Pension Protection Act Blog

Organizing this first Carnival has been very interesting. Here is this week’s link post for a little light Friday reading - Enjoy!
Brian King presents State Universal Healthcare Coverage Initiatives Will Survive ERISA Preemption posted at Brian King’s ERISA Blog.
Susan Mangiero presents the Pension Risk Management Tipping Point posted at Pension Risk Matters.
Prof. Paul Caron […]

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When the Final 409A Regulations came out earlier this month, I did a quick read of them, and then put them aside. I planned on getting around to thoroughly reviewing them at some point this summer. Because I concentrate on qualified plans, I wanted to dig into the Final 415 Regs first. […]

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With the introduction of the Automatic IRA Act of 2007, S. 1141, automatic IRAs have become a topic of conversation again. The Automatic IRA is not a new idea - Congress has seen bills containing automatic IRA provisions in the past. Automatic enrollment in 401(k) plans is not a new idea either. […]

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One of the important changes made by the Pension Protection Act was the change to whipsaw calculations for cash balance plans. Last Friday, April 20th, the Sixth Circuit Court of Appeals issued one of the first opinions to mention this change, devoting two separate sections of the opinion to PPA.
In an opinion […]

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Carnival:
noun

1. a festival marked by merrymaking and processions
2. a frenetic disorganized (and often comic) disturbance suggestive of a large public entertainment; “it was so funny it was a circus”; “the whole occasion had a carnival atmosphere”
3. a traveling show; having sideshows and rides and games of skill […]

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Some summaries of the Final 409A Regs:
- The law firm of Sutherland Asbill & Brennan has posted a 23-page summary in a Q&A format;
- The law firm of Ballard Spahr Andrews & Ingersoll has posted a very short summary;
- The law firm of Paul Hastings has posted a red-lined version of the regulations. […]

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Interesting question today - should the Quarterly Benefit Statement include the vesting schedule for the plan. The easiest answer to this question is to avoid it all together and provide the alternate notice because the alternate notice does not require vesting information to be provided this quarter, and hopefully the IRS will issue a […]

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Spent some time today going through section 903 of the Pension Protection Act, which is the section on the combined defined benefit/401(k) plans permitted for plan years after December 31, 2009. The question, which I’ve heard several times over the last couple of months, is how to make the most appropriate choices now in […]

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Today, the IRS issued the Final 409A regulations along with Notice 2007-34 on the application of 409A to split-dollar life insurance. The Final 409A Regs are as voluminous as anticipated - 397 pages in the single-column version. This makes two major pieces of guidance - the Final 415 Regs and the Final 409A […]

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The IRS released a short two-page summary of the Final 415 Regs in the form of a special edition of Employee Plan News. The summary for the items changed by the Pension Protection Act are:
The following modifications to section 415 made by the Pension Protection Act of 2006:
i. changes to the interest rate assumptions […]

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