A-2015-19: Changes in Determination Letter Program for Employee Plans
Due to severe resource cuts, the IRS has announced major changes to its Determination Letter program. Effective immediately, the IRS will no longer accept “off cycle” applications. Also, effective 1/1/2017, the IRS will no longer accept ANY applications except in three limited situations:
1. Initial plan set-up
2. Plan Termination
3. Other very limited circumstances yet to be determined
(IRS invites comments by 10/1/2015 on this topic)
Cycle A plans will still be able to file for a determination letter by the current due date of 1/31/2017. After that, the current five-year cycle that was started in 2007 will be eliminated.
The IRS hopes to issue more Model Amendments going forward to help plan sponsors stay in compliance. This change in the determination letter process will place an even heavier responsibility on the plan sponsor, legal counsel, actuaries, and other plan advisors to keep plans in compliance with all legislative and regulatory changes without the benefit of a five-year “check up” from the IRS.
IRS Notice 2015-49: Offer of Lump Sum Payment to Currently Retired Defined Benefit Plan Participants No Longer Allowed
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The Governmental Accounting Standards Board (GASB) has approved the new accounting standards for other post employment benefits (OPEB).
The GASB 45 employer accounting standard for OPEB benefits will be replaced by GASB 75 and the GASB 43 plan accounting standard for OPEB benefits will be replaced by GASB 74. The effective dates will be for periods starting after June 15, 2016 for GASB 74 and for fiscal years starting after June 15, 2017 for GASB 75. FY2018 CAFRs will be prepared based on the new GASB 75 accounting standard. Plans with irrevocable trusts will be required to prepare financial statements under GASB 74 starting in 2017.
The details of these new standards will be posted to the GASB website in late June.
GASB has also approved GASB 73 which is the new accounting standard for pension plans that are not administered through a trust. These plans are less common and are usually for volunteer firefighters. >> Click here to read more.
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Bolton Partners is an employee benefits consulting firm that specializes in actuarial pension consulting and health and welfare consulting for corporate, public sector, and multi-employer organizations. Our sister company, Bolton Partners Investment Consulting Group, provides investment consulting services and benchmarking for both defined contribution and defined benefit plans. The firm was founded in 1981 by Robert Bolton and now has over 100 employees with locations in Baltimore, MD; Washington, D.C.; Boca Raton, FL; Philadelphia, PA; Denver, CO; Atlanta, GA; and Trenton, NJ. Bolton Partners has a national client base, and our sole focus is to provide the best service for our clients.
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- Robert G. Bolton, CEO
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