February 2012
Final Rule Issued Regarding 408(b)(2) & 404(a)(5)
Retirement Plan Fee Disclosure Regulations
The U.S. Department of Labor's (DoL) Employee Benefits Security Administration (EBSA) on February 2nd, 2012 issued a final rule on 408(b)(2) fee disclosure and issued a three-month extension to the rule's effective date.
October 2011
IRS Announces 2012 Pension Plan Limits
The Internal Revenue Service announced on October 20th the cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for Tax Year 2012.
October 2011
Fall 2011
Regulatory Update
On July 13, 2011, the Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) pushed back the applicability dates for fee disclosure rules. The extension gives covered service providers and plan fiduciaries additional time to prepare fee and investment-related information required for disclosure to employees.
July 2011
DOL Extends Applicability Dates
Fee Disclosure Regulation Extension Finalized
The new applicability date for the fiduciary-level fee disclosure regulation under Section 408(b)(2) of the Employee Retirement Income Security Act (ERISA) has been extended three months later than the proposed deadline extension, to April 1, 2012.
June 2011
Department of Labor Update
Proposed 408(b)(2) Fee Disclosure Regulation Extension
US Department of Labor to extend and align applicability dates for retirement plan fee disclosure rules.
May 2011
SEAL Act
Potential Legislation Introduced
Last week, US Senators Herb Kohl (D-WI) and Mike Enzi (R-WY) introduced legislation in effort to help ensure that retirement savings in defined contribution plans will last throughout retirement for retirees.
May 2011
2011 Defined Benefit Plans Update
FAS & Funding Issues
February 2011
DOL Extends Effective Date of ERISA 408(b)(2) Regulations
Fee Disclosure Applicability Date Now 1/1/2012
The U.S. Department of Labor's Employee Benefits Security Administration announced on Feb. 11, 2011 that it intends to extend the applicability date for the new disclosure rules under section 408(b)(2) of ERISA to Jan. 1, 2012.
December 2010
Administrative Guidance on In-Plan Roth Conversions
Small Business Jobs Act of 2010 Update
On November 26, 2010, the IRS issued guidance in a Q&A format that addressed many of the issues related to adding a feature to convert pre-tax accounts in a qualified 401(k) or 403(b) plan to a Roth after -tax account within the same Plan.
November 2010
2011 Dollar Limitations for Pension Plans
No Change from 2010
Limits of $16,500 for employee deferrals and $5,500 age 50+ "catch-up contributions" remain unchanged.
October 2010
New White Paper Available
Looking Ahead (Again): The Implications of Market Volatility on Defined Benefit Plans
This paper provides an updated forward-looking analysis of both fiscal 2010 year-end disclosure results as well as 2011 and 2012 plan year funding requirements for calendar year plan sponsors based on market and yield curve performance through 9/30.
October 2010
Employee Benefits Security Administration (EBSA)
Final Rules for Participant Fee Disclosure Released
Final Rules to improve transparency of fees and expenses to participants in 401(k)-type Retirement Plans were released on October 14th 2010.
October 2010
New White Paper Available
Small Business Jobs Act and Roth Conversions
On September 27, 2010, the Small Business Jobs Act of 2010 was signed into law. One of the major components of this Act was the ability to convert pre-tax retirement accounts to after-tax Roth accounts within the Plan.
September 2010
Small Business Jobs Act of 2010
Roth Conversions & Roth 457
Both the Senate & House of Representatives have passed the Small Business Jobs Act of 2010 (and the President is expected to approve), which includes provisions that would allow for Roth contributions in a 457 plan and in-plan Roth conversions for eligible rollover distributions in qualified plans.
July 2010
New White Paper Available
Defined Benefit Plan Funding and Financial Accounting Disclosure (FAS) Issues for 2010
July 2010
DOL Publishes Final ERISA Service Provider Disclosure Regulations
ERISA Section 408(b)(2)
The new regulations require registered representatives, investment advisers, and others who work with 401(k) Plan Sponsors to provide detailed overviews of their services and compensation.
May 2010
DOL & SEC Offer Guidance on Target Date Funds
The U.S. Department of Labor's Employee Benefits Security Administration and the U.S. Securities and Exchange Commission announced guidance to help investors and plan participants better understand the operations and risks of target date fund investments.
April 2010
Department of Labor Releases Final Regulations
The DOL has finalized the proposed ruling regarding the timely remittance of employee contributions for small plan filers.
February 2012
Guidance Issued on New Summary of Benefits and Coverage Document
Deadline Change, Formatting and Content Requirements
On February 9th, the U.S. Departments of Labor and Health & Human Services and the Internal Revenue Service issued final regulations with respect to the new Summary of Benefits and Coverage (SBC) required to be distributed to health plan participants under the Patient Protection and Affordable Care Act. While there is still much to digest in the 150 pages of regulations, the first and most important point to be made at the moment is that the initial due date has been deferred from March 23rd to September 23rd.
January 2012
2012 "Fair Share Contribution" Filing Requirement
Important Reminder - February 15th Massachusetts "Fair Share Contribution" Filing Requirement
By now you may have received a notice from the Massachusetts Division of Unemployment Assistance (DUA) regarding the requirements to complete the "Fair Share Contribution" (FSC) filing online report. For those employers who have been filing quarterly during 2011, this is one more quarterly report. For those who have not been required to file quarterly, this is an annual report required to be filed by February 15, 2012. (The period you will be reporting on is October 1, 2011 - December 31, 2011).
