2024 Deadlines and Important Dates for Plan Sponsors

Help for 401k Plan Sponsors and Retirement Professionals


Newsletter for February 20, 2024

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401k Averages Book Now Includes Advisor Compensation Plus More

The newly released 401k Averages Book 24th Edition introduces fresh charts and a revamped format. Notable additions include Advisor Compensation along with the introduction of a comprehensive recordkeeping administration fee, encompassing hard dollar and asset-based recordkeeping costs along with any allocations from revenue sharing. These new data points will prove to be highly beneficial, offering a more comprehensive and insightful perspective on 401k average costs. Click here to order your copy.


In This Issue


Compliance and Regulatory

2024 Deadlines and Important Dates for Plan Sponsors

Sponsors of defined benefit and defined contribution retirement plans should keep these deadlines and other important dates in mind as they work toward ensuring compliance with their plans in 2024. Dates assume a calendar year plan. Some deadlines may not apply, or dates may shift based on the plan sponsor's fiscal year.

Source: Berrydunn.com

IRS Pre-Examination Retirement Compliance Pilot Program Is Extended

On February 7, 2024, the IRS announced the second phase of its Pre-Examination Retirement Compliance Program. Under this program, sponsors will be notified that their plan is selected for examination and will have 90 days to review and correct any plan document or operational errors, similar to the process for phase one. If a plan sponsor receives a letter notifying them of an upcoming examination, it is important to act quickly and loop in benefits counsel as soon as possible.

Source: Erisapracticecenter.com

401k's and De Minimis Financial Incentives

On December 20, 2024, the IRS released Notice 2024-2 (the "Grab Bag" guidance), which provided a Q&A format of guidance on certain provisions of the SECURE 2.0 Act of 2022. This article discusses the "de minimis" incentives for employees to defer, as outlined in SECURE 2.0 and for which the IRS just provided guidance in the Grab Bag. Here's how it may apply to your qualified plan.

Source: Ferenczylaw.com

When It Comes to Vesting, the IRS Says Once a Long-Term, Part-Time Employee, Always a LTPT Employee

Under the SECURE Act and the SECURE 2.0 Act, employers must provide long-term, part-time employees the opportunity to make elective deferrals under their 401k plans and, beginning in 2025, their 403b plans. However, long-term, part-time employees are not required to be eligible for employer matching or profit-sharing contributions until they satisfy the regular plan rules. Despite this fact, one of the most salient issues surrounding the implementation of the new rule is how it impacts -- and complicates -- tracking when employees become vested in such contributions.

Source: Mwe.com

»»  Click here for more Compliance and Regulatory Material

Fiduciary and Plan Governance

Consultants Advise Plan Fiduciaries to Vet DC Annuity Offers

With defined contribution annuity offerings proliferating in recent years among both providers and recordkeeper platforms, retirement plan advisers and sponsors must take a close look at the options to protect themselves and their participants, according to recent commentary from an annuity consultancy. ARC consultants cite "cause to question" language that requires assessing annuity offerings for qualified plan participants.

Source: Planadviser.com

Hiring an ERISA 3(16) Plan Administrator

This guide is designed to shed light on the crucial aspects of understanding your fiduciary responsibilities, how a 3(16) plan administrator can help you, as well as mitigate risks. While this choice may not be right for every retirement plan, it could be of tremendous value to those wishing to add support to their plans while mitigating risks and seeking to improve the financial well-being of plan participants.

Source: Planpilot.com

»»  Click here for more Fiduciary and Plan Governance Material

Insight: Studies, Research, Analysis, and Papers

Why Did IBM Reopen Its Defined Benefit Plan? Will Others Follow?

Enthusiasm seems to be growing to reopen -- or at least to stop closing and freezing -- defined benefit retirement plans. The most dramatic manifestation of this enthusiasm for reopening plans has been IBM's announcement to shift its 401k match to an automatic contribution to the cash balance component of its previously frozen defined benefit plan. This article lays out the implications of IBM's shift for the company and its employees and speculates about which companies might follow IBM's lead.

Source: Bc.edu

Employees See 401k Plans as Prerequisite Instead of Perk

Access to workplace retirement plans is no longer considered a job perk to employees, but a necessity instead. A new study released today by Vestwell, which surveyed 1,200 employees nationwide on savings habits, evolving benefits, and challenges, finds that 85% of respondents expect their employer to offer retirement benefits, up from 72% last year. Additionally, 89% of survey respondents say they would be more likely to continue working for an employer that offers a retirement benefit.

