Compliance June 23, 2015

IRS Publishes Information for Cycle E Plan Restatements

The information includes worksheets and explanations for the second Cycle E plan language, and explanations of the determination letter review process.
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The Internal Revenue Service (IRS) has released subject matter packages that Employee Plans Specialists use when reviewing retirement plan documents.

Plan sponsors can also use these packages as a review tool before submitting a determination letter application to the IRS. Plans in Cycle E submit determination letter applications for their plans beginning February 1, 2015, through January 31, 2016.

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Each subject matter—such as minimum vesting standards, required plan distributions and Section 401(k) requirements—is packaged as a publication and two forms. Not all packages are relevant to all plans.

Each package contains:

  • An Explanation that provides guidance in the law and legal citations;
  • Alert Guidelines (worksheets) you can use to review retirement plans. Generally, a “yes” answer to a question indicates a plan is in compliance with applicable law; and
  • Plan Deficiency Paragraphs (checksheets) that are pre-approved wording that, if used by plan sponsors, will satisfy the applicable Internal Revenue Code requirements. While you aren’t required to use this exact wording, the pre-approved language provides an easy and reliable method for assuring plan qualification.

The packages may be accessed here. 

The IRS has also provided determination letter review procedures that apply to Form 5300, Form 5310 and Form 5316 retirement plan determination letter applications received on or after February 1, 2015, starting with the second Cycle E. Form 5307 applications will continue to be reviewed under Cycle D2 procedures until the second six-year remedial amendment cycle for pre-approved defined benefit plans.
Deals & People June 22, 2015

NFP Advisor Services Names Chief Compliance Officer

NFP Advisor Services says Mike Pedlow will be the firm’s compliance chief. 
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Mike Pedlow is the next chief compliance officer (CCO) for NFP Advisor Services, an advisory network providing wealth management solutions, integrated technology and business consulting, including compliance services, to independent financial advisers.

In his new role, Pedlow is charged with supervising all compliance efforts and leading the compliance management team at NFP Advisor Services. He takes on the role after serving as vice president and investment advisory compliance officer. The new role involves supporting compliance for product development, training, marketing and advertising.

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Pedlow has more than 15 years of experience in the financial services industry, according to NFP. Additionally, he serves as the CCO of Washington Wealth Management LLC, an affiliate of NFP Advisor Services that also operates a recruiting platform for advisers transitioning to the independent model from wirehouses.

Before joining NFP Advisor Services, Pedlow worked at Raymond James, supervising the registered investment adviser (RIA) compliance program. He holds his FINRA Series 7, 66 and 24 licenses. He also holds a bachelor’s of arts degree in economics from the University of South Florida. 

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