IRS, DOL & ERISA Regulatory Updates

New IRS Restrictions for Obtaining Determination Letters
Each year, the Internal Revenue Service revises its procedures for obtaining favorable determination letters and the associated user fees.
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IRS Finally Issues New Procedures for Pre-Approved Plan Submissions -- November 2011
Since February 1, 2011, plan sponsors and mass submitters have had the opportunity to submit their pre-approved defined contribution plans to the Internal Revenue Service to obtain new opinion and advisory letters.
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Document Providers Wait for IRS Guidance on Pre-Approved Plan Submissions -- September 2011
Document providers, including the ASC Institute (ASCi), are waiting for guidance from the Internal Revenue Service on the submission process for pre-approved defined contribution plans, including master & prototype (M&P) and volume submitter plans.
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IRS/Treasury Staff Meets with Retirement Plan Practitioners – July 2011
On July 13, 2011, the Determination Letter Liaison Group met in Washington, DC to discuss current issues relating to the IRS’ determination letter program, the pre-approved plan program and other retirement plan document matters.
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250% Increase in IRS Fees for Determination Letters – February 2011
Recently, the Internal Revenue Service raised fees by as much as 250% for determination letters for individually-designed qualified retirement plans. In some cases the fee goes from $1,800 to $4500! You can avoid these fee increases, and even pay less fees, when you choose to utilize a pre-approved plan.
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Pension Provisions under Small Business Jobs Act of 2010
The Small Business Jobs Act of 2010 (SBJA) was signed into law on September 27, 2010. Although the primary focus of the SBJA was to expand the availability of credit for small businesses, there are two major provisions that will affect qualified retirement plans, 403(b) plans and governmental 457(b) plans.
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Some Observations: DOL Fee Disclosure Regulations July 2010
By this time, you likely have read much about the Department of Labor’s new fee disclosure regulations issued in July. These “interim final” regulations continue the DOL’s initiative to ensure that there is adequate disclosure relating to retirement plans to ensure that plan fiduciaries and participants have enough information to make knowledgeable decisions regarding the fees being paid under retirement plans.
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Determining Actuarial Equivalence under Cash Balance Plans – Per PPA 2006
When selecting assumptions for actuarial equivalence before the changes made under the Pension Protection Act of 2006 (PPA), it was not unusual for traditional defined benefit plans to make reference to the Code §417(e) assumptions. With the changes under PPA, referencing Code §417(e) rates for actuarial equivalence can cause difficulty for the plan’s actuary, especially for cash balance plans.
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