Seyfarth Synopsis: In newly issued ACA Implementation FAQs (Part 74), the Departments of Labor, Health and Human Services, and Treasury provide welcome guidance for employers sponsoring health-contingent wellness programs. Most notably, the agencies announced temporary enforcement relief regarding
Seyfarth Synopsis: Section 103 of the SECURE Act 2.0 replaces the Saver’s Credit with a new matching contribution from the federal government. Since the enactment of SECURE 2.0, there have been a number of questions about the implementation of this new
Seyfarth Synopsis: The IRS has issued further guidance on Trump Accounts addressing employer contributions and eligible investments in which Trump Account funds may be invested.
We discuss the new guidance in our Legal Update here. As discussed in our prior blog
Seyfarth Synopsis: The Department of Labor (DOL) recently issued Technical Release 2026-02, which clarifies that neither Trump Accounts nor employer contributions to Trump Accounts are considered “employee pension benefit plans” under Section 3(2) of ERISA. For additional information about Trump
On February 25, 2026, the Department of Labor (DOL) issued proposed regulations implementing Section 338 of SECURE 2.0, which generally requires defined contribution plan administrators to furnish at least one benefit statement on paper every calendar year and defined benefit
Seyfarth Synopsis: Two unpublished decisions involving the same change in control severance plan went in opposite directions on the standard of review. In 2026, the Fifth Circuit applied abuse of discretion based on plan language delegating interpretive authority to the
Seyfarth Synopsis: Since Trump Accounts made their debut as the “New Kid on the IRA Block” in December 2025, Treasury and the IRS have released proposed regulations that add important—but not always simplifying—details to the program.
The proposed
Since 2019, Congress has enacted three major pieces of legislation impacting retirement plans, significantly changing the retirement landscape. The legislation contained a number of amendments to the Internal Revenue Code and the Employee Retirement Income Security Act, as amended, that
If you are tired of keeping track of which retirement plan investments are deemed “good” and which are suddenly “bad”, we have encouraging news. The Department of Labor’s (“DOL’s”) latest proposed rule goes back to the fundamentals and our favorite
It has been nearly 20 years since Internal Revenue Code Section 409A transformed the rules governing nonqualified deferred compensation (NQDC). Many employers updated written plan documents by the 2008 deadline—and haven’t touched them since.
As the 20‑year mark approaches, now
