) proposed the first new regulations under the Family and Medical Leave Act of 1993 (FMLA) since 1995. In this article, we’ll discuss many of the key FMLA issues, trying to focus somewhat equally on what the proposed regulations tell us, what’s different in the proposed regulations, and what guidance is still needed.
Calculating lump sums after PPA
This article examines the changes ushered in by the Pension Protection Act of 2006 (PPA) affecting virtually all aspects of employer-sponsored pension plans.
A review of current 401(k) plan fee legislation and regulation
At least three bills related to 401(k) plan fees have been introduced in Congress, and the Department of Labor (DOL) is about halfway through its three-part regulatory initiative concerning fees. In this article, we review, generally, where these legislative and regulatory initiatives stand.
PPA check up
In this article, we review strategic decisions confronting, and critical choices available to, plan sponsors in complying with new PPA rules generally and the benefit restriction certification requirements specifically.
PBGC proposes rules for 4010 reporting for underfunded DB plans
This article briefly reviews the new 4010 reporting requirements and the PBGC's proposed regulations.
Supreme Court holds that DC participant may sue for fiduciary failure to follow instructions
In this article we review the Supreme Court ruling on the LaRue v. DeWolfe decision and briefly consider its implications for plan investment administration in 401(k) and similar defined contribution plans.
Sharpening your aim: selecting the best target date strategy for your participants
This is a summary of Sharpening your aim: selecting the best target date strategy for your participants prepared by Anne Lester and Katherine Santiago of JPMorgan Asset Management.
PPA Effective Dates
We examine the IRS issued Notice 2008-21 revising the effective date rules for PPA funding-related regulations.
IRS Proposes Cash Balance Regulations
At the end of last year, the IRS published regulations under the cash balance provisions of the Pension Protection Act (PPA). The proposal provides guidance on the PPA cash balance plan vesting requirement, age discrimination "safe harbor," conversion protection and permitted interest crediting rates. In this article, we review the proposal.
IRS Provides Long-Awaited Guidance on Backloading Rules
Here we'll examine the Revenue Ruling 2008-7 published February 1, by the IRS. It provides long-awaited guidance on the so-called “backloading” or accrual rules for defined benefit pension plans with multiple formulas.
DOL Proposes Fee Disclosure Rules
The Department of Labor recently proposed regulations under section 408(b)(2) of the Employee Retirement Income Security Act -- ERISA's "service provider exemption" -- requiring extensive provider-to-sponsor fee disclosure. In this article we review the proposal in detail with a focus on defined contribution plan fees.
Preparing for 2008 – IRS Proposes “Final” Funding Rules
At the end of 2007, the IRS published proposed regulations under the defined benefit funding provisions of PPA. Here, we review the proposal and focus on its implications to two key PPA funding issues -- the valuation of assets and the at-risk rules for 2008.
PPA...Ready or Not
In this article, we review the single-employer funding rules under PPA, reflecting regulatory guidance through December 2007. This article does not cover special issues for hybrid plans, however we plan to provide an article focusing on hybrid plan funding issues in our next publication.
Preparing for 2008 -- IRS Corrects Rules for 2008 Benefit Restriction Presumptions
The IRS has published a corrected proposal relating to the application of presumptions to the 2008 year. In this article, as we understand it, and based on the IRS's correction, is how the presumptions apply for 2008.
Final Revised Form 5500 -- New Fee Reporting Rules
The Department of Labor published final revisions to Form 5500 for 2009, part one of a three-part DOL project on defined contribution plan fees. This article reviews new reporting requirements for Schedule C, with respect to DC plans.
How Does Your Pension Plan Measure Up? A Framework for Assessing and Improving Your Plan’s Competitive Risk Profile
This is a summary of How Does Your Pension Plan Measure Up? A Framework for Assessing and Improving Your Plan’s Competitive Risk Profile prepared by Abdullah Z. Sheikh of JPMorgan Asset Management.
IRS Publishes Lump Sum Guidance
The IRS recently provided guidance concerning the calculation of lump sums in defined benefit plans. Additionally, separate guidance was released regarding "204(h) notice" requirements. Here we review the guidance and discuss its implications.
Pension Extension: FAQS on Strategies for Extending Duration
This is a summary of Pension Extension: FAQs on Strategies for Extending Duration White Paper prepared by Bill McHugh of JPMorgan Asset Management.
