With this blog, we take the next step into the Podcast world, where we describe  the CARES impact Length of Service Awards programs (called “LOSAPs) under 457(e)(11). The Podcast is more extensive than the written word below, and I recommend you give it a try. I also rant a bit on it about  current state of confusion in the implementation of the CRD rules.  Listen to the Podcast here. It’s only about 7 1/2 minutes…

If you prefer to LISTEN to this blog as a podcast, go to our new Podcast player to listen, this one is 10 minutes long.  We are introducing our new podcast site soon.  Let us know what you think! We know that all parties involved in plan administration are struggling with the question of whether the employer or the participant have the CARES Act rights to 1) an extension of loan amounts (I think it’s the…

One of the benefits from posting a techie blog for a dozen years or so is the tremendous value from other serious techies weighing in on what I write. Robert Richter, now of ARA and chief editor of the EOB, has weighed in my posting on the suspension of the due date of loan repayment. I had posited that it is effectively is the participants choice, as the specific language of the statute declares that…

This blog has been updated by a June 22 post found by clicking here The structure and the language used by the drafters of the CARES Act in their crafting of the new participant loan repayment suspension rules seem to be both rare and stunningly broad: they appear to actually mandate, as a matter of federal law, that each loan repayment due through December 31, 2020  by COVID qualifying participants be suspended for one year.…

Three things in particular struck me about the SECURE Act: First was the lack of immediate, significant impact on the employer maintaining plans. There are a number of details which their vendors-and the regulators- need to address soon, but for most plan sponsors? It really is a big ho-hum. Second was the sheer number of novel concepts that was introduced by the Act: PEPs, Groups of Plans, Birth and Adoption Rules, Portability of lifetime Income,…

The SECURE ACT introduced a concept which was not known well beyond a handful of 403(b) practitioners, that is the “distribution” of 403(b) individual custodial accounts from 403(b) plans.  The lack of understanding of what this actually means has even lead one commentator in a highly respected trade organization’s technical piece to claim that this rule transforms 403(b) custodial accounts into IRAs. Well, that is an easy one to settle: the “distributed” 403(b) custodial contract…