In blogging, I don’t typically write about informal conversations I have had with anyone, including government staff, friends or colleagues, without first discussing it with them. I fear that otherwise I would indeed lead a lonely life, as who would ever talk with me if there was a chance that conversation would end up on
IRS Extends 8955-SSA Deadline
Important Update to last blog posting. On June 21, IRS announced the extension of the 8955-SSA deadline to January 17, 2011, for which no Form 58 extension will need to be filed. The announcement is here.
403(b), 8955-SSA and 408(b)2
Important Update. On June 21, IRS announced the extension of the 8955-SSA deadline to January 17, 2011, for which no Form 58 extension will need to be filed. The announcement is here
The challenges continue for 403(b) plans, as the IRS and DOL continue to implement their plan level rules in the 403(b) space.
Healthcare’s 403(b) Aggregation Hangover
There are three key employer groups which utilize 403(b) plans: K-12; colleges and universities; and non-profit healthcare systems. Of the three, its is healthcare that seems to be most impacted by the new aggregation rules introduced with the 2007 403(b) regulations.
Not-for-profit hospital systems are typically corporations organized under the non-profit corporation rules of the
Securities Rules for Retirement Plans
A few weeks ago, I blogged on the important role that the Securities Compliance Officer may play in 408(b)(2) compliance. I touched on some of the securities rules which apply to retirement plans outside of the executive compensation context. Attached is a more htorough explanation of those rules, which can hopefully be useful as we
ERISA and Mom
T his has become my "annual Mother’s Day" posting, which hopefully helps describe the importance of what we do:
ERISA wonks such as ourselves tend to get lost in the press of details which seem to flow non-stop from our regulators and legislators in D.C. It is sometimes helpful to step back and see
New IRS Review of Higher Ed’s 403(b) Plans: An Expensive and Serious Matter
The IRS’s Employer Plans Compliance Unit is in the process of issuing a 21 question questionnaire, Form 866a, to a sampling of colleges and universities, aimed at testing whether or not there is compliance with 403(b)’s "universal eligibility rule."
This inquiry is different than the 401(k) questionnaire that EPCU issued a while back, and
The Flushing Effect of the 403(b) Connection Between 408(b)(2), Participant Disclosures and Plan Audits
I would think that it is a basic law of physics that, whenever you attempt to apply a number of different and complicated principles to a single object, that the consequences on that object will be hard to predict, or even readily ascertained.
So it is with a potential impact 408(b)(2) may have on many
408(b)(2)/ERISA Compliance and the Security Compliance Professional
I have had the pleasure recently of making a presentation to the National Society of Compliance Professionals Midwest Compliance Meeting with Chris Guanciale of PlanMember Services. The NSPC is a nonprofit membership organization dedicated to serving and supporting compliance officials in the securities industry. What we had to say to them was not particularly
401(k) Distribution Annuities: Its Just Not About “GMWB”
When the insurance industry began seriously developing the "living benefits" under annuity products for the retail marketplace a few years back, I dubbed them as "not your grandpa’s annuity." This is because they were attempting to address the concerns that the market had about traditional annuities, which are seen as irrevocable, inaccessible, invisible and inflexible.