IRS Proposes 401(k) Automatic Enrollment Regulations
The IRS recently released proposed 401(k) automatic enrollment regulations that cover two major changes to 401(k) rules made by the PPA. It also includes rules implementing certain other 401(k)-related PPA provisions. Here, we review the proposal.
Picking the Yield Curve
The IRS recently provided guidance on the calculation of the yield curve, together with numbers for August - October, 2007. In this article, we analyze the advantages and disadvantages of various yield curve "versions."
Preparing for 2008 -- DB Funding under PPA
In this article, we review generally the challenges PPA compliance presents for plan sponsors, discuss what guidance has been published and, critically, what guidance has not been published, and then briefly review some strategic considerations.
DOL Finalizes Default Investment Rules
On October 24, 2007, the Department of Labor (DOL) published final qualified default investment alternative (QDIA) regulations. Here, we provide an overview of the key items and examine the regulation in detail.
2008 IRS Benefit Limits, Social Security Increases Now Available
We have calculated 2008 IRS limits on qualified retirement plan benefits and the PBGC maximum guaranteed benefit.
Solving the Longevity Risk Problem
In this article, we discuss the issue of longevity risk as it is related to retirement plans. We review several proposals made to address the issues and problems of longevity risk in relation to both defined benefit and defined contribution plans.
Could Data Genealogy Unlock Your Data Puzzle?
In this article, we review the reasons administrators need to maintain quality data, and introduce the concept of data genealogy. We also examine how developing a data genealogy can produce time and cost savings for plan administrators.
Federal Court Dismisses Backloading Claim
In this article, we examine the court ruling in the case of Wheeler v. Boeing relating to cash balance plan issues. Particularly, determining if Boeing violated ERISA backloading rules by following PPA grandfather provisions to attain qualified status.
A Symposium on Pension Finance
In this article, we eavesdrop on a ficitional dialogue amongst colleagues regarding pension plan assets and financing. Follow along, as our ficitional characters weigh different factors in regards to funding pension obligation liabilities.
Preparing for 2008 -- PPA Rules Affecting DB Lump Sums
In this article, we review the key PPA changes affecting DB lump sum payments, the areas where guidance is needed, and some strategies sponsors may want to consider in preparing for 2008.
Preparing for 2008 -- IRS Proposes PPA Benefit Restriction Rules
On August 28, 2007, IRS proposed regulations detailing the application of the PPA benefit restrictions to underfunded plans. Here, we review the proposed regulations and their implications.
Workforce Strategies: A Case Study in Workforce Planning
In Part 2 of this continuing series on workforce strategies, we examine the need for workforce planning. We discuss the steps it involves and how it will help our ficitonal company, Big Wheels, to operate more efficiently.
Ready! Fire! Aim?
This is an executive summary of the Ready! Fire! Aim? White Paper prepared by Anne Lester and Katherine Santiago of JPMorgan Asset Management.
Stable Value Funds: Looking Good... or Overlooked?
Given the increased attention placed on the nation’s broader retirement challenges, the time is overdue to examine the procedures plan fiduciaries use in evaluating their stable value fund options. Here, we review this evaluation process.
Defendant Sponsor Wins First Round in Fee Litigation
On June 21, 2007, the US District Court for the Western District of Wisconsin handed down a decision in Hecker v. Deere, dismissing participants' complaint alleging that the sponsor's 401(k) fee arrangements violated ERISA. Here, we discuss the decision.
IRS Publishes Proposed PPA Mortality Regulations
The IRS recently published proposed regulations under the PPA on the use of mortality in determining defined benefit plan liabilities and funding requirements. Here, we review the proposal, focusing on key issues for plan sponsors.
Developing a Workforce Strategy: Introducing a Three-Phased Framework
In this article, the first of a series, we illustrate why employers need a workforce strategy and focus on the first phase of developing one - workforce analysis.
Final Roth 401(k) Regulations Published
The IRS recently published final regulations under IRC Section 402A on the taxation of Roth 401(k) distributions. These can present difficult and technical issues for sponsors, administrators and participants. Here, we'll discuss those issues in detail.
Current Pension Regulatory Outlook - 401(k) Plan Fees
In this article, we briefly review several recent developments relating to various regulatory and legislative initiatives concerning 401(k) plan fees.
