Following up on our recent blog post, SECURE 2.0’s Required Changes to Annual Funding Notice Become Effective in 2025, the Department of Labor released Field Assistance Bulletin 2025-02 on April 3, which addresses compliance questions regarding the required changes to AFNs under SECURE 2.0 and includes two updated model AFNs incorporating these changes.[1]
Pension Plans
SECURE 2.0’s Required Changes to Annual Funding Notices Become Effective in 2025
By Justin Alex & Alex Scharr on
SECURE 2.0 introduced many changes for retirement plans, including updated disclosure requirements for a defined benefit plan’s annual funding notice (AFN). These updated AFN disclosure requirements apply for all plan years beginning after December 31, 2023. For calendar-year defined benefit plans, the first AFNs subject to the revised requirements will be due by April 30…
PBGC Technical Update on Accelerated Premium Filing Due Dates for 2025
By Justin Alex & Alex Scharr on
As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025. This modification only applies for 2025.
Under ERISA Section 4007, the PBGC determines when premium filings—the submission of required data and payment…
Reminder: Is Your Individually Designed 403(b) Plan Eligible for a Determination Letter?
By Jesse T. Foley & Katrina McCann on
Plan sponsors of Code Section 403(b) tax-sheltered annuity plans (“403(b) plans”) that have not already done so may want to consider applying for an IRS determination letter or planning and budgeting for the process next year if they are not yet eligible.
In June, the IRS determination letter program became available to a second group…