On March 14, the American Retirement Association submitted a letter to the Internal Revenue Service supporting the issuance of guidance on catch-up contributions. Specifically, the ARA supports guidance that would permit an employer that is part of a controlled group or affiliated service group to aggregate compensation across multiple entities for purposes of determining whether...
On December 20, 2024, the American Retirement Association submitted a letter regarding Internal Revenue Service Notice 2024-73 (the “Notice”), which provides additional guidance with respect to long-term, part-time employee (LTPTE) rules, including guidance regarding the application of IRC § 403(b)(12) to LTPTEs under section 403(b) plans.in support of the Retirement Fairness for Charities and Educational...
On December 16, 2024, the American Retirement Association submitted a comment letter on Internal Revenue Service Notice 2024-77 (the “Notice”), which provides guidance with respect to inadvertent benefit overpayments. (more…)
On October 18, the ARA submitted comments to the Internal Revenue Service (IRS) recommending the Service issue guidance on qualified student loan payments (QSLPs). Specifically, the ARA encouraged the IRS to allow for plans to calculate all matching contributions on a payroll period basis, confirm that a plan may match QSLPs throughout the year without...
On October 7, the ARA submitted comments to the Internal Revenue Service (IRS) recommending that the Service clarify recently issued guidance related to several provisions enacted by the SECURE 2.0 Act. Specifically, the ARA’s comments encouraged the Service to provide anti-cutback relief to permit the elimination of EPED and DAVD provisions, allow administrators to rely...
On September 17, 2024, the American Retirement Association submitted a letter on the Notice of Proposed Rulemaking regarding required minimum distributions (“RMDs”) published in the Federal Register on July 19, 2024, and referenced above (the “Proposed Regulation”). (more…)
On July 16, the ARA submitted comments to the Department of Labor (DOL) applauding their decision to expand the Abandoned Plan Program to provide for a more effective and efficient procedure for Chapter 7 trustees to terminate plans of bankrupt plan sponsors. While the ARA generally supports the requirements of the Rule, the ARA’s comments...
On June 17, the ARA submitted comments to the Department of Labor strongly encouraging the Department to continue its work modernizing the Retirement Savings Lost and Found. Specifically, the ARA asked the Department to provide a useful database with robust and accurate data that American workers can use to locate their retirement savings, noting that...
On May 31, the ARA submitted comments to the IRS providing input on the retirement benefits items included in the 2024-2025 Priority Guidance Plan. Specifically, the ARA requested the IRS to issue guidance on several SECURE and SECURE 2.0 Act to provide much needed clarity on catch-up contributions, automatic enrollment, top heavy exemptions, long-term part-time...
On May 22, the ARA submitted comments to the DOL encouraging them to simplify the reporting process so that it is less burdensome and expensive for the reporting parties. Specifically, these comments encourage reporting agencies to ensure that any reporting requirements are narrowly tailored to promote accurate reporting and generally limit the breadth of reporting...
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