Defined Benefit Funding -- Preparing for 2008, Part 2
In the second of this two-part series focusing on funding issues under the PPA, we take a look at three issues that key off of funded status but do not necessarily affect the amount of the sponsor's plan contribution.
PPA and 2007 Pension Funding: What in the World Are We Waiting For?
In this article, we look at the issues arising in regards to pension funding under the PPA. Specifically we examine the uncertainty surrounding the Funding Attainment Percentage (FTAP) for plan years.
Choosing Between (Traditional) DB and DC -- Decision Points
In this article, we examine the key decision points that should be addressed in considering which type of retirement benefit is right for your company.
Defined Benefit Funding -- Preparing for 2008, Part 1
In this two-part series, we take a look at the 2007/2008 DB funding issues and address areas of uncertainty and significant concern. In Part 1 we look at issues that bear directly on funding.
Recent Cash Balance Plan Developments
In December, the IRS provided guidance on the appliication of new Pension Protection Act cash balance rules. In this article, we review IRS Notice 2007-6 and review the state of cash balance plan litigation in the United States.
DOL Mandates Electronic Filing for the 2008 Form 5500 and Proposes New Disclosures
The DOL, IRS and PBGC have proposed revisions to the Form 5500. Additionally, the DOL has made e-filing for 2008 plan years mandatory. In this article, we review the proposed revisions along with looking at the implications of mandatory e-filing.
Questions from our Readers: January 2007
In this regular monthly feature, we provide answers to reader questions we think may have broader appeal and serve to enlighten our growing Insight community.
Implementing FAS 158 for Year-End Financial Reporting
In September, FASB issued FAS 158. This statement requires companies to report the funded status of their defined benefit and other postretirement plans. Here, we review this change and its effect on the balance sheet.
IRS Issues "Grab-Bag" of Guidance on PPA Distribution Issues
The IRS released Notice 2007-7 on January 10, 2007 featuring guidance generally related to distribution issues presented by the Pension Protection Act of 2006. Here, we focus on some of the issues affected by the notice.
IRS Releases Company Stock Diversification Notice
On November 30, 2006, the IRS released Notice 2006-107 to provide transition guidance on the company stock diversification requirements of the Pension Protection Act. Here we provide a comprehensive overview of this notice.
Questions from our Readers: December 2006
In this regular monthly feature, we provide answers to reader questions we think may have broader appeal and serve to enlighten our growing Insight community.
Current Pension Legislative Update
With Democrats taking control of both the House and the Senate, leadership of Congressional committees will change. Here we review the implications of these changes.
Lump Sums under the Pension Protection Act of 2006
In response to an article in the Wall Street Journal on October 25, we provide a detailed discussion and analysis of changes in lump sum benefits under PPA.
Questions from our Readers: November 2006
In the first of this monthly feature, we provide answers to reader questions we think may have broader appeal and serve to enlighten our growing Insight community.
PPA and 2007 Pension Funding: What in the World Are We Waiting For?
There is no doubt that PPA has removed significant legislative uncertainty around pension funding rules. But there are lots of details. Here we discuss many unresolved issues related to near-term funding decisions.
2007 IRS Benefit Limits, Social Security Increases Now Available
Today the Bureau of Labor Statistics released the September inflation figures and the Social Security Administration released the 2007 benefit and wage amounts. Here we calculate 2007 IRS benefit limits and the PBGC maximum guaranteed benefit.
DOL Fee Project Part 1 -- Revised Form 5500 Proposed
The DOL has proposed revisions to the Form 5500 (Annual Report). Here we review the changes to the Schedule C "Service Provider Information."
DOL Proposes Default Investment Rules
The PPA instructed the DOL to publish regulations making it clear that the use of certain kinds of funds that include capital appreciation as a default is not imprudent. In this article, we review the DOL proposal.
Sweeping PPA changes -- What to Focus on Now
We have published several articles detailing the specifics of changes made by the Pension Protection Act (PPA). In this article we want to attempt some preliminary sorting -- which issues presented by the new law require urgent attention?
Decision in the IBM Cash Balance Litigation
In light of the Seventh Circuit's decision in Cooper vs. IBM, we review the age discrimination challenge to cash balance plans and how other courts have ruled. We also discuss where cash balance litigation may be headed next.