Source: 401kspecialistmag.com

Driving Better Insights and Outcomes -- Securely -- With Artificial Intelligence

Many recordkeepers are embracing artificial intelligence to deliver a personalized participant experience necessary to support a comprehensive retirement strategy for workers nationwide. Are you able to take advantage? While this technology is intended to provide valuable insights and optimize retirement preparedness, it also introduces fundamental concerns for plan sponsors.

Source: Napa-net.org

»»  Click here for More Studies, Research, and White Papers

Items of Special Interest to Advisers and Other Service Providers

The DOL Fiduciary Proposal's Impact on Banks and Trust Departments

Take a quick dive into the exciting world of ERISA with Faegre Drinker benefits and executive compensation attorneys Fred Reish and Brad Campbell. In this quick-hit series of updates, Fred and Brad offer a high-level view of current trends and recent ERISA developments. In this newest episode, they look at the DOL's fiduciary proposal's impact on banks and trust departments.

Source: Spotlightonbenefits.com

House Lawmakers Debate Merits of DOL's Proposed Fiduciary Rule

Coming slightly more than a month after its first hearing on the Department of Labor's proposed invest. advice fiduciary rule, a second subcommittee of the House of Representatives debated the merits of the proposal, with the battle lines drawn between the two parties. The DOL is currently reviewing the thousands of comment letters that were submitted to it earlier. The DOL's unified agenda does not show a target release date for a final rule.

Source: Asppa.org

Smaller Accounts, Insurance Product Impact Debated at Hearing on Fiduciary Proposal

Opponents of the Department of Labor's retirement security proposal testified at a Congressional hearing Thursday that the proposal would dramatically decrease access to advice for smaller account holders, while proponents argued it is a necessary regulation to reduce and mitigate investor abuses.

Source: Planadviser.com

403b Plans

Nearly Three Quarters of Higher Ed Institutions List Retirement Readiness as Top Concern

A new study on retirement plans in higher education institutions likens the past year's challenges to those during the COVID-19 pandemic and highlights how continuing economic fallouts have marred retirement planning for participants. According to Transamerica's latest Pulse survey, 71% of institutions say retirement preparedness is one of their top concerns, yet 86% cite the cost of living and inflation as their leading worry.

Source: 401kspecialistmag.com

»»  Click here for More 403b Material

Court and Legal

Milliman Headed to Trial Over Its 401k

Late last week, the company's request to quash the case through summary judgment was shot down by the judge presiding over it, who scheduled a rare bench trial to begin April 1. Whether the case goes to trial is a question. Clearing motions to dismiss and defense motions for summary judgment are considered significant victories for plaintiffs, and getting over those hurdles adds pressure to settle.

Source: Investmentnews.com

Wisconsin Federal District Court Issues Five Rulings on Motions to Dismiss 401k Investment and Fee Cases: Is There a Way to Reconcile Them?

Defense counsel frequently laments the difficulties of defending 401k investment and recordkeeping fee litigation when different judges render conflicting rulings on motions to dismiss seemingly indistinguishable complaints. For that reason, the author of the article thought it would be interesting to track the decisions by a single judge in the Eastern District of Wisconsin who rendered five rulings in this arena within one week. The hope was that the rulings would provide some insight as to distinguishing features that, at least for this judge, would drive the outcome of each motion to dismiss.

Source: Erisapracticecenter.com

Honeywell Hit With Forfeiture-Related Fiduciary Breach Suit

Another suit has been filed against a large employer for allegedly not acting in participants' best interest in their use of forfeitures, but with some twists in the arguments. The target this time is the fiduciaries of the Honeywell 401k plan who, according to the participant-plaintiff, have (1) breached their fiduciary duties under ERISA, (2) violated ERISA's anti-inurement provision, and (3) engaged in "self-dealing and transactions prohibited by ERISA."

Source: Napa-net.org

»»  Click here for more Court and Other Legal Issues

Marketplace News

Ceridian Becomes Dayforce

Pontera Partners with CAPTRUST to Enable Enhanced Retirement Planning

2024 PLANADVISER Adviser Choice Awards

Voya Evolves Suite of Advice and Guidance Solutions With Launch of New Dual QDIA

Bank of America Reports 15% Increase in 401ks in 2023

Payroll Integrations Seeks to Tackle Form 5500 Hassles for TPAs

BPAS Acquires Creative Plan Designs, Ltd


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