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In efforts to expand access to retirement savings programs for more Americans, the SECURE Act and SECURE 2.0 both included new rules that will require plans to allow long-term part-time (LTPT) employees to make elective deferrals into a 401(k) plan if they meet certain minimum hours requirements. This post updates our earlier post on the subject as ...

While many provisions of SECURE 2.0 apply to various types of retirement plans, including 403(b) plans, this update will focus on those provisions of the Act that apply only to 403(b) plans. Please check out our prior blog posts for other SECURE 2.0 provisions that impact 403(b) plans as well as other types of retirement plans.

Effective for ...

By: Michaela Taylor*

If you sponsor a group health plan, make sure you set a calendar alert before the winter holidays to submit the annual gag clause prohibition compliance attestation. Under the Consolidated Appropriations Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with ...

In welcomed news, under newly released DOL regulations, the Department of Labor (DOL) has updated the Form 5500 filing requirements to reduce the number of plans that will be required to obtain an annual audit. The rule remains that retirement plans with 100 or more participants must obtain an annual audit report from an independent qualified ...

For the third year in a row, the IRS adjusted the affordability percentage used for the shared responsibility penalties down. The IRS recently announced that the affordability percentage for 2024 will be 8.39%. This is down from 9.12% in 2023. For employers this means that if you set your employee premium costs last year right at the ...

IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code.  The Act provided that, beginning in 2024, individuals eligible to make catch-up contributions who made over $145,000 (indexed ...

Last week, the IRS announced it was increasing enforcement strategies aimed at Employee Stock Ownership Plans “ESOPs". The IRS stated this new focus on ESOPs is part of the effort to ensure tax laws are applied fairly and that high-income filers pay the taxes they owe. As part of this initiative, the IRS Commissioner commented that the IRS is ...

Last month the Sixth Circuit Court of Appeals upheld a lower court ruling that a company’s benefits committee did not properly delegate decision-making authority to its benefits department. As a result, the plaintiff’s appeal was reviewed under the de novo standard of review (which allows the court to conduct an independent analysis of ...

Errors in retirement plans happen even to the most well-intentioned plan sponsors. Several decades ago, the IRS published the first version of the Employee Plans Compliance Resolution Program (EPCRS), which outlines procedures by which plan sponsors can correct errors in their qualified retirement plans. Some of these errors could be ...

By: Lyndsey Barnett and Tommy Rogers*

As you may be aware, Employee Retirement Income Security Act (ERISA) fidelity bonds and fiduciary liability insurance are not the same. Both serve to mitigate risk for fiduciaries, and are critical aspects of an employee benefits plan. The difference between the two lies in the risks that they cover. Are you ...

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