Regulatory Round-Up

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The retirement plan landscape is ever evolving. We distill the details so you don’t have to!

We’ve corralled the best news from inside the beltway – not only regulations, but also new legislation from Congress as well as relevant guidance from the IRS and Department of Labor. In true DWC fashion, we don’t just repackage a recitation of the rules, we provide our thoughts and commentary about what those rules mean to you.

We know cash balance rules can be intimidating! Settle into the Cash Balance Corner and let us break it down for you.

Have 401(k) questions? We have 401(k) answers! We bring you answers to many of the common questions we receive.

A behind-the-scenes look not at how the sausage is made, but why we make it the way we do. (Hint: It’s all about the best interests of the client.)

We’re all about learning from other people’s (alleged) mistakes. We might not be attorneys, but we still follow benefits-related cases and summarize lessons and key take-aways. No hourly fee needed for these insights!

A deeper dive into retirement plan topics doesn’t have to be headache-inducing. Our Pension Primer articles provide depth of information without depth of jargon!

DWC |

In Case of Emergency, (Don't) Break Plan!

It seems that with each major new retirement plan law, Congress has an idea that is great in concept but unnecessarily convoluted in implementation. It’s usually when they try to combine existing but ...
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DWC |

Catching Up On Catch-Up Contributions, Part 3 – Return of the Plan Correction

Congratulations, you’ve made it to the third and final episode of our trilogy on the proposed catch-up contribution regulations that address changes made by SECURE 2.0 (S2). In part 1, we discuss the ...
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DWC |

Catching Up On Catch-Up Contributions, Part 2 – Rothification Strikes Back

A long time ago, in a Congress far far away, SECURE 2.0 (S2) was enacted...
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DWC |

Catching Up On Catch-Up Contributions, Part 1 – A New Limit

A long time ago, in a Congress far far away, SECURE 2.0 (S2) was enacted. Ok, that was only December 2022, but it seems like ages ago when we’ve had to navigate some of the new rules with minimal ...
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DWC |

Self-Correction of Participant Loans – The IRS Gave & DOL Confirms What it Took Away

Earlier this week, the Department of Labor published the first update to its Voluntary Fiduciary Correction Program (VFCP) in nearly 20 years. Probably the most newsworthy change is the creation of ...
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DWC |

Self-Correction of Late Deposits…Finally, But Not Really

In a case of “be careful what you wish for”, we give you Exhibit A – the new DOL Voluntary Fiduciary Correction Program (VFCP). The new version, published by the DOL today, makes a number of ...
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DWC |

The 2025 Retirement Plan Contribution Limits

Extra! Extra! The IRS has released the 2025 contribution limits.
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Jen Swets |

New Distribution Options to Encourage Savings

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Adam C. Pozek |

It’s About Time – Long Term, Part Time Employees – Part 2

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Adam C. Pozek |

It’s About Time – Long Term, Part Time Employees – Part 1

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Sue Schnur |

Grab Bag of RMD Changes

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DWC |

The 2024 Retirement Plan Contribution Limits

Extra! Extra! The IRS has released the 2024 contribution limits.
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Carter Kimball |

Cash Out Limit is Movin' On Up

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Adam C. Pozek |

The New Eligible Inadvertent Failure: A “Catch-Most” for Self-Correcting Plan Errors

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Adam C. Pozek |

Finding Balance with Form 5500

It’s rare that updates to the Form 5500 warrant little more than a yawn, if anyone other than those who prepare the forms even notice. That is NOT the case with changes issued by the Department of ...
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Adam C. Pozek |

Automatic (Enrollment) for the People - Losing Your Discretion

Ever since creating the ACA, EACA, and QACA as part of the Pension Protection Act of 2006, Congress has acted like automatic enrollment is the greatest thing since sliced bread when it comes to ...
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Adam C. Pozek |

Catch-Up Contributions: If It Ain’t Broke, Break It!

