On March 17, the American Retirement Association submitted a letter to the Internal Revenue Service (IRS) recommending the Service provide additional guidance. Specifically, the ARA encouraged the IRS to amend the Proposed Rule to: (1) extend the deadline for post-transaction plan mergers beyond the end of the special transition period under IRC §410(b)(6)(C)(ii) for purposes...
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 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 February 20, 2024, the American Retirement Association submitted a comment letter in response to Notice 2024-02 asking the IRS to provide guidance on the eligible automatic enrollment arrangement (EACA) mandate, permit de minimis financial incentives for all employees who make deferral elections (regardless of whether they have a deferral election already have a deferral...
On January 26, the American Retirement Association submitted a comment letter to the Internal Revenue Service making several recommendations that would reduce costs for plan sponsors and also clarify several confusing provisions. (more…)
On December 15, 2023, the American Retirement Association submitted comments to the Internal Revenue Service requesting that they formally revoke Section 4 of the Ruling. Revocation of Section 4 will help advance SECURE 2.0’s policy objectives, facilitate compliance with long-term, part-time employee rules, and improve economic efficiency by reducing the complexity and burdens of the...
On November 29, 2023, the American Retirement Association wrote to the Internal Revenue Service to ask for a delay in the application and enforcement of proposed long-term, part-time employee rules for cash or deferred arrangements under Section 401(k). (more…)
On October 24, 2023, the American Retirement Association wrote to the Internal Revenue Service to comment on Notice 2023-62 that granted a two-year transition period to comply with Section 603 of the SECURE 2.0 Act. (more…)
On August 23, 2023, the American Retirement Association wrote to the Internal Revenue Service to provide comments on the expansion of the Employee Plan Compliance Resolution System (EPCRS) included in Section 305 of the SECURE 2.0 Act. (more…)
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