Tag Archives: Benefits Alert

Overview of the SECURE Act’s interim final rule

The Department of Labor’s Employee Benefits Security Administration has published an interim final rule (IFR) describing calculation methodology and model language to “obtain relief from liability” in the presentation of “Lifetime Income Illustrations” applicable to ERISA-covered defined contribution (individual account) plans, the intent of which is likely a regulatory safe harbor.

The IFR includes several assumptions that plan administrators and providers of lifetime income models and illustrations can use to adhere to the lifetime income disclosure requirement of Section 203 of the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 at least once every 12 months. This Milliman Benefits Alert provides more perspective.

Coronavirus-related distribution considerations for DB and DC plan sponsors

A plan sponsor may wish to offer coronavirus-related distributions (CRDs) during 2020 from a single-employer defined benefit (DB) plan as well as, or in addition to, a CRD from its defined contribution (DC) plan. Lump-sum payments from a DB plan may be treated as CRDs, similar to withdrawals from DC plan accounts.

If a plan sponsor chooses to offer CRDs from both the DB and DC plans, careful joint plan administration coordination needs to be taken as the total CRDs to an individual cannot exceed $100,000. In this Benefit Alert, Milliman’s Bret Linton, Vicki Mazzie, and Vanessa Vaag explain in more detail coronavirus distributions for DB plans under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.