Adam C. Pozek | 02/02/23 Yeah, we know that’s not how the saying goes, but it appears Congress doesn’t.
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Adam C. Pozek |

Roth, Roth and More Roth – as Far as the Eye Can See

Congress seems to be in a continual love fest with two retirement concepts – automatic enrollment and Roth contributions – and SECURE 2.0 (S2) continues the trend for both. I guess it’s not ...
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Jen Swets |

SECURE 2.0’s New & Improved (But Really Math-y) Tax Credits for Startup Plans

SECURE 2.0 (S2) took the tax credits of OG SECURE and enhanced them, particularly for plans with fewer than 50 employees. And if you think “enhanced” sounds a bit loaded, you’re right; credits have ...
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Adam C. Pozek |

SECURE 2.0 Overview Post

You have likely already heard and read plenty about SECURE 2.0, signed into law on December 29, 2022. Rather than write yet another recitation of what’s in the new law in chronological order, we are ...
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DWC |

The 2023 Retirement Plan Contribution Limits

Extra! Extra! The IRS has released the 2023 contribution limits. In past years we would list only the limits that changed. With almost everything changing at historic levels, we have provided a few ...
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Adam C. Pozek |

Secure 2.0 - Don't Count Your Chickens Before They Hatch

Earlier this week, the House of Representatives passed SECURE 2.0. The bill (actual name is Securing a Strong Retirement Act of 2022) passed by the nearly unanimous margin of 414 to 5. It doesn’t get ...
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DWC |

2020 Retirement Plan Tax Deductions - It's Not Too Late

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DWC |

CARES Act Relief for Retirement Plan Loan Payments is Ending, Now What?

Facts Earlier this year, we implemented the coronavirus relief provisions that allowed our participants to suspend loan payments for the remainder of 2020. As a result of reduced hours and other ...
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DWC |

The 2021 Retirement Plan Contribution Limits

Extra! Extra! The IRS has released the 2021 contribution limits. Since not everyone was awaiting them quite as eagerly as we were, here is a quick summary.
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DWC |

DWC News Update | eDisclosures: Initial Notice and Notice of Internet Availability

Welcome to the exciting conclusion of our foray into the brave new world of eDisclosures. Today, in our final look at the DOL’s new eDisclosure ruling, we will breakdown the Initial Notice and the ...
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DWC |

DWC News Update | eDisclosures: Covered Documents

The Department of Labor’s new rules that expand the electronic distribution of plan-related notices is a long-overdue and welcome change. We have provided a summary of the new eDisclosure rules and ...
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DWC |

DWC News Update | eDisclosures: A Deep Dive into Electronic Addresses and Internet Websites

Although the Department of Labor’s new ruling on electronic disclosures doesn’t officially go live until the end of next month, it is already breathing new life into some fairly antiquated-sounding ...
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DWC |

DWC News Update | New eDisclosure Rules: Maybe This Whole Internet Thing is Going to Stick

Just before Memorial Day weekend, the Department of Labor published rules allowing plan sponsors to set electronic media as the default method to provide plan information to participants. At more ...
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DWC |

The CARES Act Weekly Update | 4.16.2020

As the conversations surrounding CARES Act provisions continue to evolve, we are constantly updating our FAQs to provide the most in-depth and up to date information. This week, as a result of a lot ...
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DWC |

Is There Any Coronavirus Relief for Participants Who Want to Postpone Plan Loan Payments?

Facts Several participants in our 401(k) plan currently have outstanding plan loans, and many others are looking to initiate them. However, given the current pandemic, many participants are concerned ...
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DWC |

The CARES Act Weekly Update | 4.9.2020

This week we took a deeper look into participant's self-certification that they are eligible for relief under the Act, as well as the option some service providers are taking to automatically ...
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DWC |

How Does the CARES Act Expand the Availability of Retirement Plan Loans?

Facts Our 401(k) plan allows participants access to their accounts via hardship distributions and, for those at least age 59 ½, via in-service withdrawals. But with the economic uncertainty of the ...
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DWC |

Can We Allow a Distribution for a Coronavirus-Related Hardship?

Facts Some of our employees are dealing with financial challenges due to the coronavirus situation, and they are asking whether they can access their 401(k) accounts. Our plan allows for loans and ...
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DWC |

DWC News Update | The CARES Act: Federal Coronavirus Relief

On Friday afternoon, March 27th, Congress passed, and the President signed, the Coronavirus Aid, Relief, and Economic Security (CARES) Act - sweeping legislation intended to provide much-needed ...
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DWC |

DWC News Update | The SECURE Act Has Snuck Through

(Updated 12/23/2019) Late Friday evening (aboard Air Force One leaving DC for his holiday retreat), President Trump signed the spending bill that included the SECURE Act. In a bit of last-minute ...
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DWC |

The 2020 Retirement Plan Contribution Limits

The IRS has released the 2020 contribution limits! Since not everyone was awaiting them quite as eagerly as we were, here is a quick summary.
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DWC |

DWC News Update | Two Years in the Making: The Final IRS Hardship Distribution Regulations Are Here

It’s been a while, but we finally have them! Late last month, the IRS published the final hardship distribution regulations, nearly two years after Congress passed the Bipartisan Budget Act and the ...
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DWC |

Meet the MEPs: What's Next?

