Department of Labor Update
|
|
- Pamela Flynn
- 5 years ago
- Views:
Transcription
1 Department of Labor Update Ian Dingwall, CPA Chief Accountant Employee Benefits Security Administration The views expressed are those of the speaker and do not necessarily represent the official position of the Department Regulatory Developments Timeliness of Participant Contributions COBRA Subsidy Under ARRA Multiemployer Plan Notices Disclosures and Penalties Under 502 (c)(4) Access to Investment Advice Penalties for Not Adopting a Funding Improvement Plan Under 502 (c)(8) 403(b) Plan Related FABs and TIAA-CREF Advisory Opinion Fee Disclosure Initiatives 1
2 Timely Remittance of Participant Contributions Remains an Enforcement Initiative for EBSA Participant contributions are plan assets on the earliest date that they can reasonably be segregated from the employer's general assets. In no event later than: for pension plans, the 15th business day of the month following the month in which the participant contributions are withheld or received by the employer for welfare plans, 90 days from the date on which such amounts are withheld or received by the employer. Untimely remittance of participant contributions is a prohibited transaction (regardless of financial materiality) and may constitute embezzlement of plan assets. Such information may be required to be presented in a supplemental schedule attached to the Form 5500 Timely Remittance of Participant Contributions Remains an Enforcement Initiative for EBSA Failure to timely remit participant contributions represents a control deficiency that may require a management letter pursuant to Statement on Auditing Standards No. 112, Communicating Internal Control Related Matters Identified in an Audit. FAQs providing guidance regarding the reporting of delinquent participant contributions may be found at Further information is available through the DOL s Office of Regulations and Interpretations at (202) Form 5500 has new supplemental schedule disclosure format. See instructions for line 4a, Schedule H and I. 2
3 Safe Harbor for Employee Contributions to Small Pension and Welfare Plans Final rule issued on January 14, The final rule, unchanged from the proposed rule, creates a safe harbor period under which participant contributions to a small plan will be deemed to be made in compliance with the law if those amounts are deposited with the plan within seven business days of receipt or withholding. The Department did not expand the safe harbor to cover plans with 100 or more participants due to a lack of information and data sufficient to evaluate current practices of such employers and assess the costs, benefits and risks to participants associated with extending the safe harbor to large plans. The final rule may be viewed at under Final Rules. Department of Labor Dedicated COBRA Web Site Dedicated Web site to help understand the COBRA stimulus provisions under the American Recovery and Reinvestment Act of 2009 (ARRA). The IRS also has a COBRA website. Eligible individuals pay only 35 percent of their COBRA premiums and the remaining 65 percent is reimbursed to the coverage provider through a tax credit. Individuals must experience a COBRA qualifying event and must have occurred between September 1, 2008 and March 31, The premium reduction applies to periods of health coverage that began on or after February 17, 2009 (and lasts for up to 15 months). Information on the DOL s responsibilities relating to the COBRA provisions may be viewed at 3
4 Final Rule on Multiemployer Pension Plan Information Made Available on Request Published in the Federal Register on March 2, 2010 Designed to ensure that workers have greater access to information about the operation and financial health of their multiemployer defined benefit and defined contribution pension plans. The Pension Protection Act (PPA) amended ERISA - adding a new section 101(k) to increase transparency with respect to multiemployer retirement plan operations. The documents that are required to be furnished are: Periodic actuarial reports. Quarterly, semi-annual, or annual financial reports. Certain applications filed with the Secretary of the Treasury and related determinations (amortization extensions). Final Rule on Multiemployer Pension Plan Information Made Available on Request A plan administrator must furnish the requested documents within 30 days from the request. The Secretary of Labor may assess a civil penalty against any person of up to $1,000 a day under 502 (c) (4) for each violation of section 101(k). A plan is not required to provide more than one copy of any document during any one 12-month period and may impose a reasonable charge on the requester to cover the cost of copying and mailing a document. The final rule became effective on April 1, The final rule and a related fact sheet may be viewed at: 4
5 Proposed Rule Regarding Investment Advice The proposed regulation allows investment advice to be given under the statutory exemption in two ways: One is through the use of a computer model certified as unbiased. The other way is through an adviser compensated on a "level-fee" basis (i.e., fees do not vary based on investments selected by the participant). Other requirements include disclosure of fees the adviser is to receive. The regulation contains some key safeguards and conditions, including: Establishing an annual audit of investment advice arrangements, including the requirement that the auditor be independent from the investment advice provider. Requiring disclosures by advisers to plan participants. The proposed regulation and a related fact sheet may be viewed at Multiemployer DB Pension Plans that Fail to Take Corrective Funding Action under 502(c)(8) Final rule published on February 26, Civil penalties against sponsors of multiemployer defined benefit pension plans that fail to adopt a funding improvement or rehabilitation plan in accordance with section 502(c)(8) of ERISA, as amended by the Pension Protection Act (PPA). PPA requires plans certified to be in endangered or critical status to adopt a funding improvement plan or a rehabilitation plan within 240 days from the required date of the certification. The PPA provides for civil monetary penalties of up to $1,100 per day against plan sponsors that fail to timely adopt funding improvement or rehabilitation plans. The proposed regulation may be found at under Proposed Rules. 5
