Pension Protection Act (PPA) Effective Date List |
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August 31, 2006 |
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| What are the effective dates of the major defined contribution and IRA provisions of PPA? E-mail Alert 2006-18, Rev. 08/31/06 | ||
| Notes about the list: | ||
| » | The defined benefit effective dates will be in a future list (though a few appear below). | |
| » | The dates below are generally not for collectively bargained nor for governmental plans (those plans usually have two additional years beyond what is listed below). | |
| » | For IRAs, the effective date is for taxable years rather than plan years. | |
| Provisions Effective Retroactively | PPA |
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| » | Penalty free withdrawals for reservist who served at least 179 days. Effective for distributions occurring after Sept. 11, 2001 | Section 827 |
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DB Issue: Cash balance and hybrid plans - after June 29, 2005 | Section 701 |
Provisions Effective on Enactment Date: August 17, 2006 |
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EGTRRA Permanency, including Saver's Credit | Section 811, 812 |
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PBGC Missing Participant Program for Defined Contribution Plans (after PBGC issues Regs) | Section 410 |
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Hardship withdrawal for beneficiary (IRS to issue regs within 180 days of enactment) | Section 826 |
| » | State withholding laws preempted, permitting automatic enrollment in all states | Section 902 |
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States prohibited from reducing unemployment benefit for individual who rolls over retirement plan distribution | Section 1105 |
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Deduction rules for combination of defined benefit and defined contribution changed for contributions for taxable years after 12-31-05 | Section 803 |
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Increase in penalties for coercive interference with the exercise of ERISA rights. Now $100,000 and/or 10 years imprisonment (was $10,000 and/or one year) | Section 623 |
| » | Tax-free distributions from IRAs for charitable purposes (for 2006 and 2007 only) | Section 1201 |
Provisions Effective for Plan Years
Beginning on or After
Jan. 1, 2007 |
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Top heavy vesting on employer contributions | Section 904 |
| » | Statement requirements | Section 508 |
| » | Non-spouse inherited rollover, for distributions occurring after 12-31-06 | Section 829 |
| » | Default Investment Arrangement for Participants Who Fail to Exercise Investment Election | Section 624 |
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Prohibited Transaction Exemption for Investment Advice | Section 601 |
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Divestiture of Employer Stock in non-ESOP plans; Notice requirement | Section 901; 507 |
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Tax refund may be sent to an IRA | Section 830 |
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Additional IRA contribution in certain bankruptcy cases (from 1-1-07 to 12-31-09) | Section 831 |
| » | Indexing Saver's Credit and deductible IRAs and Roth IRAs | Section 833 |
| » | Rollover/402(f) Notice change from 30 to 90 day range to a 30 to 180 day period | Section 1102 |
| » | Rollover of after-tax amounts in annuity contracts | Section 822 |
| » | Form 5500 simpler requirements for employers with less than 25 employees. Form 5500-EZ threshold from $100,000 to $250,000 | Section 1103 |
Provisions Effective for Plan Years
Beginning on or After
Jan. 1, 2008 |
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Automatic Enrollment 401(k) Safe Harbor, » Excess contributions refunded in six months, » No gap period income, (for all plans not just auto enroll) » 90 days to "revoke" first automatic enrollment deferrals |
Section 902 |
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Direct rollover to Roth IRAs | Section 824 |
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Funding Notice for single employer defined benefit plans | Section 501 |
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Electronic display of Form 5500 | Section 504 |
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Bonding increase for plans that hold employer securities, $500,000 to $1,000,000 | Section 622 |
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Joint and 75 percent survivor annuities | Section 1004 |
Provisions Effective for Plan Years
Beginning
on or After
Jan. 1, 2009 |
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Plan Amendments | Section 1107 |
Provisions Effective for Plan Years Beginning on or After
Jan. 1, 2010 |
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| » | DB(k) plan | Section 903 |
Click here for information on our eSeminar on the new Pension Law. Click here for information on Newkirk's Booklet: 2006 Pension Law Changes: What Every Employer Needs to Know |
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| Resources: | ||
Pension Protection Act PPA Articles on our web site: |
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Pension Protection Act of 2006 - An Overview
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Bill Grossman, QPA |
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| Back to Commentary Index | ||