News

IRS Issues Guidance on Funding Relief for Multiemployer DB Plans

The IRS has released Notice 2021-57, providing guidance for multiemployer defined benefit (DB) plans receiving funding relief under the American Rescue Plan Act of 2021. The Notice provides guidance regarding the plan sponsor’s ability to elect to delay designating a plan as being in endangered, critical, or critical and declining status or to delay updating the plan’s funding improvement or rehabilitation plan, and to extend the plan’s funding improvement or rehabilitation period. The guidance further explains the plan sponsor’s ability to amortize certain investments and other experience losses related to COVID-19 over a 30-year period in determining charges to the funding standard account.


2022 Taxable Wage Base Announced

The Social Security Administration has announced the 2022 adjustments for benefits and certain other limitations that are subject to annual cost-of-living adjustment (COLA) indices. One of these includes the Social Security taxable wage base (TWB), which identifies the maximum amount of an individual’s annual earnings that are subject to withholding for Social Security-administered benefits. The TWB is sometimes also used in retirement plan contribution allocations that use so-called “integrated” formulas, providing additional retirement plan benefits on income above the TWB, income for which the recipient will not receive Social Security benefits. For 2022, the TWB will rise from $142,800 to $147,000.

Significantly, it has been common for the IRS to provide the COLA-determined retirement limitations for the coming year shortly after the revised TWB is announced by the Social Security Administration. These 2022 retirement limitations will be announced as soon as they become available.


Washington Pulse: Form 5500 Changes Proposed

In September 2021, the DOL, IRS, and Pension Benefit Guaranty Corporation (PBGC), collectively referred to as the “Agencies”, released proposed changes to Form 5500, Annual Return/Report of Employee Benefit Plan. The changes are designed to implement certain provisions under the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019, which require multiple employer plans (MEPs) to report additional information and allow a group of defined contribution plans to file a consolidated Form 5500. The DOL has also issued a proposed rule that would amend regulations relating to annual reporting requirements under Title I of the Employee Retirement Income Security Act of 1974 (ERISA). Other proposed changes are aimed at improving financial reporting, expanding eligibility for small plan reporting, and encouraging compliance with Internal Revenue Code-based requirements.

If adopted, the proposed amendment to MEP reporting would apply to plan years beginning on or after January 1, 2021. Other proposed revisions generally would apply to reporting for plan years beginning on or after January 1, 2022. The modifications affect employee pension and welfare benefit plans, plan sponsors, administrators, and service providers subject to annual reporting requirements. Comments to the proposed changes are due by November 1, 2021.

 SECURE Act Changes to Form 5500

The SECURE Act requires MEP plan sponsors to report a new data element and sponsors of pooled employer plans (PEPs) to identify pooled plan providers. The SECURE Act also requires the Secretary of Labor and the Secretary of Treasury to update Form 5500 to allow a single consolidated annual report to be filed on behalf of certain groups of defined contribution plans.

New MEP reporting requirement

Under current rules, a MEP plan sponsor must file an attachment to Form 5500 that identifies each participating employer. The attachment must also provide a good faith estimate of the percentage of total contributions made by each participating employer during the applicable plan year.

For plan years beginning on or after January 1, 2021, the SECURE Act requires MEP plan sponsors to report the aggregate account balances attributable to each participating employer. For the 2021 Form 5500, the Agencies are proposing that MEP plan sponsors include the aggregate account balances in a way that’s similar to how other MEP information is currently being reported. For PEPs, the attachment must identify that the plan is a PEP and provide additional information specific to the PEP.

Beginning with the 2022 plan year, the Agencies are proposing to replace the attachment with a new schedule (Schedule MEP, Multiple Employer Pension Plan) that includes each participating employer’s contributions and aggregated account balances. Part III of the proposed Schedule MEP contains PEP-specific disclosures.

Under the proposal, employers maintaining welfare plans would not be required to file Schedule MEP, but all MEP plan sponsors would be required to file Form 5500. Currently, the DOL is not proposing to amend the existing reporting rules to establish a “simplified report” for MEPs that have less than 1,000 participants and whose participating employers have less than 100 participants, as suggested under the SECURE Act.

Defined Contribution Group Reporting Arrangements

In accordance with the SECURE Act, the DOL and IRS have proposed a new reporting arrangement—a defined contribution group (DCG). Eligibility to file under the new arrangement requires participating plans in the DCG to be defined contribution plans that have the same

  • trustee and trust (plans funded through custodial accounts, such as 403(b) plans, would not be eligible);
  • named fiduciaries;
  • plan administrator;
  • plan year; and
  • investments or investment options.