6 Field Assistance Bulletins on Annual Reporting by 403(b) Plans In 2007, ERISA s annual reporting rules changed - to require that employers with IRC 403(b) retirement plans covered by ERISA comply, starting in 2009, with the same financial reporting rules that apply to 401(k) plans. The Department has issued three field assistance bulletins to provide plan administrators with guidance regarding how to comply with the new reporting requirements for 403(b) plans. On July 24, 2007, the Department issued Field Assistance Bulletin (FAB) to how the IRS regulations governing 403(b) tax-sheltered annuity programs affect the status of such programs under the Department s safe harbor regulation at 29 C.F.R (f). Field Assistance Bulletins on Annual Reporting by 403(b) Plans Field Assistance Bulletin (FAB) Provides guidance on transition relief from new requirements for 403(b) Plans for Form 5500 annual reporting of information on certain individual annuity contracts. Contracts must be with current and former employees that were entered into before 2009 and for which the employer has no ongoing contribution obligation. Plan administrators must make a good faith effort to comply with applicable annual reporting requirements for the 2009 plan year. 6
7 Field Assistance Bulletins on Annual Reporting by 403(b) Plans Field Assistance Bulletin (FAB) Presented as FAQs, addresses the scope of the relief provided in FAB , and the safe harbor regulation at 29 CFR (f). The Internal Revenue Service (IRS) has issued separate transition relief for 403(b) plans. This FAB complements the IRS transition relief. The FABs may be viewed at the Department s dedicated Web site for 403(b) plan guidance: Department of Labor Advisory Opinion - TIAA-CREF Traditional Annuity Contract Advisory Opinion A on March 4, 2010 TIAA-CREF had asked whether the TIAA Traditional Annuity is a fully allocated contract for annual reporting purposes within the meaning of 29 C.F.R (b)(2) and the Form 5500 Instructions. Department views the Traditional Annuity as not meeting the requirements of a fully allocated contract within the meaning of 29 C.F.R (b)(2). These contracts will now be reported on Form 5500, Schedules H and I and be subject to the scrutiny of an independent audit. 7
8 Department of Labor Advisory Opinion TIAA-CREF Traditional Annuity Contract The Department will not reject a plan s Form 5500 Annual Return/Report or require an amended Form 5500 Annual Return/Report for 2008 and prior plan years solely for failure to report the TIAA Traditional Annuity on Schedules H or I as an unallocated insurance contract, or for failure to treat the Traditional Annuity as an unallocated insurance contract for purposes of the Schedule A or an IQPA s audit of the plan. In addition, the Department also will not reject a Form 5500 for 2008 and prior plan years on the basis of a qualified, adverse, or disclaimed IQPA opinion if the reason for such a qualified or adverse opinion or disclaimer of opinion was because the Traditional Annuity was treated as an allocated insurance contract for purposes of the IQPA audit and the plan s financial statements. For plan years beginning on or after January 1, 2009, however, the Traditional Annuity cannot be treated as an allocated contract within the meaning of 29 C.F.R (b)(2) and the Form 5500 Instructions. Department of Labor s Fee Disclosure Initiatives The Department has initiated three regulatory initiatives to improve fee disclosure and transparency The centerpiece of the proposed regulation is a requirement to provide investment-related information in a comparative chart or similar format. The Department has developed a model chart for complying with this requirement, while giving plan fiduciaries the flexibility to design their own charts or comparative formats. The chart is available on the Department s Web site at 8
9 Expanded Disclosures Aimed at Informed Decision Making and Excessive Fees Disclosures to plan fiduciaries to assist in assessing 408(b)(2) reasonableness of compensation and potential conflicts of interest-(proposed 12/13/07- Interim Final) Disclosures to public and government on electronically filed Form 5500 Annual Report including indirect compensation (Schedule C)-(Final) Quarterly disclosures by plans to participants, to assist in making investment decisions (A Condition of 404 (c) Relief- Proposed 07/23/08) EFAST2 and the New Form
10 E-Filing Regulation November Amended final regulation published Requires e-filing for plan years beginning on or after January 1, 2009 E-file mandate needed for move to EFAST2 - fully electronic filing & processing system Most form changes also delayed to 2009 filings PPA related changes phased in earlier. Move to EFAST2 EFAST2 secure web portal filing system. Free DOL website-based filing option Third-party value added software filing option EFAST2 will: help reduce filing errors. make annual report information available sooner to agencies and public. continue help desk support to filers. 10
11 Move to EFAST2 Further technical guidance on EFAST2 filing requirements will be provided as system experience is developed. EFAST to shut down after transition to EFAST2. Expect guidance in Instructions, DFVC Program, and elsewhere to assist with transition. Electronic Filing Mandate All Form 5500 and Form 5500-SF must be submitted through EFAST2 This includes plan year 2007 and prior returns/reports. (EFAST2 FAQ #4) Form 5500 filings may be submitted on paper through EFAST. 11
12 EFAST2 FAQ #4 EFAST2 FAQs can be found at: Question 4: How can I submit a delinquent or amended Form 5500 return/report for a Title I plan for years prior to 2009 once the EFAST2 system is available? Electronic Filing with EFAST2 Two ways to create & submit filings: 3 rd Party Certified Software IFILE (free web-based filing application) Combinations OK List of approved third party software is posted on 12
