What are the effective dates of the major defined contribution and IRA provisions of PPA? Rev. 08/31/06, E-mail Alert 2006-18

• 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 plaqns usually have two additional years beyond what is listed below)
• For IRAs, the effective date is for taxable years rather than plan years.

• Penalty free withdrawals for reservist who served at least 179 days.
  Effective for Distrbutions occurring after Sept. 11, 2001

• DB Issue: Cash balance and hybrid plans - after June 29, 2005

• EGTRRA Permanency, including Saver's Credit

• PBGC Missing Participant Program for Defined Contribution Plans (after PBGC issues Regs)

• Hardship withdrawal for beneficiary (IRS issue regs within 180 days of enactment)

• State withholding laws preempted, permitting automatic enrollment in all states

• States prohibited from reducing unemployement benefit for individual who rolls over retirement plan distribution

• Deduction rules for combination of defined benefit and defined contribution changed for contributions for taxable years after 12-31-05

• 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)

• Tax-free distributions from IRAs for charitable purposes (for 2006 and 2007 only)

• Top heavy vesting on employer contributions

• Statement requirements

• Non-spouse inherited rollover, for distributions occuring after 12-31-06

• Default Investment Arrangement for Participants Who Fail to Exercise Investment Election

• Prohibited Transaction Exemption for Investment Advice

• Divestiture of Employer Stock in non-ESOP plans; Notice requirement

• Tax refund may be sent to an IRA

• Additional IRA contribution in certain bankruptcy cases (1-1-07 to 12-31-09)

• Indexing Saver's Credit and deductible IRAs and Roth IRAs

• Rollover/402(f) Notice change from 30 to 90 day range to a 30 to 180 day period

• Rollover of after-tax amounts in annuity contracts

• Form 5500 simpler requirements for employers with less than 25 employees. Form 5500-EZ threshold from $100,000 to $250,000

• 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

• Direct rollover to Roth IRAs

• Funding Notice to single employer defined benefit plans

• Electronic display of Form 5500

• Bonding increase for plans that hold employer securities, $500,000 to $1,000,000

• Joint and 75 percent survivor annuities

• Plan Amendments

• DB(k) plan