A new Revenue Procedure makes a change to Revenue Procedure 2018–4 Section 8.02 to add new section 3, “Other Circumstances,” to provide a new category for which determination letters can be requested.
Several commenters argued that without changes, the proposed rule would have little impact on expanding retirement plan coverage for American workers.
The table is needed to compute the value of early retirement benefits and, thus, the total value of benefits under a plan.
Under the once-in-always-in exclusion condition, for a 403(b) plan that excludes part-time employees from making elective deferrals, once an employee is eligible to make elective deferrals, the employee may not be excluded from making elective deferrals in any later exclusion year on the basis that the employee is a part-time employee.
Under the proposed regulations, 401(k) plan sponsors could choose to make additional accounts available for hardship withdrawals.
The DOL said it is considering regulatory options in light of a 5th Circuit opinion vacating its previous fiduciary rule, and has on its timeline that a final rule will be issued in September of 2019.
The agency says the additional information is needed to help it determine a defined benefit (DB) plan sponsor’s ability to continue to maintain its DB plan.
A Program Letter lists compliance strategies for the agency for next year.
The IRS has issued two modified safe harbor explanations which take into consideration changes related to qualified plan loan offsets and other statutory changes.
The agency included a list of common filing errors and provided details about those errors in a new Appendix.
The executive order regarding RMD rules and open MEPs, signed last week by the President, also asks the DOL and Treasury to simplify disclosure regulations for plan sponsors and participants.
The IRS clarified that forfeitures would be permitted to be used to fund QMACs and QNECs.
Internal Revenue Code (IRC) Section 411(d)(6) provides that an accrued benefit may not be decreased by amendment.
While non-electing church plans are not subject to most ERISA requirements, they are subject to pre-ERISA regulations.
“Non-qualified deferred compensation plans will always be tax advantageous and a useful benefit,” Bruce J. McNeil, partner with The Wagner Law Group, told Plan Sponsor Council of America (PSCA) 71st Annual National Conference attendees.
David Levine, principal at Groom Law Group, said there is a real chance of a big impact on the retirement plan agenda if Republicans take losses in the mid-terms, so he expects a huge push to pass everything they can before then.
The new guidance addresses ESG investment considerations under investment policy statements and when choosing QDIAs.
The agency ended its determination letter program effective in 2017, but said it will measure the need for exceptions in a variety of ways including annual input from the Employee Plans (EP) community.