13 EFAST2 Help EFAST2 website at FAQs Users guides Web-based tutorial Staffed help desk at GO-EFAST during business hours Third party software certification & support Using EFAST2 Register for credentials Create a filing Check the filing for errors Sign the filing Submit the filing and check the status View filings on our website 13
14 Register Now for Credentials All plan sponsors & administrators must register for credentials to sign filings (Filing Signer role) Anyone wishing to fill out the forms/schedules through ifile must register for credentials to author (Filing Author or Schedule Author role) Anyone wishing to transmit completed filings through third party software MAY need to register for credentials (Transmitter role) Actuaries and accountants do not need to register but may do so if they wish. You can not use EFAST ELF credentials for EFAST2 Summary of Steps to Register Go to and click Register Enter contact information and select role Check your (and spam folder) for a message from EFAST2 Click on the link in the EFAST2 message to complete your registration Keep track of your UserID and password 14
15 Registration Tips Use your business address when registering, rather than your personal address. Check your spam folder if you do not receive the EFAST2 within 5 minutes. You can change your address (including ), phone number, PIN, Password, and roles at any time. Login to the website and click User Profile. You can not modify the UserID or secret knowledge (place or date of birth). Your Personal Identification Number (PIN) is personal and not to be shared. EFAST Contacts for Helpful Information EFAST Website ( Information Copies of Forms & Instructions List of Approved Software Vendors FAQs EFAST Help Line ( ) Questions on Forms or Instructions Confirm Filings Received Contact EBSA, IRS & PBGC Technical Assistance 15
16 2009 Form 5500 Revisions Facilitate move to fully electronic filing system. Streamline and simplify small plan filing. Better disclosure on plan fees & expenses. Adopt Pension Protection Act (PPA) reporting changes. New Schedule C Reporting Identify each service provider who received $5,000 or more in compensation (direct & indirect). Includes new codes describing services & types of compensation Report total direct compensation paid by plan separately from total indirect compensation received by provider. Prior rule requiring plan to identify only top 40 highest paid service providers is eliminated. 16
17 New Schedule C Reporting For Key service providers, must also identify persons from whom provider received $1,000 or more in indirect comp. Non-monetary comp (gifts, trips, meals, etc.) included, subject to a de minimis exception Alternative Reporting Option for Eligible Indirect Compensation Only certain types of indirect comp eligible Disclosure requirements Other Fee & Schedule C Issues Bundled fee arrangements. Insurance benefit contracts. Service providers who fail to provide necessary Information. Report of terminated accountants/enrolled actuaries. Small plan fee reporting rules. Audit implications-sas 8 40 FAQs on 17
18 Small Plan Fee and Expense Reporting Schedule I filers not subject to Schedule C indirect compensation reporting rules. Must break out fees on Schedule I paid directly by plan to administrative service providers. Small plans filing Schedule A must still report information on insurance fees and commissions. Short Form has questions on direct comp paid by plan and insurance fees & commissions. Reporting by 403(b) Plans 403(b) plans treated like 401(k) plans for reporting purposes. Applies only to Title I 403(b) plans DOL safe harbor for voluntary tax sheltered annuities still available. FAB Audit requirement applies for large 403(b) plans Small plan 80 to 120 rule also applies. 18
19 2009 Audit Focus Areas Fraud Contributions Failure to Audit Investment Fair Values 157 Disclosures Benefit Payments Participant Data Increased Fraud Risks in the Current EBP Environment Current economic conditions Unexpected losses Employee furloughs and layoffs (plan sponsors and administrators) Financing and liquidity difficulties Curtailed or suspended benefits Opportunities and incentives to commit fraud 19
20 Types of Fraud Types of fraud: Fraudulent financial reporting Misappropriation of assets Source: AICPA Fraud Risk Factors Specific to Employee Benefit Plans EBP Fraud Conditions Three conditions generally present when fraud exists: 1. Incentive/pressure to perpetrate fraud 2. Opportunity to carry out the fraud 3. Attitude/rationalization to justify the fraudulent action Source: AICPA Fraud Risk Factors Specific to Employee Benefit Plans 20
21 Conducting Fraud Brainstorming Sessions Discuss how and where the plan s financial statements might be susceptible to material misstatement due to fraud Who should participate? When should the brainstorm be conducted? Who to ask in plan management? Brainstorming Do s and Don'ts Don t Only have a mass brainstorming session Conduct session without partner involvement Get input from only the audit partner and manager Come into the meeting without current year planning information Let past experience with client sway you to overlooking risks Conduct a session customized to each specific engagement Do Use all audit team members and invite new ideas from all Have examples of what could go wrong and discuss what we know or don t know As about the impact of current economy on this specific client Be professionally skeptical 21
22 Contributions No work performed (Where was documentation?) Insufficient work regarding contributing employers Failure to test payroll internal controls Failure to test elective deferrals No payroll testing Failure to Audit Investments at Fair Value Failure to test year end asset values No evidence of work performed Failure to test investment transactions Failure to obtain certification from an eligible entity Failure to test participant loans Inappropriate reliance on SAS 70 22