Welcome to the finale of our series on the Department of Labor’s new regulations, updating the definition of “Employer” under ERISA to extend the availability of multiple employer plans to more ...
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DWC |

Meet the MEPs: Grab Bag

The Department of Labor’s new regulations that expand the availability of multiple employer plans cover quite a bit of ground. In previous posts, we’ve explored Association MEPs, PEO MEPs, Corporate ...
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DWC |

Meet the MEPs: Corporate MEPs

Thanks to the Department of Labor’s recently published regulations, we went from just having multiple employer plans top having several different types of MEPs. We’ve already covered association MEPs ...
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DWC |

Meet the MEPs: PEOs

The next item up for bids in our series on the Department of Labor’s new regulations on multiple employer plans is on professional employer organizations, more commonly referred to by their acronym: ...
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DWC |

Meet the MEPs: Working Owners

Unless you’ve been on vacation somewhere off the grid, you’ve likely heard the news and read the headlines that the Department of Labor recently published new regulations that expand the availability ...
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DWC |

Meet the MEPs: Association Retirement Plans

When the Department of Labor’s new multiple employer plan regulations take effect later this year, we will have three types of MEPs:
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DWC |

DWC News Update: It's Just Another MEPish Monday

Yesterday morning while we were all sipping our first cup of Monday morning coffee, the Department of Labor published its much-anticipated final regulations expanding the availability of multiple ...
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DWC |

DWC News Update: A Bad Apple a Day Keeps the MEP Away

One of the drawbacks that is often cited about multiple employer plans is the so-called “one bad apple rule.” It provides that if a single participating employer in a MEP allows its part of the plan ...
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DWC |

DWC News Update: House Passes the SECURE Act

-A breakdown of breaking news from DWC's Managing Partner, Keith Clark If you are reading the mainstream press, the SECURE Act being signed into law is just around the corner. While the overwhelming ...
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DWC |

DWC News Update: The IRS Helps Those Who Help Themselves

The IRS did its part to make Friday, April 19th a really good Friday for those who sponsor qualified retirement plans. After not making many friends when it jacked up the user fees for the Voluntary ...
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DWC |

Breaking News: Hardship Distributions Becoming Even Less of a Hardship Than Previously Expected

Nearly a year after Congress passed changes to the hardship distribution rules in the Bipartisan Budget Act and the Tax Cuts and Jobs Act, the IRS has published proposed regulations to fill in some ...
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DWC |

The 2019 Retirement Plan Contribution Limits

The IRS has released the 2019 contribution limits! Since not everyone was awaiting them quite as eagerly as we were, here is a quick summary.
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DWC |

Breaking News: The IRS PLR on Student Loan Benefits in 401(k) Plans is Much Ado About Not Much

We interrupt your regularly scheduled programming to highlight the IRS’ not-so-ground-breaking entrance into the world of student loan benefits in 401(k) plans.
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DWC |

The 2018 Retirement Plan Contribution Limits Are Here

The IRS has released the 2018 contribution limits! Since not everyone was awaiting them quite as eagerly as we were, here is a quick summary.
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Adam C. Pozek |

Happy MEP-morial Day From The DOL

Back in March, Assistant Secretary of Labor Phyllis Borzi testified before a Senate committee, expressing concern about whether open MEPs can be treated as single plans under ERISA since there is no ...
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Adam C. Pozek |

403(b) Plan Termination: Fact or Fiction?

Over the last several years, the answer has been a little of both. Beginning with the 2009 effective date of the IRS overhaul to the 403(b) regulations, it was establised that 403(b) plans could, ...
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Adam C. Pozek |

In Search of the Elusive Non-ERISA 403(b)

Crikey! We’ve just discovered the rare non-ERISA 403(b) plan meandering along, oblivious to such details as filing Form 5500 or worrying about fiduciary responsibility. Wait…could it be this harmless ...
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