Under the proposal, participating plan sponsors in a DCG arrangement could have sub-trusts, but not separate trusts for investments. The proposal would also require DCGs to be 100 percent invested in “eligible plan assets”, which are secure, easy-to-value assets. Examples include mutual funds, publicly traded securities held by a registered broker dealer, and cash or cash equivalents. In addition, a participating plan

  • could not hold employer securities or have brokerage windows,
  • could not be a multiemployer plan or a MEP, and
  • would have to comply with the annual independent qualified public accountant (IQPA) audit requirement unless eligible for a waiver of the audit.

Participating plan sponsors would file Form 5500 under the rules and conditions that currently apply to large defined contribution plans. Each participating plan sponsor would file a new schedule, Schedule DCG, Individual Plan Information, to report individual plan level information. If an extension of time to file the aggregated Form 5500 was needed, each participating plan sponsor would need to request an extension by filing Form 5558, Application for Extension of Time To File Certain Employee Plan Returns. Failure to request an extension would result in a late filing for the DCG.

Participant Count Methodology Changes

Eligibility to file as a small plan, eliminating the IQPA audit requirement, is currently based on participant counts as of the beginning of the plan year. Plan sponsors must include employees who are eligible to make elective deferrals even if they have elected not to participate and do not have an account balance in the plan. For defined contribution plans only, the Agencies are proposing that participant counts include only those employees who have account balances at the beginning of the plan year. The change was driven in part by the SECURE Act ‘s provision allowing long-term, part-time employees to make elective deferrals, thus potentially reducing the plans eligible for small plan reporting. For a plan’s initial plan year, the participant count for this purpose would exclude plans that have fewer than 100 participants with account balances both at the beginning of the plan year and the end of the first plan year.

Schedule H – Schedule of Asset Changes

Plan sponsors of funded pension benefit plans and funded welfare benefit plans (e.g., VEBAs) are required to file Schedule H, Financial Information. Line 4i requires plan sponsors to attach a schedule reporting any invested assets held at the end of the plan year, and a schedule reporting those assets that were acquired and disposed of within the plan year. The Agencies are proposing to standardize the information reported on Schedule H in order to create a searchable reporting format for improved transparency and electronic use. If the changes are approved, plan sponsors would need to use legal or other industry and regulatory investment identifiers when completing the schedule.

According to the proposal, participant-directed brokerage account assets could be treated as one asset held for investment purposes; however, certain investments would need to be reported separately, such as investments in real property, employer securities, partnership or joint venture interests, and investments that could result in a loss that exceeds the participant’s account balance. The Agencies added a check box for hard-to-value assets, including nonpublicly traded securities, real estate, and hedge funds. Additional check boxes are being added to identify investments that are designated investment alternatives or qualified default investment alternatives. The proposal would require plan sponsors to enter the total annual operating expenses expressed as a percentage of assets, which is currently provided to participants in accordance with the participant fee disclosures required by DOL Regulation 404(a)(5).

Schedules MB, SB, and R Changes

  • Schedule MB. The Agencies have proposed changes to Schedule MB, Multiemployer Defined Benefit Plan and Certain Money Purchase Plan Actuarial Information, which collects actuarial information on multiemployer defined benefit plans and certain money purchase pension plans. The changes are meant to provide greater transparency in the actuarial status of such plans. The Agencies propose modifying the instructions to require an attachment that breaks down the total withdrawal liability amounts by date, and separately specifies the periodic withdrawal liability amounts and lump-sum withdrawal liability amounts. The Agencies would also require plan sponsors to 1) report the interest rate used to determine the present value of vested benefits for withdrawal liability determinations; 2) indicate if an expense load is included in the normal cost; and 3) provide additional information about demographics, benefits, and contributions for PBGC-insured multiemployer plans with 500 or more total participants.
  • Schedule SB. Similar to the changes that are currently proposed for Schedule MB, proposed changes to Schedule SB, Single-Employer Defined Benefit Plan Actuarial Information, would add requirements about reporting demographics and benefits of single-employer defined benefit plans. For ERISA plans with 500 or more total participants as of the valuation date, the Agencies would require a projection of benefits expected to be paid in each of the next 50 years. The average age and average monthly benefit as of the valuation date would also be required. A question relating to elections made regarding pension funding relief under the American Rescue Plan Act of 2021 is also being proposed. The proposed changes reflect an effort to provide the PBGC with more detail to project defined benefit pension plan and PBGC insurance program liabilities.
  • Schedule R. The proposed changes to Schedule R, Retirement Plan Information, would require plan sponsors of multiemployer defined benefit plans to report identifying information about any participating employer who either 1) contributed more than five percent of the plan’s total contributions, or 2) was one of the top ten highest contributors.

