| Provisions Effective Retroactively |
PPA |
- Penalty free withdrawals for reservist who served at least 179 days. Effective for distributions occurring after 9-11-2001
This was addressed in Notice 2007-7
|
Section 827 |
- DB Issue: Cash balance and hybrid plans — after 6-29-05
|
Section 701 |
| Provisions Effective on Enactment Date: Aug. 17, 2006 |
|
- EGTRRA Permanency, including Saver's Credit
|
Section 811, 812 |
- PBGC Missing Participant Program for Defined Contribution Plans Awaiting PBGC guidance
|
Section 410 |
- Hardship withdrawal for beneficiary
This was addressed in Notice 2007-7
|
Section 826 |
- State withholding laws preempted, permitting automatic enrollment in all states
|
|
- States prohibited from reducing unemployment benefit for individual who rolls over retirement plan distribution
|
Section 1105 |
- Deduction rules for combination of defined benefit and defined contribution changed for contributions for taxable years after 12-31-05
|
Section 803 |
- 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) This was addressed in Notice 2007-7
NOTE: Charitable Donations from IRAs ends after 12-31-07
|
Section 1201 |
| Provisions Effective for Plan Years Beginning on or After Jan. 1, 2007 |
|
- Top heavy vesting on employer contributions
This was addressed in Notice 2007-7
|
Section 904 |
- Statement requirements Good faith guidance addressed in FAB 2006-3
Awaiting guidance and model benefit statements
|
Section 508 |
- Nonspouse inherited rollover, for distributions occurring after 12-31-06
This was addressed in Notice 2007-7
|
Section 829 |
- Default Investment Arrangement for Participants Who Fail to Exercise Investment Election Awaiting guidance
|
Section 624 |
- Prohibited Transaction Exemption for Investment Advice
This was addressed in FAB 2007-1
Awaiting guidance on computer models
|
Section 601 |
- Divestiture of Employer Stock in non-ESOP plans; Notice requirement
Notice addressed in Notice 2006-107
|
Section 901; 507 |
- Tax refund may be sent to an IRA
|
Section 830 |
- 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
This was addressed in Notice 2007-7
Awaiting IRS Model 402(f) Notice
|
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
Small Plan Form 5500 under development
|
Section 1103 |
| Provisions Effective for Plan Years Beginning on or After Jan. 1, 2008 |
|
- Automatic Enrollment 401(k) Safe Harbor
|
|
- Excess contributions refunded in six months
|
|
- No gap period income for ADP and ACP Corrections (for all plans not just auto enroll) GAP still applies to excess deferrals
- 90 days to "revoke" first automatic enrollment deferrals
Pending IRS guidance and possible model amendment for QACA
|
Section 902 |
- Direct rollover to Roth IRAs
Awaiting IRS guidance
|
Section 824 |
- Funding Notice for single employer defined benefit plans
|
Section 501 |
- Electronic display of Form 5500
Deferred to Plan Year 2009
|
Section 504 |
- Bonding increase for plans that hold employer securities, $500,000 to $1,000,000
|
Section 622 |
- Joint and 75 percent survivor annuities
|
Section 1004 |
| Provisions Effective for Plan Years Beginning on or After Jan. 1, 2009 |
|
|
Section 1107 |
| Provisions Effective for Plan Years Beginning on or After Jan. 1, 2010 |
|
|
Section 903 |