23 FAS 157 Disclosures Requires assets to be disclosed in one of three valuation levels Plan administrators, not auditors, determine fair value of plan assets Limited-scope certifications may/may not reflect fair values of assets Circumstances may dictate performing a full scope audit Benefit Payments No audit work performed Failure to test eligibility to receive benefits No audit program Inappropriate reliance on SAS 70 23
24 Participant Data No audit work performed (Where was documentation?) Failure to adequately test payroll data. Failure to adequately test eligibility, terminations and/or forfeitures. Are the proper people participating in the plan? Questions 24
Instructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2015 Instructions for Form 5500-SF Short Form Annual
More informationInstructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2016 Instructions for Form 5500-SF Short Form Annual
More informationUpdates to Peer Reviews of EBP Audits, including 403(b) Plan Considerations
Updates to Peer Reviews of EBP Audits, including 403(b) Plan Considerations June 22, 2011 Presenters Moderator Marilee Lau, retired partner KPMG LLP; Marilee Lau, CPA Part 1 Bob Lavenberg, Chair, AICPA
More informationInstructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2012 Instructions for Form 5500-SF Short Form Annual
More informationInstructions for Form 5500 Annual Return/Report of Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2012 Instructions for Form 5500 Annual Return/Report
More informationInstructions for Form 5500-SF
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2009 Instructions for Form 5500-SF Short Form Annual
More informationQ & A on Forms 5500: New Mandatory Electronic Filing Requirements
Q & A on Forms 5500: New Mandatory Electronic Filing Requirements Developed from Conner Strong s web briefing of June 29, 2010 On June 29, Conner Strong held a web briefing on the Form 5500 annual report
More informationInstructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2017 Instructions for Form 5500-SF Short Form Annual
More informationInstructions for Form 5500 Annual Return/Report of Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2010 Instructions for Form 5500 Annual Return/Report
More informationInstructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2010 Instructions for Form 5500-SF Short Form Annual
More informationInstructions for Form 5500 Annual Return/Report of Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2010 Instructions for Form 5500 Annual Return/Report
More informationInstructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2010 Instructions for Form 5500-SF Short Form Annual
More informationDOL & IRS CORRECTION PROGRAMS
Session 2 DOL & IRS CORRECTION PROGRAMS Eric Ernest, CPA Partner Page 26 Objectives This session will provide an overview of the regulatory environment for employee benefit plans and cover: Plan Regulatory
More informationInstructions for Form 5500 Annual Return/Report of Employee Benefit Plan
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2017 Instructions for Form 5500 Annual Return/Report
More information2012 MACPA EMPLOYEE BENEFIT PLANS CONFERENCE MAY 8, 2012 Department of Labor Update
2012 MACPA EMPLOYEE BENEFIT PLANS CONFERENCE MAY 8, 2012 Department of Labor Update 1 Marcus J. Aron Senior Auditor Office of the Chief Accountant Employee Benefits Security Administration The views expressed
More informationReporting and Disclosure Guide for Employee Benefit Plans
Reporting and Disclosure Guide for Employee Benefit Plans This publication is available on the Internet at: www.dol.gov/ebsa For a complete list of EBSA publications, call toll-free: 1-866-444-EBSA (3272)
More informationEFAST 2 - What you need to know April 22, 2009 Webinar Q&As ftwilliam.com
EFAST 2 - What you need to know April 22, 2009 Webinar Q&As ftwilliam.com NOTE: Since the broadcast of the webinar we have learned that DOL may be in the process of issuing FAQs on the EFAST system that
More informationWhat to Expect from an Employee Benefits Security Administration (EBSA) Investigation. Voluntary Fiduciary Correction Program.
What to Expect from an Employee Benefits Security Administration (EBSA) Investigation Voluntary Fiduciary Correction Program May 15, 2014 Miguel Paredes, Supervisory Investigator Thuy Pham, Benefits Advisor
More informationImportant Approaching Deadlines Please make note of these important approaching deadlines for calendar year plans:
Important Approaching Deadlines Please make note of these important approaching deadlines for calendar year plans: June 30, 2016: 6 months after plan year-end: Deadline for completion of corrective distributions
More informationDOL Update. Employee Benefit Plans Audit Conference May 6, 2013
Employee Benefit Plans Audit Conference May 6, 2013 MACPA DOL Update Michael E. Auerbach, CPA Chief, Division of Accounting Services Employee Benefits Security Administration The views expressed are those
More informationCPE. Advanced Auditing for Defined Contribution Retirement Plans
CPE Advanced Auditing for Defined Contribution Retirement Plans 1 Advanced Auditing for Defined Contribution Retirement Plans Chapter I/O Title Introduction and Overview 1 Defined Contribution Retirement
More informationDOL Update. WP&BC Portland Spring Seminar May 1, Marcus J. Aron, CPA Office of the Chief Accountant Employee Benefits Security Administration
WP&BC Portland Spring Seminar May 1, 2013 DOL Update Marcus J. Aron, CPA Office of the Chief Accountant Employee Benefits Security Administration The views expressed are those of the speaker and do not
More information403(b) Bulletin for Advisors and Consultants
403(b) Bulletin for Advisors and Consultants Tools and resources for assessing 403(b) plans Standard Retirement Services Introduction In 2009, significant changes were made to the 403(b) landscape. Plan
More informationInternal Revenue Service Tax Exempt & Government Entities Division Employee Plans
Internal Revenue Service Tax Exempt & Government Entities Division Employee Plans The IRS system of retirement plan correction programs, the Employee Plans Compliance Resolution System (EPCRS), helps employer
