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The year in DC plans: Confidence up, savings to follow?

11 November 2015
Regli-JinnieFrom a regulatory perspective, 2015 has been a good year for defined contribution (DC) retirement plans. The Employee Benefit Research Institute (EBRI) 2015 Retirement Confidence Survey reported that 22% of workers are now very confident about their retirement savings, up 4% from 2014 and 9% from 2013 survey results. Despite the rising confidence, only 67% percent of workers have reported they or their spouses have saved for retirement, which is statistically equivalent to the findings from 2014.

As we roll into 2016, we ll begin to see the effects of most of 2015's legislative updates. We hope to see a continued rise in retirement confidence among American workers. Here are the regulatory updates from 2015 that will affect defined contribution plans:

Announcement 2015-19 (January): Changed the determination letter program for qualified plans. Effective January 1, 2017, the regular five-year determination letter cycle for individually designed plans will be terminated. Determination letters will only be required upon initial plan qualification and plan termination. Effective July 21, 2015, off-cycle determination letter applications will no longer be accepted.
Form 5500 SUP (effective January 2015): Offers a paper-only form to supplement the Form 5500 for 2015 and later plan years. Only plans that are exempt from mandatory Internal Revenue Service (IRS) electronic filing may use this form.
Rev Proc 2015-28 (April): Updated the corrections procedures under the Employee Plans Compliance Resolution System (EPCRS) to provide some relief for missed deferral penalties.
Rev Proc 2015-32 (June): Granted late filer penalty relief for Form 5500-EZ filers. The new payment per submission is $500 for each delinquent return for each plan up to a maximum penalty of $1,500 per plan.
H.R. 3236, Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 aka The Highway Funding Bill (July): Extended the Form 5500 deadline for taxable years beginning after December 31, 2015. For calendar-year plans, the deadline extends from October 15 to November 15 of the following year.

What's on the horizon for 2016? Here are developments you can expect, along with some questions that remain open:

New 2016 limits announced: Most limits remain unchanged, as shown in the table below.
Pension Limit Item IRC ?? 2016 Limit 2015 Limit
Defined Benefit Plan Limit 415(b)(1)(A) $210,000 $210,000
Includable Compensation Limit 401(a)(17) $265,000 $265,000
401(k)/403(b) Elective Deferral Limit 402(g)(3) $18,000 $18,000
401(k)/403(b) Catch-Up Contribution Limit 402(g)(3) $6,000 $6,000
Highly Compensated Employee 414(q)(1)(B) $120,000 $120,000
457 Deferral Limit 457(e)(15) $18,000 $18,000
Defined Contribution Plan Limit 415(c)(1)(A) $53,000 $53,000

Preapproved document restatement period will wrap up April 30, 2016. If your plan is based on a prototype or volume submitter document and you haven t heard from your plan consultant yet, it's time to check in! For more information, read here.
With the added relief provided by Rev Proc 2015-28, will we see an increase in plans adopting automatic enrollment provisions?
Will the IRS issue filing deadline relief for Form 5500 filers for direct filing entities?
Proposed changes by the U.S. Department of Labor (DOL):
  • Changes to fiduciary conflict of interest rules are currently on hold until 2016. This pending proposal would further define fiduciary for employee benefit plans; anyone who provides investment advice or recommendations to an employee benefit plan, participant, beneficiary, fiduciary, or IRA owner as a fiduciary under ERISA.
  • Changes to the exemptions in the Fair Labor Standards Act (FLSA), which haven t been updated since 2004. Proposed changes would update the salary level and revise the white collar exemption that applies to executive, administrative, professional, outside sales, and computer employees.

  • With lots of new legislative updates on hold as we near the end of 2015, it is clear there is still much in store for 2016, so stay tuned for more information!

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