Connections for Success


Employee Benefit Plans


Sign Your Plan Document, Warns the IRS
Stephanie M. Zaleski-Braatz

When the IRS audits a retirement plan, it expects the plan sponsor to produce a plan document and amendments that have been signed by the relevant fiduciaries. Except under extraordinary circumstances, an unsigned plan document will not suffice. The IRS recently reiterated this position in a memorandum issued by the Office of Chief Counsel. It […]


Watch Employee Turnover Rate to Avoid Partial Termination
Michael Kovacs

If you have laid off more than 20% of your plan participants over the course of your plan year — an unfortunate necessity for many employers during the COVID-19 pandemic — the IRS could deem that your retirement plan has undergone a “partial termination.” Such a partial termination would trigger the immediate vesting of all […]


SECURE Act: Changes to 401(k) Plan Eligibility and Vesting for Part-Time Employees
Kenneth Kobiernicki

The Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 contained the most significant legislative changes to the private-sector retirement system in decades. One of the SECURE Act’s provisions changes the 401(k) plan eligibility requirements for part-time employees. Related Read: What You Need to Know About the SECURE Act Understanding the rule Previously, part-time […]


Understanding Private Equity Investments in Defined Contribution Plans
James Pellino

The Department of Labor (DOL) recently released an “information letter” in response to inquiries from the private equity industry as to whether private equity investments can be offered to defined contribution plans. Per the DOL’s response, it will allow defined contribution plans to offer indirect investment in private equity funds. Is this a good fit […]


Should You Establish a Retirement Plan Governance Committee?
James Quaid

Retirement plan governance is the system through which key decisions are made about strategy and operations, including plan design, administration and investment choices. Typically, at the core of plan governance is an official plan governance committee. Although the Department of Labor (DOL) and IRS do not require a plan to have a plan governance committee, […]


How to Handle Laid-Off Employees’ 401(k) Accounts Still in Your Plan
Stephanie M. Zaleski-Braatz

As employee headcount grows, some turnover now and then usually does not create many concerns about “orphan” 401(k) accounts.  However, employers forced to downsize during the economic downturn brought on by the COVID-19 pandemic might have a larger proportion of accounts left behind by former employees. This could be a problem, but there are some […]


CARES Act Balancing Act: Helping Employees Recoup Retirement Savings
Michael Kovacs

The Coronavirus Aid, Relief, and Economic Security (CARES) Act’s retirement plan provisions are designed to throw a financial lifeline to people suffering adverse economic consequences from the COVID-19 pandemic. However, they leave plan sponsors largely in the driver’s seat. If you amended your plan to allow employees to take advantage of the CARES Act, what […]


Preventing Cyber Theft of Plan Assets Before it is Too Late
Kenneth Kobiernicki

In the employee benefit plan landscape, cyber theft of participant accounts is a disaster waiting to happen. Whether or not you are liable as a plan sponsor, is a situation that you do not want to be in. Fortunately, there are steps plan sponsors can take to safeguard participant accounts from cyber theft. Plan sponsors […]


Trending in the Right Direction With the New Electronic Disclosure Rules
Larry A. Ruff

The Department of Labor (DOL) issued final electronic disclosure rules on May 27, 2020. These rules provide relief from printing and mailing certain Employee Retirement Income Security Act (ERISA) notices to plan participants and beneficiaries. This relief is great news for plan sponsors of retirement plans. It is, however, not all-encompassing because it does not […]


CARES Act Expands Financial Options for Impacted Plan Participants
James Pellino

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was passed a few weeks ago in an effort to help curb the possible economic stress the Coronavirus pandemic has placed on Americans. The Act was far reaching and included many provisions regarding retirement plans and accounts. Although guidance on the CARES Act continues to come […]

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