More informationDOL Update. Ginny Barker, CPA. Office of the Chief Accountant. Employee Benefits Security Administration
DOL Update Ginny Barker, CPA Office of the Chief Accountant Employee Benefits Security Administration The views expressed are those of the speaker and do not necessarily represent the official position
More informationA GUIDE FOR EMPLOYERS. Table of Contents. How will electronic filing of the Form 5500 (EFAST2) affect my plan?... 1
Table of Contents A GUIDE FOR EMPLOYERS How will electronic filing of the Form 5500 (EFAST2) affect my plan?... 1 When is the new electronic filing program effective?... 2 Do all retirement plans have
More informationImportant Approaching Deadlines
Important Approaching Deadlines Please make note of these important approaching deadlines for calendar year plans: September 15, 2016: 8 ½ months after plan year-end: For employers who filed corporate
More informationDOL Update. Michael E. Auerbach, CPA. Chief, Division of Accounting Services Employee Benefits Security Administration
MACPA DOL Update Michael E. Auerbach, CPA Chief, Division of Accounting Services Employee Benefits Security Administration The views expressed are those of the speaker and do not necessarily represent
More informationAon Hewitt Compliance Calendar - Significant Compensation and Benefit Due Dates for 2012
Aon Hewitt Compliance Calendar - Significant Compensation and Benefit Due Dates for 2012 January 2012 This Compliance Calendar assumes a plan administered on a calendar year basis by an employer with a
More informationEBSA Organizational Chart
What to Expect from a DOL - Employee Benefits Security Administration (EBSA) Investigation October 17, 2012 EBSA Organizational Chart Assistant Secretary Deputy Assistant Secretary for Program Operations
More informationEMPLOYEE BENEFIT PLAN AUDITS - CFO S RESPONSIBILITIES. Gary Broder, Bob Hamilton & Hosanna Custodio
EMPLOYEE BENEFIT PLAN AUDITS - CFO S RESPONSIBILITIES Gary Broder, Bob Hamilton & Hosanna Custodio What Every CFO Should Expect in the Annual Audit of Their Employee Benefit Plan 2 Generally, audit requirement
More informationFINAL 403(b) REGULATIONS ISSUED BY IRS
ADMINISTRATOR LIBRARY SERIES FINAL 403(b) REGULATIONS ISSUED BY IRS FOR ADMINISTRATOR USE ONLY. NOT FOR DISTRIBUTION TO EMPLOYEES. OVERVIEW In July 2007, the IRS finalized the regulations under Section
More informationCompliance Testing Sponsor User's Guide. Reference Material
Compliance Testing Sponsor User's Guide Reference Material Contents Chapter 1... 5 Introduction to Compliance Testing... 5 What is Compliance Testing?... 6 Using This Guide... 6 Conventions... 6 Screen
More informationSignificant Compensation and Benefit Due Dates for 2011 January 2011
Significant Compensation and Benefit Due Dates for 2011 January 2011 This compliance calendar assumes a plan administered on a calendar year-end basis by an employer with a calendar year-end fiscal year.
More information2019 Aon Compliance Calendar Significant Compensation and Benefit Due Dates. Prepared by Aon
2019 Aon Compliance Calendar Significant Compensation and Benefit Due Dates Prepared by Aon 2019 Aon Compliance Calendar Significant Compensation and Benefit Due Dates Aon is pleased to present its 2019
More informationMeeting Your Fiduciary Responsibilities
Meeting Your Fiduciary Responsibilities This publication is available on the Internet at: www.dol.gov/ebsa For a complete list of EBSA publications, call toll-free: 1-866-444-EBSA (3272) This material
More information401(K) PLAN ADMINISTRATION HOW TO HELP YOUR CLIENTS AVOID IRS AND DOL PENALTIES
401(K) PLAN ADMINISTRATION HOW TO HELP YOUR CLIENTS AVOID IRS AND DOL PENALTIES Sponsor Background Summit CPA Group Distributed Firm Employees Located Throughout the Country Audit Partner Kim Moore, CPA
More informationReporting and Disclosure Guide for Employee Benefit Plans. U.S. Department of Labor Employee Benefits Security Administration
Reporting and Disclosure Guide for Employee Benefit Plans U.S. Department of Labor Employee Benefits Security Administration This publication is available on the Internet at: www.dol.gov/ebsa For a complete
More informationJanuary 5, 2010 RE: NEW PAPERLESS FILING REQUIREMENTS FOR IRS FORM Dear Clients, Advisors and Support Personnel:
January 5, 2010 RE: NEW PAPERLESS FILING REQUIREMENTS FOR IRS FORM 5500 Dear Clients, Advisors and Support Personnel: We are writing to give you advance notice that beginning this year the Department of
More informationTroubleshooter s Guide to Filing the ERISA Annual Report (Form 5500) U.S. Department of Labor Pension and Welfare Benefits Administration
Troubleshooter s Guide to Filing the ERISA Annual Report (Form 5500) U.S. Department of Labor Pension and Welfare Benefits Administration This publication has been developed by the U.S. Department of Labor,
More information2018 Aon Compliance Calendar Significant Compensation and Benefit Due Dates
2018 Aon Compliance Calendar Significant Compensation and Benefit Due Dates Aon is pleased to present its 2018 Compliance Calendar to help plan sponsors identify significant compensation and benefit due
More informationHelping you fulfill your fiduciary duties
A Fiduciary Planning Guide for Plan Sponsors Helping you fulfill your fiduciary duties MassMutual s Regulatory Advisory Services 2016 Calendar Contents Defined Contribution Plans 2 January March 4 April
More informationEMPLOYER. Helping you fulfill your fiduciary duties. MassMutual s Regulatory Advisory Services 2019 Calendar for non-calendar year DC and DB plans
EMPLOYER Helping you fulfill your fiduciary duties MassMutual s Regulatory Advisory Services 2019 Calendar for non-calendar year DC and DB plans TABLE OF CONTENTS Defined Contribution Plans... 2 January
More informationDOL and IRS REPORTING and DISCLOSURE
DOL and IRS REPORTING and DISCLOSURE 1 Annual Funding Notices Required by Multiemployer DBPs under ERISA 101(f), as Amended by WRERA * Requires disclosure of value of assets and liabilities as of valuation
More informationAGENCY: Employee Benefits Security Administration, Department of Labor.
