2020 has been filled with new legislation that affects the retirement plan industry. From the SECURE Act to the CARES Act don’t miss TPA expert and ERISA Attorney Ilene Ferenczy explain how these changes affect your TPA compliance operations. These interactive training sessions are open to all TPAs for $395 for both sessions but are FREE to all PensionPros who have PROPASS. Evolve the way you work.
Session 2 – October 22nd 2:00pm – 4:00pm EDT (2 CE Credits)
Annual Data Collection under the CARES Act
Data Collection and Annual Plan Compliance – Under normal circumstances, collecting annual data and providing annual plan compliance services is no easy task. With the law changes in 2020, this brings many other issues into the mix. In this session we will take a deep dive into the practical issues that will arise most frequently and what process changes can be put in place to ensure you have the information you need. Collecting the correct data for the 2020 cycle will be tantamount to effectively managing your annual compliance for the 2020 plan year.
- CARES Act Amendment – The deadline for most plans to adopt the CARES Act provision is the last day of the first plan year beginning on or after January 1, 2022 (governmental plans have two additional years). The amendment must reflect how the plan operated in the interim. We will help you create a process to document the optional provisions that were implemented by each plan.
- Partial Plan Termination – A plan sponsor never likes to hear that a partial plan termination has occurred. We expect this to be a common concern for the 2020 plan year. It is important to understand the differences between a leave of absence or furlough and a true termination and the impact each has on the plan. In addition, we will discuss how the dates of termination could impact this determination and how to adjust your census request to make sure you are receiving everything you need to help plan sponsors make this determination.
- Plan Compensation – For plan sponsors, determining plan compensation can be confusing at best. This year, they may have the added difficulty of government mandated PTO or company paid leave. We will discuss how different types of compensation should be classified and what you can do to make sure all applicable compensation has been submitted on the annual census. We’ll also review potential issues that may arise with the compensation ratio test.
- Defined Benefit Funding – If you administer defined benefit plans, I’m sure you prepared a lot of freeze amendments during 2020! We will discuss client outreach and questions to ask in your annual questionnaires to gauge a plan sponsor’s interest in unfreezing their plan for 2021, and for those that didn’t freeze, ways to reduce their funding burden going forward.
- Business Closures – We all heard so many stories this year about businesses that had to close their doors due to the pandemic. In this trying time, their retirement plan was probably low on the priority list. We will discuss best practices for handling these situations, including what you should do if you are unable to locate the plan sponsor.
- Non-Discrimination Testing – With so many layoffs and terminations, it is quite possible that plans who typically have no issue with their ADP/ACP tests may find themselves failing one or both tests.
- SECURE Act – With all the talk surrounding the CARES Act, it is easy to forget that was not the only piece of legislation that recently impacted the industry. We will discuss ways the SECURE Act impacts the annual plan compliance, including the additional flexibility to retroactively add a 4% safe harbor non elective contribution for the 2020 plan year.
- Annual Administration project that includes the following:
- Plan questionnaire with sample CARES Act data request items
- Suggested CARES Act and SECURE Act task items