Art of the Qualified Plan Audit

In our previous blog post, Pooled Employer Plans (PEPs): The Basics, we outlined the basics of a PEP and will not dig into the details of the financial reporting requirements for these plans. The administrator of a PEP must file an annual Form 5500, Annual Returns/Reports of Employee Benefit Plan, to which the PEP administrator … Continued

PEPs were established in section 101 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), which amended ERISA and the IRC, to allow unrelated employers to join a defined contribution retirement plan maintained by a pooled plan provider (PPP) acting as the plan’s administrator and named fiduciary. A PEP, as … Continued

Originally published in the Summer 2023 Issue of Delaware Banker (Delaware Bankers Association). Let’s Start With the Basics – What is a Pooled Employer Plan (PEP)? PEPs were established in section 101 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), which amended ERISA and the IRC, to allow unrelated … Continued

Death by a thousand cuts. That’s what initial 401(k) and 403(b) audit clients fear their first financial statement audit will feel like. Fear of the unknown leads the human mind to worst case scenarios. Could I fail the audit? Sure, anything is possible. Will I fail my first audit? Not likely. Even if the audit … Continued

Statement on Auditing Standards (SAS) 136 addresses the auditor’s responsibility to form an opinion on the financial statements of employee benefit plans (EBPs) subject to the Employee Retirement Income Security Act of 1974 (ERISA). It also addresses the form and content of the auditor’s report issued as a result of a full scope or an … Continued

In the past, innocent participants paid the price for their employers’ mistakes In our previous blog Give it BACK!!!”…”No!”…”OK, Keep It!, we described how the previous law required retirement plan fiduciaries to take reasonable action to recover any overpayment of plan benefits, even when the overpayment is generally the employer’s fault. Reasonable action meant an … Continued

Not Enough RMD Participants must take an Required Minimum Distribution (RMD) from retirement plans and IRAs. 403(b) plans often have more than one account in the name of each participant. While each 401(k) plan must issue its own RMDs, an individual can take one RMD distribution for the entire amount computed using the balances in … Continued

In its quest to Set Every Community Up for Retirement Enhancement, SECURE 2.0 enhanced the Long-Term Part-Time (LTPT) rules of Secure 1.0 by making them applicable to 403(b) plans. Since employees are more likely to contribute to an employer-sponsored retirement arrangement than an Individual Retirement Account, and more Americans are working part-time since the pandemic, … Continued

The Rule Individuals who turn age 72 after December 31, 2022, AND who reach age 73 before January 1, 2033, have a compulsory RMD age of 73. What It Means Individuals who turn 73 during 2023 must take an RMD for 2023 by April 1, 2024, but individuals who turn 72 during 2023 do not … Continued

Retirement Readiness vs. Immediate Financial Needs Life is a balancing act. Regulators strive to fight leakage by imposing penalties on early distributions, but they also don’t want to add to legitimate unforeseen and extreme emergency situations by imposing penalties when participants are in trouble. At the same time, regulators don’t want to impose administrative burdens … Continued