Art of the Qualified Plan Audit

The Office of the Chief Accountant (OCA) in the Employee Benefit Security Administration (EBSA) of the Department of Labor (DOL) has released a 2023 Audit Quality Study covering the quality of audits being performed by independent qualified public accountants (IQPAs).  This is the fourth study to be performed with prior studies being performed in 2015, … Continued

In Summary PEP Structure Under the SECURE Act: Pooled Employer Plans (PEPs) are a new type of “open” multiple-employer plan (MEP) created by the SECURE Act, which eliminates the “common interest” rule previously required for closed MEPs. A PEP must designate a Pooled Plan Provider (PPP) as the named fiduciary and plan administrator, offering employers … Continued

The Setting Every Community Up for Retirement Enhancement (SECURE) Act, signed into law in December 2019, brought about significant changes to retirement planning in the United States. Among its many provisions, one notable alteration has positively impacted Roth 401(k) accounts – the elimination of Required Minimum Distributions (RMDs). Understanding Roth 401(k)s Roth 401(k) accounts combine … Continued

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

In Summary PEP Definition and Structure: Pooled Employer Plans (PEPs), established by the SECURE Act, allow unrelated employers to join a single defined contribution plan, which is maintained by a pooled plan provider (PPP). This “open MEP” structure treats the plan as a single entity for both ERISA and IRC compliance, eliminating common-interest requirements that … Continued

In Summary Implementation Requirements and Effective Dates: Statement on Auditing Standards (SAS) 136 is effective for audits of periods ending on or after December 15, 2021, governing audits of employee benefit plans (EBPs) subject to ERISA. Compliance is mandatory for calendar year 2021 plans and subsequent periods, with permitted early compliance for the immediate preceding … 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

In Summary SECURE 2.0 Act Simplifies Hardship Withdrawal Administration: Section 312 of the SECURE 2.0 Act grants plan sponsors of 401(k), 403(b), and 457(b) plans relief by permitting reliance on an employee’s written certification that the distribution meets the requirements for immediate need, necessary amount (including taxes), and lack of alternative means, unless the administrator … Continued