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Government Affairs
On May 7, 2012, the U.S. Department of Labor issued Field Assistance Bulletin 2012-02, which includes Questions and Answers on the participant-level fee disclosure regulation under ERISA § 404(a)(5) and the fiduciary-level fee disclosure regulation under ERISA § 408(b)(2). The Field Assistance Bulletin covers topics that include disclosures related to administrative expenses, brokerage windows, benchmarks, comparative formats, and model portfolios. A DOL press release on this guidance is available at http://www.dol.gov/ebsa/newsroom/2012/EBSA050712.html and the Field Assistance Bulletin itself is available at http://www.dol.gov/ebsa/regs/fab2012-2.html.
COMMENTS/TESTIMONY
On May 8, 2012, ASPPA submitted comments to the Internal Revenue Service regarding the use of forfeitures to fund safe harbor contributions. ASPPA requested that the IRS consider issuing additional guidance clarifying that forfeitures can be used to fund ADP safe harbor contributions and that forfeitures may be used to fund ADP safe harbor contributions that are qualified automatic contribution arrangements. [Comment]
On May 8, 2012, ASPPA submitted comments to the Internal Revenue Service with respect to proposed regulations relating to longevity annuity contracts under defined contribution plans. ASPPA recommended an increase in the limits, greater flexibility and clarifications regarding premiums paid under a contract that fails or ceases to be a QLAC. [Comment]
On May 2, 2012, ASPPA and ACOPA submitted comments on proposed modifications to IRC 417(e) regulations regarding partial annuity distribution options. Issues addressed included implications for past practice, multiple annuity starting dates and notice and election rules for bifurcated benefits. [Comments]