ERISA & Employee Benefits

Multiple Employer Pension Plan Update

On October 22, 2018, the DOL issued a proposed regulation in response to the August 31, 2018, Executive Order by President Trump to remove regulatory burdens faced by defined contribution multiple employer pension plans ("MEPs"). On July 31, 2019, final DOL regulations on the definition of "Employer" were published in the Federal Register. While there are several possible types of MEPs, the DOL ...

DOL Offers Temporary Penalty Relief for All Multiple Employer Plans not Currently in Compliance with the Special MEP Reporting Requirements

Recently, the Employee Benefits Security Administration (EBSA) of the Department of Labor (DOL) announced guidance and relief (Field Assistance Bulletin 2019-01) affecting Form 5500 annual report submission for multiple employer plans (MEPs). The relief applies to any MEP that, in plan years 2014 - 2017, failed to submit with its Form 5500, a list of participating employers in the MEP, and a good ...

Proposed IRS Regulation Would Eliminate "One Bad Apple" Rule for Multiple Employer Defined Contribution Plans

On July 3, 2019, the IRS proposed a new regulation addressing one problem experienced by multiple employer defined contribution plans (DC MEPs) which are tax qualified as single plans under Section 413(c) of the Internal Revenue Code (the "Code"). Under 413(c), the failure by one contributing employer to meet the qualification rules would result in the disqualification of the entire plan. The ...