Fidelity reports average 401(k) balance up 12.9% in last 12 months. But let’s not live in the moment.

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It’s a clunker of a headline, but there’s an important point to make.

Yes, it’s good news that Fidelity reported last Friday. The average account balance for participants in 401(k) plans they administered rose to $91,000 for the quarter ended June 30, 2014, an increase of 12.9% in the last 12 months.

But let’s not live in the moment. The issue of retirement readiness is still a big problem in this country. Those of us in the retirement plan business must continue to work hard with employers to encourage their employees to increase their rate of saving.

Retirement savings is not just an issue in this country. Some individuals see the issue on a worldwide basis. Dawid Konotey-Ahulu, for example is the founder and co-chief executive of Mallowstreet, a London-based social media platform that connects the pensions and insurance industries. He takes a grim global view of the situation.

Writing in Workplace Pensions, he warns that unless we deal with five great challenges, we will face dire consequences for generations to come. The first four, he says, are

  1. Global security
  2. Sustainable living
  3. Global health
  4. The economy

The fifth global challenge he says is

… inadequate retirement resources – the pensions crisis. We are living much longer than our parents and grandparents. Some 40 per cent of girls born today will live to be 100. And, by 2060, the UK expects to have half a million centenarians. But we’re also contracting chronic illnesses in old age, and the cost of being elderly is high and climbing.

Like many of us, he believes that government is unlikely to provide much assistance in the future. The government he is talking about, of course, is his own in the U.K. It’s much the same here in the U.S. In other words, employees are on their own to supplement Social Security.

But there’s a big difference.  The U.K. has a much different attitude about retirement savings than we have. Auto-Enrollment in the U.K. is the law.

Image: The Wiley Life Science Blog reporting on University of Pittsburgh  research Why Living in the Moment Is Impossible.

What’s a fiduciary to do?

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Admit it: Your company, as a 401(k) sponsor, and company decision makers who direct plan operations (including in-house trustees), are ERISA fiduciaries. Don’t quibble about this but take a step back and figure out what to do about it.

Some Basic Steps

You’ve read about investment advisors who can assist in performing investment duties and fiduciary insurance for claim protection (this insurance should not to be confused with the required ERISA fidelity bond that protects the plan, not the fiduciaries). Those options may make sense for you, and may not. But, whether or not you use an investment advisor or purchase fiduciary insurance, there are other more basic steps to take.

Bear in mind that retirement plan fiduciaries do not have to make perfect decisions. For example, they don’t necessarily have to select the cheapest mutual funds in the market for their plan’s investment array. But they do need to deliberate on their investment decisions including the periodic review of investment results.

This follows because cases which question fiduciary investment decisions frequently turn on the nature of the process followed by plan fiduciaries rather than the substance of the resulting decision. In other words, a “correct” investment decision reached in a flawed decision making process is still subject to question.

So, fiduciaries need to deliberate and make considered decisions. And the best way to prove such deliberation is documentation of the decision making process. Such documentation can take the form of meeting minutes, memos or committee resolutions. There are no hard and fast rules on how to do this. The bottom line is that any reasonable written record of how and why the fiduciaries made their decision will work to protect them from breach of duty claims.

Fee Disclosure Questions to Answer

Also consider the Section 408(b)(2) fee disclosure rules that have been in effect since August 2012. The specific matters that plan fiduciaries must consider have been expanded by the new fee disclosure rules. “Responsible plan fiduciaries” have to evaluate each provider’s fee disclosure statement to determine

  1. Are provider fees reasonable?
  2. Has the provider’s fee disclosure document itself meets all of the requirements of the fee disclosure rules?
  3. Have your plan fiduciaries done this?
  4. Have those fiduciaries made a written record of their evaluation of the provider fee disclosures?
  5. Do your plan fiduciaries meet regularly to review the plan’s investment performance and provider fees?

A “no” answer to any of these questions is a red flag.

Need help with any of this? Plan service providers can provide invaluable assistance. Third party administrators (TPAs) can help benchmark provider fees so fiduciaries have some guidelines on “reasonable” fees. Investment advisors can assist in selecting investments for the plan and in monitoring investment results. And they can help with documentation of fiduciary decisions. But the ultimate responsibility for these matters likely falls on the shoulders of your in-house fiduciaries.

