McKay Hochman Company, Inc.

The Worker, Retiree, and Employer Recovery Act of 2008 (WRERA)
Rev. 06/26/09; E-mail Alert 2009-9

PROVISIONS EFFECTIVE RETROACTIVELY FOR PLAN YEARS BEGINNING AFTER DECEMBER 31, 2007
Elimination of gap period income on excess deferrals Article	Section 902
Roth Rollovers to Roth IRAs are no longer tied to income	Section 824
Eligible Automatic Contribution Arrangement (EACA) no longer required to invest contributions for participants without investment elections into a QDIA	Section 902
PROVISIONS EFFECTIVE FOR PLAN YEARS BEGINNING ON OR AFTER JANUARY 1, 2009
Required minimum distributions are suspended for the 2009 year Article	Section 201
PROVISIONS EFFECTIVE FOR PLAN YEARS BEGINNING ON OR AFTER JANUARY 1, 2010
All qualified plans must allow non-spouse inherited rollovers The IRS had previously said this provision was mandatory as of the 2008 plan year; therefore many employers have already implemented this plan change as part of their PPA amendment Article	Section 829
Final EACA requirements	Section 902
PROVISIONS EFFECTIVE FOR PLAN YEARS BEGINNING ON OR AFTER JANUARY 1, 2011
WRERA Plan Amendment *Governmental plans generally have a deadline of two years beyond the effective date stated above, however the WRERA deadline is only one year later	Section 201

Resources:

For more information on WRERA, click here for information or to register for our 401(k) Update eSeminar.

To learn more, call 1-973-492-1880 or e-mail info@mhco.com.