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Last month we provided an analysis of the Worker, Retiree, and Employer Recovery Act of 2008 (WRERA), and earlier this week we shared a Summary of Key WRERA Provisions. Here are links to two additional summaries:

Responding to Employee Benefits Provisions of the Worker, Retiree and Employer Recovery Act of 2008 discusses the defined contribution plan changes under the WRERA and provides some action items:

  • 2009 Required Minimum Distributions – Plan sponsors should review their plans to determine if an amendment is needed to address this change. Amendments must be adopted on or before the last day of the plan year beginning on or after January 1, 2011. For a calendar year plan, the plan must be amended on or before December 31, 2011. Plan sponsors may want to review and possibly revise distribution notices.

  • Rollovers to Roth IRAs – Distribution notices should be updated.

  • Gap Period Income – Plan sponsors should review their plans to determine if an amendment is needed to address this change. Amendments must be adopted on or before the last day of the 2009 plan year.

  • Non-Spouse Rollover Rules – Plan sponsors should review their plans to determine if an amendment is needed to address this change. Amendments must be adopted on or before the last day of the 2009 plan year. In addition, distribution notices should be updated.

  • EACA – This sponsors with EACAs should consider whether they wish to change the default investment to an investment that is not a QDIA, and if a change is desired, they must review their plans to determine if an amendment is needed to address this change. Amendments must be adopted on or before the last day of the 2009 plan year if retroactive application to the first day of the plan year is desired.

It also discusses the funding shortfall, at-risk plan, and lump sum distribution changes and action items for defined benefit plans.

New Pension Bill Offers Some Relief in Light of Market Turmoil; Technical Corrections Enacted also provides a summary.

  • Provisions Responding to the Economic Crisis

    • One-Year Waiver of Required Minimum Distribution Rules for Defined Contribution Plans and Individual Retirement Accounts
    • Phase-In of Pension Funding Targets
    • Temporary Relief from Freezing of Benefit Accruals for Underfunded Plans
    • Relief for Multiemployer Plans

  • Technical Corrections and Other Changes Related to the PPA

    • Nonspouse Beneficiary Rollovers Made Mandatory
    • Asset Smoothing

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