DEPARTMENT OF LABOR Employee Benefits Security Administration 29 CFR Part 2510 RIN 1210-AB02 Definition of Plan Assets Participant Contributions AGENCY: Employee Benefits Security Administration, Department
More information2014 Instructions for Schedule I (Form 5500) Financial Information Small Plan
2014 Instructions for Schedule I (Form 5500) Financial Information Small Plan General Instructions Who Must File Schedule I (Form 5500) must be attached to a Form 5500 filed for pension benefit plans and
More informationERISA Compliance FAQs: Reporting and Disclosure Rules
Brought to you by The Noble Group ERISA Compliance FAQs: Reporting and Disclosure Rules The Employee Retirement Income Security Act of 1974 (ERISA) is a federal law that sets minimum standards for employee
More informationForm 5500 Update. Janice M Wegesin, form5500help.com
Form 5500 Update Janice M Wegesin, form5500help.com New DOL Initiative Form 5500 For large retirement plan filers, matching them to welfare plan filings for same business Such missing/late filings may
More informationGetting it right. Know Your Fiduciary Responsibilities. The Employee Benefits Security Administration U.S. Department of Labor
The Employee Benefits Security Administration U.S. Department of Labor Getting it right Know Your Fiduciary Responsibilities A Compliance Assistance Program 1 Fiduciary Responsibility - Overview What is
More informationPresented by Travis P. Jack, CPA Metz & Associates, PLLC
Presented by Travis P. Jack, CPA Metz & Associates, PLLC » Qualified Plan Definition Technical definition: A Plan that satisfies the requirements of Internal Revenue Code Section 401(a) + Must satisfy
More informationSummary Plan Description (SPD) (See 29 CFR b-2) To: Participants and those pension plan beneficiaries receiving benefits
LIST OF PARTICIPANT DISCLOSURES The following list is loosely based on the list presented by Eugene Holmes of Proskauer Rose during an ABA teleconference on disclosure. The list below is more comprehensive
More informationguide to the census and 5500 reporting tools
guide to the census and 5500 reporting tools Use this document for assistance in completing your annual census and 5500-SF filing. Before getting started you will need: 1 Your User ID and Password for
More informationERISA Compliance FAQs: Reporting and Disclosure Rules
Provided by Brown & Brown Benefit Advisors ERISA Compliance FAQs: Reporting and Disclosure Rules The Employee Retirement Income Security Act of 1974 (ERISA) is a federal law that sets minimum standards
More informationEBPFAQ Introduction. Indiana Society of CPAs September 17, 2013 Concurrent Session 2: The EBP Market 2013 Address Common Questions
Indiana Society of CPAs September 17, 2013 Concurrent Session 2: Loscalzo s Frequently Asked Questions In Employee Benefit Plan Loscalzo s 2012 Accounting And Auditing Template for PowerPoint Slides A
More informationKeeping Your Organization s Retirement Plan in Shape: A Two-Part CAPLAW Webinar Series. Webinar One: Ins and Outs of Retirement Plan Audits
Keeping Your Organization s Retirement Plan in Shape: A Two-Part CAPLAW Webinar Series Webinar One: Ins and Outs of Retirement Plan Audits Trainer: Angie Whiteside, CPA, AIF, Senior Manager 1 Materials/Disclaimer
More informationGROOM LAW GROUP, CHARTERED
GROOM LAW GROUP, CHARTERED 2007 Employee Benefits Seminar Potpourri of Plan Communication Issues Presenters: Mark Lofgren (Moderator) Kendall Daines Liz Dold Anna Driggs Topics: PPA-Required Notices Benefit
More information2007 Form 5500 Schedule C Instructions 2011 >>>CLICK HERE<<<
2007 Form 5500 Schedule C Instructions 2011 C. Filing requirements regarding foreign corporations We discussed the Internal Revenue Service Form 5500-EZ with Joyce Kahn and Schedule SSA with until 2011
More informationFor Administrators of Multi Employer Pension and Welfare Plans under ERISA. This calendar reflects requirements as of January 1, 2007
For Administrators of Multi Employer Pension and Welfare under ERISA This calendar reflects requirements as of January 1, 2007 Introduction The 2007 Reporting Compliance Calendar for Administrators of
More informationNew law impacts multiemployer defined benefit plans
Important information Plan administration and operation New law impacts multiemployer defined benefit plans Who s affected These developments affect sponsors of and participants in qualified multiemployer
More informationDisclaimer WHAT TO EXPECT FROM AN EBSA INVESTIGATION OUTLINE OF PRESENTATION
WHAT TO EXPECT FROM AN EBSA INVESTIGATION United States Department of Labor Employee Benefits Security Administration Presented by Andy Cameron Senior Benefits Advisor, Seattle District Office Disclaimer
More information4/8/2010. Overview of the New 403(b) Regulations. Overview of 403(b) Issues
The New Regulatory Environment for Sponsors of 403(b) Plans 2003-2010 Multnomah Group, Inc. All rights reserved. Overview of 403(b) Issues Overview of the New Regulations Plan Operations: Universal Availability
More informationAttachment to Benefit News Briefs Frequently Asked Questions. Fiduciary Responsibilities under an Apprenticeship and Training Plan
Frequently Asked Questions Fiduciary Responsibilities under an Apprenticeship and Training Plan http://www.dol.gov/ebsa/faqs/faq-atp.html Table of Contents What Are The Essential Elements Of A Plan?...
