The IRS has issued guidance (Rev. Proc. 2019-20) expanding the determination letter program for certain individually designed plans. The IRS had previously announced in 2017 that the determination letter program for individually designed plans would be limited to
Benefit Notes
Understanding Employee Benefits
Benefit Notes, published by Stinson LLP, focuses on legal developments and compliance issues related to employee benefit plans and retirement plans. The blog covers topics such as annual limits and cost-of-living adjustments for qualified retirement plans, risk management in retirement plan litigation, legislative changes affecting health savings accounts and flexible spending arrangements, and regulatory updates impacting health plan compliance including HIPAA and mental health parity laws. It provides guidance on plan administration, fiduciary responsibilities, and the implications of recent court rulings and federal agency actions for employers and plan sponsors.
Latest from Benefit Notes - Page 4
IRS Approves Student Loan Repayment “Match” Under 401(k) Plan
By Mark Wilkins
One of the clear trends in employee benefits involves companies offering assistance with their workforce’s student loan repayments. The reasons are obvious. Student loan debt is now the largest source of consumer debt after housing and that will likely be…
High Points of Trump’s Retirement Security Executive Order: MEPs, Benefit Plan Disclosures, Required Minimum Distribution Changes Anticipated
By Stinson LLP
On August 31, 2018, President Trump signed an executive order outlining the administration’s priorities for American retirement plans. Emphasizing that as many as 34 percent of workers do not have access to a workplace retirement plan, the order outlines the…
All Businesses, even if not Subject to 162(m), Should Consider Gathering Data to Support Future Deduction of Deferred Compensation under the Grandfather Rule
As mentioned in a previous blog, the IRS has issued its initial guidance on Code Section 162(m), as modified by the Tax Cuts and Jobs Act. One important aspect of the guidance is its discussion of preserving deductibility under the…
IRS Guidance Provides Some Clarity, but Leaves Questions Unanswered under 162(m)
On August 21, 2018, the IRS issued its initial guidance on the amendments to Section 162(m) made by the Tax Cuts and Jobs Act, in the form of Notice 2018-68. The guidance is fairly limited and does not completely…
DOL Issues Final Association Health Plan Rule
By Tom Dowling
On June 19, 2018, the Department of Labor (DOL) released a final rule that offers new options for associations to sponsor health plans for their members. These new options allow more small businesses to come together to create large employer…
Too Much of a Good Thing? Environmental, Social and Governance Investment Considerations for Plan Fiduciaries (FAB 2018-01 Part 1)
By Stinson LLP
On April 23, 2018, the DOL released Field Assistance Bulletin (FAB) 2018-01 relating to (1) plan investment in “economically targeted investments (“ETIs”), (2) the exercise of shareholder rights and (3) investment policy statements. We will address the first of these…
To Be Determined? IRS Requests Comments Regarding Potential Determination Letter Program Expansion in 2019
By Stinson LLP
The IRS announced on April 5th that the agency is seeking input on whether (and how) the individually designed retirement plan determination letter program should be expanded for the 2019 calendar year. Notice 2018-24 requests stakeholder comment regarding additional situations…
New Disability Claims Procedures May Apply to Qualified and Nonqualified Retirement Plans, Too
As mentioned in our recent blog, the date for complying with the new disability claims procedures (April 2, 2018) is rapidly approaching. In addition to making sure disability plans comply with the new rules, employers should also be reviewing…
Thanks for Noticing: Disability Claims Procedure Regulations Change Notice Requirement Next Month, Impose Strict Compliance Standard
By Stinson LLP
29 C.F.R. §2560.503-1
The DOL’s revised ERISA disability claims procedures regulations will be taking effect early next month, and plan sponsors should take a hard look at plan processes over the next few weeks to ensure compliance. The new requirements…