Compliance Questions

The IRS is proposing to change Form 5500 for the 2022 plan year by adding questions that would help identify plans that fail to meet coverage and nondiscrimination testing requirements. A plan sponsor that permissively aggregates plans for testing purposes would need to disclose whether the plans satisfy the coverage and nondiscrimination tests of Internal Revenue Code Sections 410(b) and 401(a)(4). A 401(k) plan sponsor would need to indicate whether the plan uses a design based safe harbor or the prior-year or current-year ADP testing method. Aimed at identifying late amenders, the IRS is also proposing to add a question asking for the date and serial number of the favorable Opinion Letter for an employer that has adopted a pre-approved plan.

MEWA Reporting Changes

Administrators of multiple employer welfare arrangements (MEWAs) that provide medical benefits must file an annual report, Form M-1, Report for Multiple Employer Welfare Arrangements (MEWAs) and Certain Entities Claiming Exception (ECEs). Administrators of “plan” MEWAs must also report, as an attachment to Form 5500, each participating employer’s identifying information and a good faith estimate of the percentage of total contributions made by each participating employer during the plan year. Effective for plan years beginning on or after January 1, 2022, the DOL is proposing to require all administrators of MEWAs (plan and non-plan MEWAs) that offer or provide coverage for medical benefits to report the participating employer information on Form M-1 (not as an attachment to Form 5500).

Next Steps

Although the changes are only proposed at this time, plan sponsors and administrators should review the proposals and watch for further developments once comments have been submitted. The Agencies are requesting that comments be made by November 1, 2021. Ascensus will continue to follow any new guidance as it is released. Visit ascensus.com for the latest developments.

 

Click here for a printable version of this issue of the Washington Pulse.


IRS Provides COBRA Coverage Clarifications

The IRS has issued Notice 2021-58, which clarifies the application of extension under the “Joint Notification of Extensions of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak” and additional guidance issued by the Department of Labor’s Emergency Relief Notices. Moreover, this notice addresses the interaction between the Emergency Relief Notices and COBRA premium assistance available under the American Rescue Plan Act (ARPA).

Notice 2021-58 clarifies that the disregarded period for an individual to elect COBRA continuation coverage runs concurrent to the disregarded period to make the premium payment. Individuals generally have 60 days to elect COBRA and an additional 45 days to pay the premium. The Notices provide that if an individual elects COBRA continuation coverage within the 60-day period, the individual will have one year and 45 days after the date of the COBRA election to make the initial COBRA premium payment. However, if the individual elects COBRA continuation coverage outside of the initial 60-day COBRA election time frame, the individual will have one year and 105 days after the date the COBRA notice was provided to make the initial COBRA premium payment. Relating to subsequent premium payments, Notice 2021-58 provides that an individual has a maximum period of one year from the date the payment originally would have been due, including any applicable 30-day grace period.

The guidance also offers transition relief to those individuals who made an election outside of the initial 60-day period and whose payment is due before November 1, 2021. Under the transition relief, the premium payment is not required to be made before November 1, 2021, even if November 1, 2021, is more than one year and 105 days after the date the election notice was received. The transition relief applies so long as the individual makes the initial payment within one year and 45 days after the date of the election.

Notice 2021-58 reiterates that the extensions under the Emergency Relief Notices do not apply to the COBRA subsidy notices required under the ARPA or to the election of COBRA continuation coverage under the ARPA. Individuals may retroactively elect COBRA continuation coverage but will not be eligible for the COBRA subsidy.

Finally, the notice offers various examples of applying the extension.


Ascensus Plans to Add Nearly 400 New Associates Through 2022

Hiring Initiative Supports Recent and Anticipated Growth

Ascensus—whose technology and expertise help millions of people save for retirement, education, and healthcare—expects to add nearly 400 new associates by the end of 2022, adding scale and expertise in support of expanding client, partner, and advisor business.