More informationManaging Employer Fiduciary Issues for 401(k) and 403(b) Plan Sponsors in 2013
Managing Employer Fiduciary Issues for 401(k) and 403(b) Plan Sponsors in 2013 Presented by: Rose Panico-Marino, AIF, ERPA, QPA Senior Vice President January 30, 2013 Learning Objectives Review specific
More informationEmployee Benefits Security Administration. Voluntary Fiduciary Correction Program Workshop
Philadelphia Regional Office Employee Benefits Security Administration Voluntary Fiduciary Correction Program Workshop for Late Participant Deferrals and Loan Repayments Welcome Voluntary Fiduciary Correction
More informationAUTOMATIC ENROLLMENT 401(k) PLANS. for Small Businesses
AUTOMATIC ENROLLMENT 401(k) PLANS for Small Businesses Automatic Enrollment 401(k) Plans for Small Businesses is a joint project of the U.S. Department of Labor s Employee Benefits Security Administration
More informationAudit Engagement Letter a. [CPA Firm s Letterhead]
8 EBP 2/15 EBP-CL-1.1: Audit Engagement Letter a [CPA Firm s Letterhead] [Date] [Identify the body or individual(s) charged with governance.] and [Name of Management] b [Client s Name and Address] We are
More informationEmployee benefit plan large filers: Meeting your compliance and fiduciary requirements. April 20, 2016
Employee benefit plan large filers: Meeting your compliance and fiduciary requirements April 20, 2016 1 Your presenters Rose Ann Abraham, CPA Partner Baker Tilly 312 729 8086 roseann.abraham@bakertilly.com
More informationWhat to Expect from an Employee Benefits Security Administration (EBSA) Audit
What to Expect from an Employee Benefits Security Administration (EBSA) Audit Sherry Brackney Senior Benefits Advisor Cincinnati Regional Office The views expressed are those of the speaker & do not necessarily
More information401(k) PLANS. for Small Businesses
401(k) PLANS for Small Businesses 401(k) Plans for Small Businesses is a joint project of the U.S. Department of Labor s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service.
More information2017 Instructions for Schedule H (Form 5500) Financial Information
2017 Instructions for Schedule H (Form 5500) Financial Information General Instructions Who Must File Schedule H (Form 5500) must be attached to a Form 5500 filed for a pension benefit plan or a welfare
More information2014 Expanded Reporting and Disclosure Requirements Calendar
2014 Expanded Reporting and Disclosure Requirements Calendar Single-Employer Pension and Welfare Plans Under ERISA Table of Contents Reporting Requirements 2 IRS Form 1099-R (DB/DC) 2 PBGC Reporting for
More informationEmployee Benefit Plan Voluntary Correction Programs: Fixing Costly Errors and Preserving Tax Benefits
Employee Benefit Plan Voluntary Correction Programs: Fixing Costly Errors and Preserving Tax Benefits Leveraging Available IRS and DOL Programs to Proactively Address Plan Mistakes and Minimize Penalties
More informationOverview and Introduction. Basic Audit Workshop. Discussion Leaders. Michael E. Auerbach Marilee P. Lau Employee Benefit Plan Audit Conference
2011 Employee Benefit Plan Audit Conference Basic Audit Workshop Maryland Association of CPAs Columbia, Maryland May 110, 2011 Discussion Leaders Michael E. Auerbach Marilee P. Lau 2 Overview and Introduction
More informationBenefit Plan Compliance Checklist
Benefit Plan Compliance Checklist 0 Introduction The checklist in this document is intended for use by employers as a guideline to consider compliance regulations and how each regulation may apply to an
More informationCommon Compliance Issues and Remedies
Common Compliance Issues and Remedies Ilene H. Ferenczy, Esq. Ferenczy + Paul LLP Tricia A. Van Vliet, CPA Elliott Group CPAs, PLLC Today s Lineup Overview of plan compliance errors knowing how to recognize
More information2015 Employee Benefit Plan Audit Conference Basic Audit Workshop Maryland Association of CPA s Columbia, Maryland April 27, 2015
2015 Employee Benefit Plan Audit Conference Basic Audit Workshop Maryland Association of CPA s Columbia, Maryland April 27, 2015 1 Discussion Leaders Michael Auerbach Marilee P. Lau 2 1 Overview and Introduction
More informationOverview and Introduction. Basic Audit Workshop. Discussion Leaders. Michael Auerbach Marilee P. Lau 4/29/2013
Basic Audit Workshop Maryland Association of CPA s Columbia, Maryland May 6, 2013 1 Discussion Leaders Michael Auerbach Marilee P. Lau 2 Overview and Introduction 3 1 Workshop ERISA and Related Regulations
More informationReference Guide. MassMutual s Regulatory Advisory Services FOR PLAN SPONSOR USE ONLY.
201 $XGLWRUV Reference Guide MassMutual s Regulatory Advisory Services FOR PLAN SPONSOR USE ONLY. Table of Contents Introduction... 6 What s New?... 6 PART I: Important Information for Year End Reporting...
More informationFraud Risk Assessment Awareness in Employee Benefit Plans
Fraud Risk Assessment Awareness in Employee Benefit Plans Tyler Geiman, CPA, CFE, CFF Novak Francella, LLC Phone: (443) 832-4009 Fax: (443) 393-0323 Web: www.novakfrancella.com Fraud is any intentional
More informationRetirement Plan Audit Strategies Revising Audit Roadmaps Based on 403(b) Regs, Form 5500 Changes and New Transitional Guidance
Presenting a live 110 minute webinar with interactive Q&A Retirement Plan Audit Strategies Revising Audit Roadmaps Based on 403(b) Regs, Form 5500 Changes and New Transitional Guidance WEDNESDAY, NOVEMBER
More informationHealth and Welfare Plan Compliance Checklist
Health and Welfare Plan Compliance Checklist ERISA Disclosure Requirements, including Plan document Summary plan description (SPD) Summary of material modifications or reductions (SMM or SMR) Summary of
More informationPresenters. James Jaramillo. Rose Ann Abraham, CPA. Todd Solomon, JD. Partner, McDermott Will & Emery LLP. Partner, Baker Tilly Virchow Krause, LLP
Presenters Rose Ann Abraham, CPA Partner, Baker Tilly Virchow Krause, LLP Todd Solomon, JD Partner, McDermott Will & Emery LLP James Jaramillo Vice President, Sheridan Road Financial 4 Trends in Corporate
More informationThe Importance of Hiring a Quality Auditor. to Perform Your Employee Benefit Plan Audit. Plan Advisory
The Importance of Hiring a Quality Auditor to Perform Your Employee Benefit Plan Audit Plan Advisory The AICPA EBPAQC is a firm-based, volunteer membership center created with the goal of promoting quality
More informationLess Than Perfect Filings Wednesday, May 1, 2013
Less Than Perfect Filings Wednesday, May 1, 2013 Scott Albert, DOL Kristina Kananen, APA QPA QKA DATAIR Employee Benefit Systems, Inc. TODAY S DISCUSSION EFAST Rules Before a Filing is Accepted Attachment
More informationGeneral guidelines for completing IRS Form Tax year 2017
General guidelines for completing IRS Form 5500 Tax year 2017 Filing instructions We re pleased to provide these guidelines as a supplement to the annual financial reports provided by Vanguard and the
More informationDefined Contribution and Defined Benefit Plans: Have you considered everything?
