"Plan disqualification" is a well understood and managed feature of the 401(a) landscape, complete with great history, a long line of guidance and rulings, and a well developed set of correction programs. We all know what happens when a 401(a) rule is violated, its affect on plan qualification, and (ususally) what to do about it.
January 2010
CORRECTION BLOG: Annuity PLR Reference Incorrect!
By Robert Toth on
Posted in Lifetime Income
My everlasting thanks to Andrea-Ben Yousef of BNA. We were exploring annuities, and some confusion from my blog of January 6th, 2009. We discovered that I posted the incorrect PLR number and link on that blog, where I discussed the importance of a new PLR to DC annuitization. The link I had incorrectly provided was…
IRS PLR Helps Pave the Way for DC Annuities
By Robert Toth on
Posted in Lifetime Income
Annuitization from DC plans suffers from the lack of clarity on a number of key technical rules, which need to be resolved before such annuities can be widely implemented. The IRS has taken a major step in its issuance of PLR200951039, a complex PLR which- for the first time-defines what an annuity really is…
DOL’s Fiduciary Proxy Voting Rules Makes Upcoming Proxy Season “Dicey” for Plan Fiduciaries
By Robert Toth on
Posted in Uncategorized
Its going to be a demanding year for fiduciaries of retirement plans, particularly of those in the small and mid-market which are not particularly accustomed to paying close attention to them. I have blogged earlier on the increased fiduciary demands related to the new data provided to fiduciaries under the 2008 Form 5500 Schedule C…