PPA 2006 -- Plan Distribution Provisions
The Pension Protection Act of 2006 made some subtle, but meaningful changes related to distributions from qualified plans. Here we discuss the primary changes.
PPA 2006 -- Defined Contribution Provisions
While the Pension Protection Act of 2006 (PPA) began life as defined benefit funding reform legislation, along the way it picked up a number of provisions that address defined contribution plan issues. In this article we're going to review key PPA provisions applicable to single employer DC plans.
PPA 2006 -- Pension Funding Provisions
The Pension Protection Act of 2006 (PPA) provides for a comprehensive overhaul of the defined benefit plan funding rules under ERISA and the Tax Code. In this article, we review PPA changes to the pension funding for single employer plans, in summary form, provide an analysis of the major changes and the details of some of the more complicated changes.
PPA 2006 -- Hybrid/Cash Balance Provisions
The Pension Protection Act of 2006 (PPA) includes a number of provisions applicable to "hybrid" plans (including cash balance plans). In this article we begin with review of PPA changes to hybrid/cash balance plan rules in summary form and follow with a detailed analysis of the issues hybrid/cash balance plans have presented and what PPA does about them.
PPA 2006 -- Reporting and Disclosure Provisions
New government reporting and participant disclosure rules under the Pension Protection Act of 2006 (PPA) will be of immediate interest to sponsors and administrators. In this article we review new reporting and/or disclosure requirements under PPA applicable to single employer plans.
Legislative Outlook -- Signs of Progress in the Conference
Legislators are hopeful that they can pull together a defined benefit funding reform package before the August recess. Here we review, briefly, where we understand the conferees are on key issues.
Employee Benefits Security Administration Releases 2006 Form 5500
On July 13, the Employee Benefits Security Administration (EBSA) released advance copies of the 2006 Form 5500 Annual Report and instructions. Here we review the key changes.
Employee Benefit Plans Form 5500 - Are You In Compliance?
Many companies are unaware of the Form 5500 filing requirements for their employee benefit plans. Here we review the Form 5500, who has to file it and why.
CCA Strategies Offers Compelling Compromise for FASB Consideration
In this article, we offer an approach that balances FASB's short-term objective with the primary concerns raised about its two-step approach to comprehensive reform.
401(k) Plans and Fees
With increasing attention to 401(k) plans as the retirement "benefit of the future," both Congress and regulators are considering initiatives to somehow "get at the fee issue." In this article, we're going to review a couple of those initiatives.
Emerging DC Issues
Policymakers generally believe this is a post-DB era. Therefore, we can expect an increased focus on DC plan issues. Here we begin with a general review of the issues presented by the (perceived) shift from traditional DB to DC plans.
Employee Plans Compliance Resolution System (EPCRS) Updated and Expanded
Here, we review the changes made by the IRS to the Employee Plans Compliance Resolution (EPCRS), the voluntary correction program for retirement plans.
Cash Balance Litigation
In this article, we review the age discrimination challenge to cash balance plans and how the courts have responded.
Legislative Outlook -- Update on Conference Progress
In this article, we're going to review briefly where, as we understand it, the pension bill conferees are on key issues.
Optional Forms of Payment, Wearaway and Cash Balance Plans
Here we review three key interrelated issues: the technical issues in the recent optional form disclosure regulations, Congress's current struggle to agree on how to handle cash balance plans and litigation over cash balance plan legality.
Changes to the Department of Labor's Voluntary Fiduciary Correction Program
The newly updated VFCP simplifies the correction process that was last revised in 2005 and creates an option that allows for corrections without the plan sponsor having to reverse certain transactions.
Commentary: DB plans -- Dead or Alive?
In this commentary, we discuss DB plans and what the future has in store.
2005 Plan Year Form 5500 Filing Requirements for Pension and Welfare Benefit Plans
Each year, pension and welfare benefit plans are required to file an annual return/report (Form 5500) regarding their financial condition, investments, and operations. This article discusses the changes to the 2005 Form 5500.
IRS Provides More "Final" Guidance on Relative Value Disclosure
On March 24, 2006 IRS published final regulations updating previously finalized relative value regulations. In this article, we've tried to provide enough detail to permit you to understand what the IRS is doing in the 2006 final regulations.
Legislative Outlook -- Conference Progress
Pension funding reform legislation appears to have three big issues requiring resolution -- credit condition, cash balance plans and advice. Here we review each of these issues.