“The U.S. economy has shown remarkable resilience through the challenges of the past 18 months, and it’s clear that both organizations and workers are now finding new opportunities for growth,” said David Musto, president and CEO of Ascensus. “Ascensus is generating outstanding sales momentum as a tech-enabled solutions provider, and our wins in the marketplace are creating significantly greater opportunities to recruit and retain the best talent across our businesses.”

Musto noted that the company’s world-class NPS scores and client satisfaction have helped Ascensus drive strong client retention in a highly competitive market, adding: “We’re committed to proactively addressing our workforce needs to position ourselves for even greater client and business success in the years ahead.”

Forecasted growth and investments over the next 15 months will add associates in technology, client services, operations, sales, marketing, compliance, and general management across all four of the company’s lines of business—Retirement, FuturePlan by Ascensus, Government Savings, and Health & Benefits.

  • In Retirement, hiring plans will create eight new sales territories, expand product and digital capabilities, and strengthen Ascensus’ proven outsourcing model by investing in added institutional partner capabilities.
  • Recruiting in FuturePlan, one of the largest independent retirement plan TPAs in the country, includes expansion of plan design and client consulting teams, growing the business line’s prevailing wage capabilities (addressing opportunities in the building and construction industries benefiting from federal infrastructure spending), and enhancing support for technology and digital solutions.
  • Government Savings plans to enhance its scope, scale, and service model with new roles in operations—addressing significant growth across Ascensus’ industry-leading 529 education and ABLE programs—and expand its employer onboarding and servicing teams to support increasing participation in its state-facilitated retirement program business.
  • Health & Benefits recruiting efforts will focus on helping differentiate Ascensus’ product strategy and solutions in the marketplace and drive customer and partner growth. Additional investments will add service and operations roles targeting emerging needs in health savings account, Affordable Care Act, and COBRA plan servicing.

Ascensus recently announced special compensation and benefits enhancements for associates in recognition of the extraordinary results and performance delivered throughout the organization over the past year and a half. Improvements included an immediate salary adjustment of 3% for the majority of associates and a special  profit-sharing contribution to eligible associates’ retirement accounts in early 2022.

“Through a very demanding period, our associates have doubled down on their commitment to serving our clients and helping people save for what matters,” continued Musto. “We’re grateful for their efforts and delighted to reward them for their outstanding achievements—all while supporting them with significant new hiring investments to address today’s client needs and future growth.”

Since spring 2020, Ascensus has added more than 1.7 million savings participants across its lines of business, launched new mobile apps for retirement and education savers, acquired and onboarded the retirement plan administration and servicing business of one of the nation’s largest financial institutions, advanced capabilities in its FuturePlan line of business to deliver scale and expertise nationally, and enhanced service and digital solutions for its Health & Benefits business. Ascensus was recently named a finalist for Retirement Leader of the Year by Fund Intelligence for the third consecutive year—having won the honor in 2019—while Government Savings logged its 21st consecutive quarter of five-star ratings by National Quality Review, recognizing its excellence in customer service performance.

For information about pursuing a career at Ascensus, visit careers.ascensus.com.

 

About Ascensus
Ascensus helps millions of people save for what matters—retirement, education, and healthcare. Through co-branded, private-labeled, and other governmental partnerships, our technology, market insights, and business knowledge enhance the growth and success of our partners, their clients, and savers. Ascensus is the largest independent recordkeeping services provider, third-party administrator, and government savings facilitator in the United States. For more information, visit ascensus.com.


Proposed Bill Would Create Portable Retirement Accounts

Representative Jim Himes (D-CT) and Senator Mark Warner (D-VA) have announced legislation to establish universal, portable retirement accounts. The Portable Retirement and Investment Account (PRIA) Act of 2021 would create such accounts for every American at birth, in conjunction with the issuance of a Social Security number.

The child of any taxpayer who received the earned income tax credit in the tax year prior to establishment of the account would also receive a $500 contribution. Any individual will be permitted to make contributions to their own account throughout their life, except during years in which they are an active participant in an employer-sponsored retirement plan. Annual aggregate contributions will be limited to an amount comparable to the IRA contribution limit imposed under Internal Revenue Code Section 219(b) and catch-up contributions for those age 50 or older.

Employers will be permitted to make direct deposits, apply automatic contribution and automatic escalation features, and make contributions to the accounts of their eligible employees. These employees are limited to anyone

  • whose employer does not maintain a qualified retirement plan,
  • whose employment consists of work (whether or not as an employee) through mobile platforms, or
  • who is not eligible to participate in their employer’s qualified retirement plan.

