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Delinquent Contributions and a 7-Business Day Safe Harbor

  
  
  

Last week the DOL announced DOL Proposed Regulation – Amendment of Regulation Relating to Definition of ‘‘Plan Assets’’ Participant Contributions, which provides a safe harbor rule for making employee contributions to small plans.

This comes about a month after Field Assistance Bulletin No. 2008-01 – Fiduciary Responsibility for Collection of Delinquent Contributions, which provides guidance on the responsibilities of fiduciaries and trustees with monitoring and collecting delinquent contributions.

To stay current on all of the current retirement plan rules and regulations, be sure to check out or subscribe to ERISA Rules and Regulations, which can be found at www.erisarulesandregulations.com.

The latest Pension Protection Act Blog post provides a more detailed analysis of the proposed regulation and the changes to Labor Regulation 2510.3-102 Definition of “plan assets”—participant contributions.

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2012 IRS Pension Plan Limits

401(k) Deferral Limit - $17,000

Annual Additions Limit - $50,000

Maximum Compensation Limit - $250,000

Catch-Up Contribution Limit - $5,500

Highly Compensated Employee - $115,000

ESOP 5-Year Distribution Threshold - $1,015,000

ESOP Additional Year Threshold - $200,000

2012 Pension Plan Limits

1989 - 2012 Plan Limits