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Things Every Employer Should Know About Pension-Linked Employee Savings Accounts (PLESAs)

In the wake of recent developments, we are pleased to provide insights into Pension-Linked Employee Savings Accounts (PLESAs) under the Secure 2.0 Act.  PLESAs are short-term savings accounts that are established and maintained within a defined contribution plan.  The legislative intent of a PLESA is to allow low- and middle-income employees to use payroll deductions […]

| 2 min read

IRS Delays Roth Catch-Up Contribution Requirement

On August 25, 2023, the IRS issued Notice 2023-62, which gives retirement plan sponsors a two-year administrative transition period to implement the SECURE 2.0 requirement that certain catch-up contributions to 401(k) and similar defined contribution plans be made on an after-tax Roth basis. More specifically, SECURE 2.0 requires catch-up eligible participants who received more than […]

| 2 min read

SECURE 2.0 and Required Minimum Distributions in 401(k) Plans: What Plan Sponsors Need to Know

SECURE 2.0 brought significant changes to retirement planning and distributions, including updating the Required Minimum Distribution (RMD) requirements.  As background, RMDs are the minimum amounts that individuals who attain their “required beginning date” must withdraw from their retirement accounts each year. SECURE 2.0 introduced several changes to the rules on RMDs including the following: 1. […]

| 2 min read

SECURE 2.0 Expands Self-Correction Under EPCRS

Effective December 29, 2022, Section 305 of SECURE 2.0 expands the ability for plan sponsors to self-correct certain plan failures under the Employee Plans Compliance Resolution System (“EPCRS”).  Section 305 of SECURE 2.0 generally permits the self-correction of certain “eligible inadvertent failures” under EPCRS, including certain plan loan failures, provided that: (1) the failure is […]

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CalSavers Program Expanding for Small Employers

On August 26, 2022, the Governor of California signed Senate Bill No. 1126 (“S.B. 1126”) into law, amending California’s CalSavers Retirement Savings Program (“CalSavers”).  In general terms, CalSavers automatically enrolls eligible California employees in ROTH Individual Retirement Accounts if their employer does not provide a qualified retirement plan.  CalSavers requires eligible employers to facilitate the […]

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IRS Extends Amendment Deadline for Certain Qualified Plan Amendments

The IRS recently provided some welcome relief in the form of extended amendment deadlines for sponsors of qualified retirement plans (including collectively bargained plans).  Notice 2022-33 extends the deadline for adopting amendments required by the Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”) and the Bipartisan American Miners Act of 2019 […]

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A Running Start: IRS Pilots New Pre-Examination Program

The Employee Plans Office of the Internal Revenue Service (the “IRS”) announced a new pre-examination program for retirement plans to begin as of June 2022.  The pilot program is designed to reduce the amount of time and resources the IRS expends on plan audits, while affording plan sponsors the opportunity to identify and correct errors. […]

To the Moon After All? DOL Targets Cryptocurrency in Retirement Plans

In Compliance Assistance Release No. 2022-01 (the “Release”), the Department of Labor (the “Department”) signaled its intention to scrutinize inclusion of cryptocurrency assets and crypto-derivative products as investments in ERISA-covered retirement plans.  In particular, the Release articulates the Department’s view that offering exposure to this asset class – either in a plan’s investment lineup or […]