In March we posted an article reviewing the Retirement Plans Experience Committee (RPEC) of the Society of Actuaries “Exposure Draft RP-2014 Mortality Tables,” recommending new mortality tables for the valuation of defined benefit plan liabilities. The new tables significantly increase life expectancy assumptions and, if adopted by regulators and DB plan actuaries, will significantly increase… Read More
IRS recently released four Private Letter Rulings (PLR Numbers 201422028, 201422029, 201422030 and 201422031) holding that in certain circumstances the payment of lump sums to retirees currently receiving annuities does not violate Tax Code minimum distribution rules. The rulings deal with an important issue in de-risking transactions involving retirees. In this article we discuss the… Read More
Several states are considering adopting legislation that would require private (that is, non-governmental) employers that do not provide a retirement plan for their employees to adopt some sort of retirement program – typically, an ‘auto-IRA.’ These proposals generally do not cover employers who already have a plan. But, depending on how they deal with uncovered… Read More
In a speech on May 13, 2014, Senator Marco Rubio (R-FL) proposed “giv[ing] Americans who do not have access to an employer sponsored plan the option of enrolling in the federal Thrift Savings Plan.” With this proposal Senator Rubio joined a growing group of policymakers and employee-advocates calling for ‘doing something’ to help the 75… Read More
In our previous article we reviewed [Professors Ayres and Curtis’s paper Beyond Diversification: The Pervasive Problem of Excessive Fees and ‘Dominated Funds’ in 401(k) Plans] (John M. Olin Center for Studies in Law, Economics, and Public Policy Research Paper No. 493). Our purpose in that article was simply to describe what Professors Ayres and Curtis… Read More
Law professors Ian Ayres (Yale) and Quinn Curtis (University of Virginia) recently published a much-anticipated article – Beyond Diversification: The Pervasive Problem of Excessive Fees and ‘Dominated Funds’ in 401(k) Plans (John M. Olin Center for Studies in Law, Economics, and Public Policy Research Paper No. 493). The paper builds on work Ayres and Curtis… Read More
On April 11, 2014 the Center for American Progress (CAP) released a report “Fixing the Drain on Retirement Savings – How Retirement Fees Are Straining the Middle Class and What We Can Do about Them.” The report is important for a couple of reasons. First, CAP – “an independent nonpartisan educational institute dedicated to improving… Read More
The IRS has released a revenue ruling (Rev. Rul. 2014-9) clarifying the process by which a qualified plan determines that an incoming rollover may be accepted. Generally, under the process described in the revenue ruling, a qualified plan may accept a check or wire transfer payable to it (the receiving plan) and issued by a… Read More
IRS recently released Notice 2014-19 “Application of the Windsor Decision and Rev. Rul. 2013-17 to Qualified Retirement Plans.” The Notice covers issues including effective dates and plan qualification and amendment requirements. More or less at the same time IRS released “Answers to Frequently Asked Questions Regarding the Application of the Windsor Decision and Post-Windsor Published… Read More
On March 11, 2014 the Department of Labor released a proposed regulation that, if adopted, would require that certain service providers required to make fee disclosures under the 2012 408(b)(2) regulation provide a separate guide or ‘roadmap’ to those disclosures. Background Under the 2012 408(b)(2) regulation, certain service providers are required to provide information about… Read More
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