Defined Contribution and Defined Benefit Plans: Have you considered everything? Amy Henselin Partner, Audit Appleton Debbie Smith Partner, National Professional Standards Group Chicago Objectives Identify
More informationQDIAs under the Pension Protection Act
QDIAs under the Pension Protection Act RETIREMENT MANAGEMENT SERVICES, LLC 9/14/2015 Rhonda Henry, CPA, APA When Congress passed the Pension Protection Act of 2006 ( PPA ), they addressed a major problem
More informationInstructions for Form 5500
Department of the Treasury Department of Labor Pension Benefit Internal Revenue Service Employee Benefits Guaranty Corporation Security Administration 2008 Instructions for Form 5500 Annual Return/Report
More informationShort Form Annual Return/Report of Small Employee Benefit Plan
Form 55-SF Department of the Treasury Internal Revenue Service Department of Labor Employee Benefits Security Administration Pension Benefit Guaranty Corporation Part I Short Form Annual Return/Report
More informationPlan Correction Programs
Plan Correction Programs Recognizing Client Problems and Finding Solutions Robert Higgins, JD, AIFA, CEBS Scottsdale, AZ April 18-19, 2013 Plan Corrections Programs Internal Revenue Service (IRS) o Tax
More informationAon Hewitt Compliance Calendar Significant Compensation and Benefit Due Dates for 2015
Aon Hewitt Compliance Calendar Significant Compensation and Benefit s for 2015 Aon Hewitt is pleased to present its 2015 Compliance Calendar to help plan sponsors identify significant compensation and
More informationCompliance for Health & Welfare Plans
Compliance for Health & Welfare Plans Presented by Lauren Johnson, APA, CFC McGregor & Associates, Inc. 997 Governors Lane, Suite 175 Lexington, KY 40513 (859) 233-4377 laurenj@mai-ky.com AGENDA Overview
More informationEBP ACCOUNTING, AUDITING AND REGULATORY UPDATE
EBP ACCOUNTING, AUDITING AND REGULATORY UPDATE Michelle Brumfield, CPA Director Page 135 Objective At the end of this session, participants will: Receive a debrief of the new accounting and auditing standards
More informationThe importance of hiring a quality auditor
Employee Benefit Plan Audit Quality Center Plan advisory The importance of hiring a quality auditor to perform your employee benefit plan audit 1 The AICPA EBPAQC is a firm-based, volunteer membership
More information403(b) PLANS A GUIDE FOR SECTION 501(c)(3) ORGANIZATIONS
403(b) PLANS A GUIDE FOR SECTION 501(c)(3) ORGANIZATIONS ING January 2011 This guide is not intended and may not be used to avoid tax penalties, and was prepared to support the promotion or marketing of
More informationERISA Compliance: Wrap Plan Document and Form 5500 Filing Requirements
ERISA Compliance: Wrap Plan Document and Form 5500 Filing Requirements February 2019 1 Sue Sieger, ACFCI, CAS Employee Benefits Corporation Senior Compliance Consultant sue.sieger@ebcflex.com The material
More informationSUMMARY COMPARISON OF CURRENT LAW AND THE PRINCIPAL PROVISIONS OF THE PENSION PROTECTION ACT OF 2006: 1 MULTIEMPLOYER PENSION FUNDING REFORMS
August 17, 2006 SUMMARY COMPARISON OF CURRENT LAW AND THE PRINCIPAL PROVISIONS OF THE PENSION PROTECTION ACT OF 2006: 1 MULTIEMPLOYER PENSION FUNDING REFORMS Contents Page Minimum Required Contributions
More informationEmployee Benefit Plan Voluntary Correction Programs: Fixing Costly Errors and Preserving Tax Benefits
FOR LIVE PROGRAM ONLY Employee Benefit Plan Voluntary Correction Programs: Fixing Costly Errors and Preserving Tax Benefits WEDNESDAY, MARCH 1, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE
More informationEverything a health subrogation professional needs to know about Form 5500
Everything a health subrogation professional needs to know about Form 5500 Presented by: Lisa S. H. Boero, Esq. Security Health Plan of Wisconsin, Inc., Chief Legal Officer Sara J. Skrzeczkoski, CSRP Security
More informationTesting & Reporting Services. Glossary
Testing & Reporting Services Glossary Table of Contents Click on a term/letter below to view a definition or section of the Glossary. # - IRC, 1% Owner, 103-12 Investment Entity, 3-Digit Plan Number, 401(a)(4)
More information