Today's Update

IRS Guidance

Proposed Regulations on Withholding on Periodic and Non-periodic Payments

Document Excerpt This document contains a proposed regulation regarding withholding on certain periodic and nonperiodic distributions under section 3405, other than eligible rollover distributions. This regulation would affect payors and payees of these distributions. Link

Inflation Adjusted HSA Limits for 2020

Document Excerpt This revenue procedure provides the 2020 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under § 223 of the Internal Revenue Code. Link

IRS Regulatory Agenda, Spring 2019

Document Excerpt Link

Request for Comments on Revisions to Form 5500EZ

Document Excerpt SUMMARY: The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning the Annual Return/Report of […]

2019 Operational Compliance List

Document Excerpt The Operational Compliance List (“OC” List) is provided per Rev. Proc. 2016-37, Section 10, to help plan sponsors and practitioners achieve operational compliance by identifying changes in qualification requirements effective during a calendar year. The OC List: Identifies matters that may involve either mandatory or discretionary plan amendments depending on the particular plan. […]

Temporary Expansion of Determination Letter Program

Document Excerpt This revenue procedure, consistent with the process described in Rev. Proc. 2016-37, 2016-29 I.R.B. 136, provides for a limited expansion of the determination letter program with respect to individually designed plans. Under this limited expansion, the Internal Revenue Service (IRS) will accept determination letter applications for (i) individually designed statutory hybrid plans during […]

DOL Guidance

Electronic Filing of Notices for Apprenticeship and Training Plans and Statements for Top Hat Plans

Document Excerpt SUMMARY: This document contains final regulations that revise the procedures for filing apprenticeship and training plan notices and “top hat” plan statements with the Secretary of Labor. The final regulations require electronic submission of these notices and statements, as opposed to paper filings. The final regulations will make filing these notices and statements […]

Individual Coverage HRA Model Attestations

Document Excerpt The Departments of the Treasury, Labor, and Health and Human Services (the Departments) have issued final regulations allowing plan sponsors to offer individual coverage health reimbursement arrangements (HRAs), subject to certain requirements. Link

Model Individual Coverage HRA Notice

Document Excerpt Individual coverage HRAs may use this model notice to satisfy the notice requirement. To use this model notice properly, the HRA must provide information specific to the HRA (indicated with italicized prompts in brackets). The HRA may modify the notice based on the terms of the particular HRA. For example, if the HRA […]

FAQs on Integrating Health Reimbursement Accounts with other Coverage

Document Excerpt The new rules also increase flexibility in employer-sponsored insurance by creating another, limited kind of HRA that can be offered in addition to a traditional group health plan. These “Excepted Benefit HRAs” permit employers to finance additional medical care (for example to help cover the cost of copays, deductibles, or other expenses not […]

Final Rule on Health Reimbursement Accounts and other Account Plans

Document Excerpt SUMMARY: This document sets forth final rules to expand opportunities for working men and women and their families to access affordable, quality healthcare through changes to rules under various provisions of the Public Health Service Act (PHS Act), the Employee Retirement Income Security Act (ERISA), and the Internal Revenue Code (Code) regarding health […]

SEC Interpretation of “Solely Incidental” Prong Exclusion for Broker-Dealers

Document Excerpt Link

PBGC Guidance

PBGC Regulatory Agenda, Spring 2019

Document Excerpt Link

PBGC Updates Reportable Events & Large Unpaid Contributions Page

Document Excerpt Section 4043 of ERISA requires that plan administrators and sponsors notify PBGC of the occurrence of certain events that may signal problems with a pension plan or business. PBGC’s regulation on reportable events and large cumulative funding underpayments describes the events and notice requirements in detail (see 29 CFR Part 4043). In most […]

Coverage Determination Changes or Status Request Form

Document Excerpt SUMMARY: The Pension Benefit Guaranty Corporation (PBGC) is requesting that the Office of Management and Budget (OMB) approve, under the Paperwork Reduction Act, a collection of information necessary for PBGC to determine whether a plan is covered under title IV of the Employee Retirement Security Income Act of 1974. This notice informs the […]

Terminated and Insolvent Multiemployer Plans

Document Excerpt SUMMARY: The Pension Benefit Guaranty Corporation is amending its multiemployer reporting, disclosure, and valuation regulations to reduce the number of actuarial valuations required for smaller plans terminated by mass withdrawal, add a valuation filing requirement and a withdrawal liability reporting requirement for certain terminated plans and insolvent plans, remove certain insolvency notice and […]

PBGC Offers Pre-Filing Consultation for ERISA Section 4010 Filers

Document Excerpt PBGC staff is available to help filers, especially first-time filers, understand the filing requirements. During a pre-filing consultation, we will provide an overview of the process, share helpful tips on how to use the e-filing software and how to avoid common errors. To schedule a pre-filing consultation, email or call (202) 326-4000 […]

March Interest Rate Summary

Document Excerpt The purpose of this summary is to provide, in one place, a summary of current interest rates that relate to various calculations required under Title IV of ERISA. PBGC posts this summary each month, as soon as all of the new information is available. Rate‑specific webpages containing additional information about and historical data […]

Articles, White Papers & Other Information

Proposed Revised ACA Nondiscrimination Regulations

Document Excerpt SUMMARY: The Department of Health and Human Services (“the Department”) is committed to ensuring the civil rights of all individuals who access or seek to access health programs or activities of covered entities under Section 1557 of the Patient Protection and Affordable Care Act. The Department proposes to revise its Section 1557 regulation […]

SEC Interpretation of “Solely Incidental” Prong Exclusion for Broker-Dealers

Document Excerpt Link

SEC Interpretation of Standard of Care of Investment Advisers under Investment Advisers Act

Document Excerpt SUMMARY: The Securities and Exchange Commission (the “SEC” or the “Commission”) is publishing an interpretation of the standard of conduct for investment advisers under the Investment Advisers Act of 1940 (the “Advisers Act” or the “Act”). Link

SEC Best Interest Regulation

Document Excerpt SUMMARY: The Securities and Exchange Commission (the “Commission”) is adopting a new rule under the Securities Exchange Act of 1934 (“Exchange Act”), establishing a standard of conduct for broker-dealers and natural persons who are associated persons of a broker-dealer (unless otherwise indicated, together referred to as “broker-dealer”) when they make a recommendation to […]

White House Announces Approach To Prohibit Surprise Medical Billing

Document Excerpt he Administration wants to ensure patients are not price gouged in emergency situations by out-of-network providers they could not choose. In emergency situations, balance billing for amounts above the in-network allowed amount should be prohibited. The Administration wants to bring transparency to the confusing and opaque pricing system patients face when scheduling care. […]

Regulations on Health Care Providers Objecting to certain Procedures such as Abortions

Document Excerpt Link

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