The online filing will also entail completing the annual Employer "Health Insurance Responsibility Disclosure" (HIRD) report.
December 2011
End of Year Action Items 2011
END OF YEAR ACTION ITEMS
It's that time of year again - the holidays are here and it's time to review some end of year benefit plan "action items" that may require your attention:
Long term disability imputed income: if LTD is a "gross up" or "tax choice" plan, employees recognize income to the extent of premiums paid by the company for LTD, thus paying the tax on the premium. In exchange, any benefits paid would be non-taxable under current law. Action: add cost of LTD to W-2's.
Life insurance amounts over $50,000: The coverage over $50,000 results in "imputed income" to participants. Action: impute income on life insurance amounts over $50,000 by adding value of insurance protection to W-2'S.
September 2011
Medicare Part D Notice and CMS Online Disclosure
Employees or Dependents eligible for Medicare must be provided with certain notices with regard to their employer's Rx coverage. In addition, plans that cover any Medicare Part D eligible individuals are required to file a disclosure with the Centers for Medicare Services ("CMS").
September 2011
Healthcare Reform Update - PPACA
Healthcare Reform Update - PPACA
Beginning last September 23rd, the major provisions of the Patient Protection and Affordable Care Act ("PPACA") have been phasing in to health insurance plans nationwide. Coverage for children up to age 26, $0 cost sharing for preventive care services, unlimited lifetime benefits and the elimination of coverage for non-prescription medicine under FSA plans are some of the mandates generally in effect for plans now. A number of the law's provisions, as we summarize below, are just now beginning to go into effect and are generating many questions and/or need to be addressed in the near future.
June 2011
COBRA Reimbursement for New Hires
From time to time a client will inquire about ways to provide health coverage to certain newly hired employees while the new hires are in the client's plan's "waiting period." One way to do this is to pay for the new employee's COBRA coverage until they become eligible to join the company's plan.
May 2011
Reporting the Cost of Health Care Coverage on the W-2 Effective for 2012 for Large Employers
According to a new IRS Notice "Large Employers" will be responsible to report the cost of their health plans on W-2's beginning next year.
January 2011
Massachusetts Fair Share Filing Reminder: February 15th
By now you probably have received a notice from the Massachusetts Division of Unemployment Assistance (DUA) regarding the requirements to complete the "Fair Share Contribution" (FSC) filing online report. For those employers who have been filing quarterly during 2010, this is one more quarterly report. For those who have not been required to file quarterly, this is an annual report required to be filed by February 15, 2011. (The period you will be reporting on is October 1, 2009 - September 30, 2010).
December 2010
Employer Notice Requirement
Children's Health Insurance Program
Employers sponsoring group health plans are required to advise employees of potential opportunities to qualify for a subsidy, through Medicaid in the state in which they live via the Children's Health Insurance Program (CHIP), to help them pay for employer sponsored health insurance.
December 2010
2010 End of Year Action Items
Summit Benefit Solutions
It certainly has been a tumultuous year for those who deal with employee benefits, as characterized by the passage of the mammoth Patient Protection and Affordable Care Act. While we are always looking at the larger picture, we want to make sure to keep up with the more routine items that need to be performed annually at year end.
October 2010
Medicare Part D Notice Information
November 15th Deadline Approaching
Group health plan sponsors offering prescription drug coverage must provide annual notices of creditable or non-creditable prescription drug coverage by November 15th each year.
October 2010
New White Paper Available
Updated October 2010 National Healthcare Reform Review
October 2010
W-2 Health Plan Cost Reporting Relief
Notice 2010-69
This notice provides interim relief to employers with respect to reporting the cost of coverage under an employer-sponsored group health plan on Form W-2.
July 2010
More Healthcare Regulations Issued
Preventive & Wellness Services
Federal agencies issued regulations on July 14th outlining the preventive & wellness benefits that must be covered on a "1st dollar" basis.
May 2010
IRS Liberalization of Dependent Taxation
In a ruling dealing with the child coverage extension contained in the new federal health law, the Internal Revenue Service has announced a liberalization of tax laws as they pertain to older covered children.
May 2010
New Department of Labor Notice Requirements
The Children's Health Insurance Program Reauthorization Act of 2009 (CHIPRA) has added new notice and disclosure obligations for employers
July 2011
Alternative Minimum Tax (AMT)
Summit Financial Strategies Tax Insight
The "Alternative Minimum Tax (AMT)" and how it may apply to you.
June 2011
Calculating NUA
Summit Financial Strategies Tax Insight
Examining "Net Unrealized Appreciation" of Employer Securities.
October 2010
New White Paper Available
2010 Small Business Jobs Act
A wide range of tax breaks and incentives are now available for the small business as a result of the recently enacted 2010 Small Business Jobs Act. Read about what tax changes in the new law your business can benefit from.
July 2010
2010 Federal Tax Developments
Q1 2010 Update
The first quarter of 2010 brought many tax developments from Congress, the IRS and the courts. The following are some of these important federal tax developments below.
July 2010
New White Paper Available
Dealing with Health Care Reform's New Regulations
The materials created through August 2011 are when the professionals of Summit Financial were with Ogilvie Security Advisors Corp. The professionals of Summit Financial have not been with Ogilvie Security Advisors Corp. since August 31, 2011 and have no further affiliation with that organization.