 

The bill was referred to the House Committee on Ways and Means.


Proposed House Budget Reconciliation Amendment Includes IRA Restrictions

The House Ways and Means Committee has released additional legislative text as part of its tax portion of the anticipated $3.5 trillion budget reconciliation bill. If enacted, the proposal would impose several restrictions on IRAs.

  • Creates a prohibition on Roth or Traditional IRA contributions if aggregate IRA and defined contribution balances exceed $10M, and generally applies to individuals making more than $400–$450k (depending on filing status)
  • For account balances exceeding $10M, provides for a required distribution equal to 50 percent of the amount by which the prior year aggregate balance exceeds $10M—again, for individuals making more than $400–$450K. If the aggregate value exceeds $20M, then the excess is required to be distributed first from Roth IRAs and designated Roth accounts to bring the value to $20M (or deplete Roth assets) after which the individual can choose which accounts to distribute from to satisfy the remaining RMD resulting from having a balance exceeding $10M.
  • Closes the “back-door” Roth loophole by eliminating conversions of all after-tax IRA and after-tax employer plan contributions
  • Eliminates pretax conversions and rollovers to Roth from non-Roth accounts for those making $400–$450k (beginning in 2032)
  • Extends statute of limitations from three years to six years after a return containing an error was filed to allow IRS to pursue IRA noncompliance

The legislation also imposes restrictions on certain types of investments as follows.  Such investments that exist in IRAs at the time of enactment would be required to be divested from the IRA by December 31, 2023.

  • Prohibits investment of IRA assets in a security if the issuer of the security (or other person specified by the Treasury Department) requires the account owner to either
    • have a specified minimum amount of income or assets,
    • have completed a specified level of education, or
    • hold a specific license or credential
  • Prohibits investment of IRA assets in entities in which the owner has a substantial interest (10 percent or more) or is an officer or director of the entity. Constructive ownership of family members applies (spouse, ancestor, lineal descendant, and spouse of lineal descendant).

Other retirement provisions included in the Ways and Means Committee’s portion of the bill were announced last week. After nearly 40 hours of debate and 66 amendments over the course of four days, the legislation was approved by the Ways and Means Committee in a near party-line vote. It now moves to the House Budget Committee for markup.


Ascensus Unveils Retirement Website and Mobile Enhancements That Offer Simple, Seamless, and Supportive User Experiences

Plan Sponsors and Participants Benefit from Continued Investments in Technology and Digital Initiatives Designed to Save Time and Improve Outcomes

Ascensus—whose technology and expertise help millions of people save for retirement, education, and healthcare—is pleased to announce a recent series of technology and digital updates designed to enhance and simplify retirement plan sponsor and participant user experiences.

Chief among these are participant website and mobile experiences that have been redesigned based on the latest feedback and user experience principles. Updates include more intuitive designs that are in line with Ascensus’ approach of keeping retirement plan engagement simple, seamless, and supportive for all users. The enhancements include a dashboard redesign, behavioral interventions, and experimentation to drive positive saver outcomes.

The participant dashboard redesign, which ensures important account information is prominently displayed and easy to understand, has received high marks, with four out of five savers preferring the new design over those of other financial websites. Ascensus’ mobile app now provides personalized, context-sensitive interventions that have successfully deflected 30% of participants who intended to decrease their savings rate. And through A/B testing and using behavioral economics principles, Ascensus was able to increase the number of savers who increased their savings rate by 50% over control.

“Ascensus is committed to investing in technology that delivers fresh, simple, and efficient experiences to plan sponsors and participants,” states Kevin Cox, president of Ascensus Retirement. “As a company that is constantly on the move, we’ll continue to evolve our online experiences based on user feedback and data-driven insights with the goal of delivering better outcomes for the plan sponsors and participants we service.”

In addition to the participant website and mobile redesign initiatives, Ascensus has also recently unveiled several other experience enhancements as a result of technology-related investments, including:

  • Payroll: Ascensus has introduced several features to make payroll processing more seamless and intuitive for plan sponsors, including a wizard that assists with uploading files, the ability to track contributions and clearly see remaining steps in the process, and an option to update banking information within the payroll experience. These enhancements have been well received by plan sponsors who handle their own payroll processing.

