Pension Protection Act Blog

Lizzie Palmer has posted an amazing video on YouTube. The video has nothing to do with plan documents or ERISA directly.
Earlier this month, I posted about reviewing the USERRA provisions in plan documents before making year-end contribution projects for next year. Paul Secunda of the Workplace Prof Blog discusses an article in the […]

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Brian Kanner, a law student at Emory University School of Law, has published an interesting article which reviews USERRA requirements with the protections provided to pregnant women. While the title is unfortunate - Reservists are Like Pregnant Women - A Fertile Battleground for a Reinterpretation of USERRA - the article provides a very good […]

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Summary plan descriptions can be easier and harder to write than the actual plan document. Summary plan descriptions are harder to write because it requires condensing a 100+ page plan document down to 20 or 30 easy to read pages without missing any of the plan nuances. On top of that, the Department […]

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The IRS has released the 2007 list of interim and discretionary amendments for 2007. The amendments contained in the list are based on the 2006 Cumulative List.
In Rev. Proc. 2005-66, the IRS created a 5-year remedial amendment cycle for restating plans and submitting them for determination letters. Within this structure, the IRS included […]

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This IRS issued Notice 2007-67 today, which extends the transitional relief provided to plans of Indian tribal governments and certain related entities under Notice 2006-89. Section 906 of the Pension Protection Act amended Code section 414(d).
Code section 414(d) contains the definition of governmental plans, and includes plans established and maintained by Indian […]

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As a pension geek, I spend a lot of time reading reports produced by the federal government, or reading reports about guidance produced by the federal government. These reports tend to fall into two categories. One categories is the stack of papers which I read, highlight, and spend some time contemplating. The […]

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Recognizing when a plan has partially terminated is important and sometimes overlooked. For both participants and plan sponsors, the finding of a partial termination is an important plan event because participants who were partially vested before the partial termination event will become fully vested due to the partial termination.
In Revenue Ruling 2007-43, issued today […]

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Every now and then, the idea that plan documents should include language which automatically forfeits the non-elective portion of a participant’s account balance if the participant leaves the employer and goes to work for a competitor. This language is known as a “Bad Boy Clause” in the plan document.
The concept is fairly […]

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