Will Pension Administrators Sink or Swim? Preparing to Face the Demographic Wave Ahead
DB plan administration may be higher profile than ever before. Here we review a number of factors creating challenges for the future of administration.
Comparison of Cash Balance Provisions of House and Senate Bills
In this chart we provide a side-by-side comparison of House and Senate bills on cash balance provisions.
Current Pension Legislative Outlook -- March 6, 2006
DB funding legislation will likely pass this spring. Before then, the House and Sentate bills will be conferenced. Here we review conference attendees, politics and prospects, outstanding issues and the treatment of cash balance plans.
Comparison of Pension Funding and PBGC Provisions of House and Senate Bills
In this chart we provide a side-by-side comparison of House and Senate bills on pension funding and PBGC provisions.
Roth 401(k)s -- IRS Proposes Distribution Rules
Distributions from Roth 401(k)s present a number of difficult and highly technical issues for sponsors, administrators and participants. In this article, we go into more detail on how the recent IRS proposal addresses these issues.
Administering Pension Plans: Freeze 'Em and Forget 'Em is Not a Practical Strategy
In this article we provide an overview of the two distinct types of plan freezes and their implications for plan administrators. We also include a checklist of the steps employers must take in order to effectively support a frozen pension plan.
Legislative Outlook -- $30 PBGC Premium Likely; Boehner New House Majority Leader
Here we review two recent actions taken by the House that willl affect pension policy.
CCA Editorial: Living with the Cash Balance Burden -- Time to Act?
In the wake of the IBM ruling, cash balance plan sponsors are in a state of limbo and potential legal risk. This editorial puts the risk in proper perspective, and offers options moving forward.
Roth 401(k)s -- How They Work
IRS recently published final regulations implementing Roth 401(k)s and providing guidance on certain recordkeeping and administrative issues. Here we review, briefly, the basics of Roth 401(k)s and the regulation.
Happy New Year Administrators: What to Expect in 2006
There is significant coverage of pension plan design, funding and strategy but little talk about the resulting administration impact that results from new social policy decisions. This article overviews the new complexities facing administrators.
2006 Pension Policy Agenda
In this article we review the pension policy agenda (as of January) for 2006, much of which is leftover from 2005 (or 2004).
IRS Acknowledges Delay in Finalization of Relative Value Regulations
According to the IRS Winter 2006 Employee Plan News periodical, finalization of the "relative value" regulations will not be completed in time for the February 1, 2006 effective date.
Current Legislative Outlook: December 2005
Here we review the PBGC premium provisions in the budget bill and House DB reform bill. We've also included an updated comparison of the House and Senate DB reform proposals. Finally, we'll briefly discuss the outlook for passage of a final final bill.
Defined Contribution Proposals Included In Defined Benefit Legislation
In this article, we review the defined contribution legislative initiatives included in Senate and House DB reform proposals. Many of these DC proposals enjoy broad support and may find their way into a final DB funding bill or other legislation.
2005 "To Do" List Under Code Section 409A
This article highlights some key "to-do's" between now and the end of the year under Code Section 409A. We will focus on account balance plans, non-account balance plans, and separation pay plans.
FASB's November 10th Meeting: Fair Value Accounting for Pension and OPRB Plans
In this article we review the balance sheet issues related to pensions and OPRBs as well as the income statement issues under this new FASB project.
Current Legislative Outlook, November 2005
After more than two years of proposals and negotiations over DB funding reform and the current temporary "fix" set to expire at year end, what is Congress going to do? In this article we review year end alternative solutions to the DB funding "crisis."
2006 IRS Benefit Limits, Social Security Increases Now Available
Here, we overview the 2006 increases for Social Security benefits and IRS benefit limits for retirement plans.
Proposed Deferred Compensation (409A) Regulations -- Focus On SERPs
On October 4, 2005, Treasury published proposed regulations under Tax Code section 409A, relating to the taxation of nonqualified deferred compensation. In this article, we are going to focus on issues relating to retirement plans.
Funding Reform: Status of Cash Balance Provisions
While it appears that there's no logical necessity for Congress to address cash balance plans at the same time it reforms DB funding, it's beginning to look inevitable that it will. Here we review current proposals to "fix" or reform cash balance plans.