Category: DOL/IRS Guidance
Learning How to Count Again
March 29, 2023
Retirement plan administration is not a costless endeavor. Plan sponsors must administer the retirement plan following plan provisions, legislative requirements, and participant elections. To help administer the plan, plan sponsors hire service providers to help with recordkeeping, custody of assets, investment advisor tracking, and auditing the plan. Regulatory authorities want to promote retirement readiness with … Continued
SECURE Act 2.0 Brings New and Improved Self-Correction Opportunities
March 21, 2023
Enhanced Correction Options: I Didn’t Know What I Was Missing! Mistakes happen…all the time, especially in retirement plan administration. For years, I have been thankful for the self-correction opportunities granted by the IRS Program, the Employee Plan Compliance Resolution System. With each update to the program, my clients would benefit from additional opportunities to self-correct … Continued
Accountant’s Opinion Selection on Form 5500
March 02, 2023
Plan sponsors, third-party administrators, and other Form 5500 preparers take note! DOL representatives indicated that in some instances Part III – Accountant’s Opinion, Line 3(a) and 3(b) of the Schedule H is being filled out incorrectly. Marcus Aron (Division of Accounting Services) and Scott Albert (Division of Reporting Compliance) indicated at the 2023 Joint TE/GE … Continued
Universal Availability Rules
May 31, 2022
In Summary Exceptions Exist for Universal Availability: Limited exceptions permit the exclusion of certain employees from the 403(b) elective deferral opportunity, such as non-resident aliens, employees who normally work less than 20 hours per week, specific student employees, and those eligible for deferrals under certain other employer plans (401(k), governmental 457, or another 403(b)). Crucial … Continued
Correcting Retirement Plan Eligibility Errors: Improper Exclusion Leads to Corrective Contributions
March 25, 2022
In Summary High Cost of Exclusion Correction: Correcting the improper exclusion of eligible employees from making salary deferrals under the IRS’s EPCRS involves substantial employer contributions. This includes a Qualified Nonelective Contribution (QNEC) and 100% of the missed matching contribution, potentially leading to a perceived windfall for the affected participants who received their full paychecks … Continued
How Can Plan Sponsors Evaluate Prospective Auditors?
October 18, 2021
Is your auditor a Jack of all trades, but a master of none?
The New EPCRS
September 13, 2021
Posted By: Maria T Hurd, CPA, RPA Improved EPCRS : More Self-Correction Options Inside the Box Perfection is aspirational, especially when it comes to retirement plan administration. That is why 30 years ago, in 1991, the IRS created the EPCRS (Employee Plan Compliance Resolution System), a mechanism for plan sponsors to fix mistakes. Compliance with … Continued
Are Your Part Time Employees “In or Out” OR “In and Out?”
June 17, 2020
Posted by Maria T. Hurd, CPA, RPA For 403(b) plan eligibility determinations, the IRS says that “Once In, Always In” is much better than “In and Out,” so are your part-time employees “In or Out” or “In and Out”? Part-time workers and transient workers have always posed a challenge for plan sponsors trying to determine … Continued
How Do I Correct Late Salary Deferral Deposits?
April 28, 2020
Posted by Christopher J. Ciminera, CPA, QKA Update – April 29, 2020 On Wednesday, April 29, 2020 the Employee Benefits Security Administration (EBSA) also posted a Disaster Relief Notice 2020-01. In this notice, the EBSA provides relief to plan sponsors regarding the possibility of lags in deposits due to the recent COVID-19 issues which was … Continued
How do I get out of this employer contribution to my retirement plan?
April 14, 2020
Posted by Maria T. Hurd, CPA, RPA In pandemic times, employer contributions to retirement plans are not immune to cost-cutting initiatives, as corporate cash flows and liquidity dwindle. However, discontinuing discretionary contributions does not always eliminate all employer contribution requirements, and it is important for employers to anticipate and budget for any contributions that cannot … Continued