    For plan sponsors who do not want to facilitate their own payroll processing, Ascensus continues to integrate with additional payroll vendors to offer more options, including Payroll 360. Ascensus has integrated with more than 100 payroll providers and is currently working on expanding a number of those into Payroll 360 integrations.

  • Compliance: Our year-end compliance testing package has been refreshed with a clean, intuitive design to help plan sponsors ensure their plan operations and documents are current and compliant. Plan-level alerts are now available to assist with ineligible contributions and offer tips and best practices. The new experience features dynamic content and interactive digital links, with more enhancements on the horizon.
  • Managed Accounts: We’ve expanded our strategic relationships to provide managed account optionality for institutional partners and advisors looking to deliver personalized account management services to their clients and savers.

“Our technology-driven investments demonstrate Ascensus’ commitment to providing enhancements to better support plan sponsors and participants,” adds Cox. “Since our independent service model allows for more choice and flexibility, our partners can leverage these enhancements to facilitate solutions that connect with their clients.”

“We’ll continue to develop our purpose-driven technology to make it easier for employers of all sizes to offer retirement plan benefits to their employees while also helping more savers save more,” concludes Cox.

About Ascensus
Ascensus helps millions of people save for what matters—retirement, education, and healthcare. Through co-branded, private-labeled, and other governmental partnerships, our technology, market insights, and business knowledge enhance the growth and success of our partners, their clients, and savers. Ascensus is the largest independent recordkeeping services provider, third-party administrator, and government savings facilitator in the United States. For more information, visit ascensus.com.


IRS Issues Deadline Relief for Hurricane Ida Victims in Pennsylvania

The IRS has issued a news release announcing the postponement of certain tax-related deadlines for victims of Hurricane Ida in Pennsylvania. The tax relief postpones various tax filing deadlines that began August 31, 2021. Affected individuals and households who reside or have a business in Bucks, Chester, Delaware, Montgomery, Philadelphia, and York counties, as well as taxpayers with records located in the covered area that are needed to meet covered deadlines, qualify for relief.

In addition to extending certain tax filing and tax payment deadlines, the relief includes completion of many time-sensitive, tax-related acts described in IRS Revenue Procedure 2018-58 and Treasury Regulation 301.7508A-1(c)(1). Affected taxpayers with a covered deadline on or after August 31, 2021, and before January 3, 2022, will have until January 3, 2022, to complete the acts. This includes filing Form 5500 series returns that are required to be filed on or after August 31, 2021, and before January 3, 2022.

“Affected taxpayer” automatically includes any individuals who live, and businesses whose principal place of business is located, in the covered disaster area. Those who reside or have a business located outside the covered disaster area, but have been affected by the disaster, may contact the IRS to request relief.


DOL Releases Proposed Revisions to Form 5500 Reporting

The Department of Labor’s Employee Benefits Security Administration (EBSA), in conjunction with the IRS and Pension Benefit Guarantee Corporation (PBGC), have released proposed forms revisions modifying requirements for Form 5500, Annual Return/Report of Employee Benefit Plan, reporting. Additionally, the EBSA has issued a proposed rule to amend regulations relating to annual reporting requirements under Title I of the Employee Retirement Income Security Act of 1974 (ERISA).

The Setting Every Community Up for Retirement Enhancement (SECURE) Act included a provision that would allow employers sponsoring defined contribution plans that have the same trustee, administrator, fiduciaries, plan year, and investment options the opportunity to file one common Form 5500 beginning in 2022. While guidance outlining reporting requirements in accordance with the Act had been anticipated, the proposals also appear to include several other forms modifications.

The following revisions have been highlighted as part of the guidance package release.

  • Implement SECURE Act requirements by establishing a new type of direct filing entity called a Defined Contribution Group Reporting Arrangement and add a new Schedule DCG that such reporting group must file
  • Modify Form 5500 to reflect pooled employer plans as a new type of plan and modify multiple employer plan reporting of information by establishing a new Schedule MEP
  • For multiple employer welfare plans that provide medical benefits, move questions regarding participating employers from the Form 5500 to the Form M-1 Report for Multiple Employer Welfare Arrangement (MEWA) and Certain Entities Claiming Exception, and apply that reporting requirement to non-plan MEWAs that file the Form M-1
  • Expand reporting requirements to add new fee and expense reporting and enhance the content of the existing schedules of assets held for investment
  • Add questions to improve financial and funding reporting by PBGC-covered defined benefit pension plans

There will be a 45-day comment period following publication in the Federal Register.