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PLANSPONSOR BLINESs LOGO December 29th, 2020
Information & Insights for the 403(b) Community
Editor’s Note
In 2020, retirement plans were affected by the COVID-19 pandemic as well as new legislation and regulations. This edition of (b)lines includes Ask the Experts columns related to those.
Retirement Plan Considerations When Laying Off Employees
“Our college, like others, has closed due to the COVID-19 pandemic, and we are contemplating laying off a substantial portion of the workforce, at least temporarily. Are there any retirement plan considerations in doing so?”
Ask the Experts
with subject line “Ask the Experts.”
Does e-Disclosure Rule Allow for Postcard Notification of Links?
“In an Ask the Experts column from last summer, the Experts stated that the use of a letter/postcard with a website link to a Summary Plan Description (SPD) or other Employee Retirement Income Security Act (ERISA)-required disclosure would fall outside of the Department of Labor (DOL)’s safe harbor for electronic disclosure. Does the DOL’s issuance of a proposed rule regarding electronic disclosures change that response in any way?”
How May ACP Testing Results be Affected by COVID-19?
“We sponsor an ERISA 403(b) matching plan that is subject to actual contribution percentage (ACP) testing. Our recordkeeper recently sent us an alert saying our 2020 test results could be affected by the COVID-19 pandemic, but failed to provide any details as to how that is possible. Can the Experts help us out here?”
Can Plan Sponsors Send Documents Electronically Right Away?
“Now that the DOL has released its final rule on e-disclosure, can I go ahead and work with my recordkeeper to start sending covered documents to participants immediately?”
Clarification of the Legislative Changes Made for RMDs
“With the avalanche of guidance on required minimum distributions lately, from the SECURE Act to the CARES Act and beyond, I am now thoroughly confused as to when required minimum distributions (RMDs) are due, and for whom. Without confusing me, can the Experts provide a simple response in this regard?”
Delay of Initial e-Disclosure Notice
“I understand that the DOL recently announced that the one-time paper initial notice necessary to implement its new safe harbor on e-disclosure can be deferred due to COVID-19. Does that mean that I can just start sending covered documents electronically if I otherwise follow the new safe harbor?”
ACP Testing for Safe Harbor Plan That Suspended Match Contributions
“Our ERISA 403(b) safe harbor retirement plan recently suspended it’s matching contributions. We realize that we must perform ACP testing for our matching contributions the 2020 plan year. We are wondering if we can use the “prior-year testing method” for ACP testing for the 2020 plan year, as that would make it easier for us to pass.”
Rules for Bringing Back Laid Off or Furloughed Employees
“We are a 403(b) higher education plan sponsor who laid off and furloughed employees due to the COVID-19 pandemic. We have now hired back/recalled from many of those employees. Could the Experts opine as to some of the major 403(b) retirement plan issues I should be addressing for rehires?”
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