Author: Kristina Ferris Salamoun

Kristina F. Salamoun counsels clients who provide qualified health and retirement plans on plan design and administration. Kristina assists benefit plan clients with compliance with ERISA, the Internal Revenue Code and other applicable laws, including COBRA, HIPAA, PPACA and SECURE Act. She advises plan sponsors and administrators on fiduciary matters and various government reporting and filing requirements. Kristina also negotiates and reviews service-provider contracts for employee benefit plans and drafts key documents such as summary plan descriptions, plan and trust amendments, and plan policies. In addition, she manages client responses to government investigations, and provides advice on the review of qualified domestic relations orders (QDROs), power of attorney documents, subpoenas and subrogation matters.

DOL Lost & Found Database for Retirement Savings Goes Live

If you have ever found $10 in the pocket of a coat that you have not worn for some time, you are familiar with the delight of finding lost money that belongs to you. The Department of Labor’s new Retirement Savings Lost & Found Database (Database) seeks to recreate that feeling in the employee benefits realm by reuniting missing participants and beneficiaries with benefits they may have accrued under job-based retirement plans.

The importance of locating missing participants

Taking steps to find participants and beneficiaries who may be owed a benefit is important to companies that sponsor retirement plans for several reasons.

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PBGC Issues Technical Update on Accelerated Due Date for 2025 Premium Filings

The Pension Benefit Guaranty Corporation (PBGC) has issued its first technical update of the year to provide guidance on the accelerated premium filing date for plan years that begin in 2025.

As required by a provision in the Bipartisan Budget Act of 2015, for plan years that begin in 2025, the PBGC premium filing due date for all plans is the 15^th day of the 9^th calendar month that begins on or after the first day of the plan year. This is a change from the normal due date under the PBGC regulations, which is the 15^th day of the 10^th calendar month that begins on or after the first day of the plan year. The provision also supersedes the special due dates that typically apply for certain new plans and plans that complete a standard termination before the normal premium due date.

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Final Regulations Issued on Required Minimum Distributions Under SECURE Act

The Internal Revenue Service (IRS) has issued final regulations for required minimum distributions (RMDs) from certain retirement plans, including tax-qualified plans, Internal Revenue Code (Code) section 403(b) plans, individual retirement accounts (IRAs) and Code section 457(b) eligible deferred compensation plans. The regulations implement changes put into law by the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the SECURE 2.0 Act of 2022 (SECURE 2.0).

The final regulations apply for distribution calendar years beginning on or after January 1, 2025. However, as some of the RMD changes addressed in the final regulations already have taken effect in accordance with the effective dates set forth in the SECURE Act and SECURE 2.0, plan sponsors should review current plan operations for compliance.

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