Helpful Guidelines for Recent Court Cases

You may have seen commentary on recent court decisions and settlements that involve multi-million dollar recoveries against retirement plans and their fiduciaries. These court decisions get the headlines but some less publicized decisions provide helpful guidelines.

Consider the U.S. Supreme Court case that can help control plan liabilities and related fiduciary exposure.  The Supreme Court’s 2013 decisions in Heimeshoff v. Hartford Life & Accident Insurance Co. demonstrates the effectiveness of the most important provision that probably is not in your plan.

Heimeshoff upheld the validity under ERISA of a plan provision which required any suit to recover plan benefits to be filed within a three (3) year period after a proof of loss is due under Wal-Mart’s insured disability plan. So, even a valid benefit claim by a plan participant cannot be pursued in court after the expiration of a claim limitation period provided in the plan document (that’s if the period is reasonable in length and there is no controlling statute to the contrary).

For states like Illinois, which provides a “borrowed” ten (10) year statute of limitations for ERISA suits to collect benefits, the imposition of a two or three year limitation period through the plan document can provide considerable additional protection.

The bottom line is that there is no downside to this kind of provision. It should be in your 401(k) plan document and summary plan description, and it should be there now.

Recommendations

Fiduciaries do need to deal with expanded liabilities from the changing regulatory and judicial landscape. Employers, plan administrators, HR staff and plan service providers should make sure that plan fiduciaries meet regularly to discuss plan business and document their deliberations. If you have any concerns about the prior conduct of plan fiduciaries, make sure you consult top notch plan service providers – and keep their advice confidential by dealing through independent legal counsel and not your company’s regular corporate or benefits lawyer.

Image: CanStockPhoto

IRS opens window for Pension Protection Act Restatements

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If you’re an employer who sponsors a 401(k) or profit sharing plan, it’s time to amend and restate your plan.

Qualified retirement plans must operate in accordance with their plan documents. Ongoing legal and regulatory changes in retirement plan rules frequently require plan sponsors to amend and restate their plans to keep their documents compliant with the IRS.

As a result, there are frequent changes in the laws and regulations that require changes to plan documents. In most cases, these changes are not major ones and can be handled by “snap-on” or interim amendments. Periodically, however, the plan must be rewritten in its entirety because of the number and complexity of the changes which is referred to as a “Restatement”.

The IRS requires that prototype documents and volume submitter plans must be rewritten, reviewed and approved by the IRS, and readopted by employers once every six years to conform with tax law changes.  The IRS has now directed 401(k) plans to begin a new restatement cycle that started on May 1, 2014 and ends April 30, 2016.

It’s important that you understand why your plan document must be restated. What follows is a non-technical explanation in Question and Answer format.

Why do I need to keep amending my plan?

Qualified plans are governed by a set of Federal laws enacted by Congress and regulated by various agencies. The IRS is responsible for oversight of the tax aspects of retirement plans, and the DOL is responsible for reporting, disclosure and fiduciary aspects of retirement plans.  The result is a continual change in the laws due to changing legislation and regulations issued to oversee compliance with the laws. As a result, there are frequent changes in the law but in most cases they are not major ones. A requirement to have a qualified retirement plan is that it must be in writing. This means that as the laws change, your plan must generally be amended to reflect the changes.

Why do I have to restate my plan now?

On August 17, 2006, President Bush signed into law the Pension Protection Act of 2006 (“PPA”) which is the most comprehensive pension reform legislation since ERISA was enacted in 1974. The PPA, which comprises approximately 400 pages, significantly affects plans in many ways including:

  • Strengthening plan reporting and participant disclosure rules.
  • Requiring stricter funding rules for single-employer and multiemployer defined benefit pension plans.
  • Resolving legal uncertainty surrounding cash balance and other hybrid defined benefit plans.
  • Allowing plan fiduciaries to give investment advice to participants.
  • Making permanent significant tax retirement savings incentives enacted under prior law.

When must our plan be restated?

All retirement plans were required to comply with the PPA in operation according to the effective date of each provision beginning in 2006. Employers were required to adopt interim EGTRRA amendments covering these provisions over the past several years which your retirement plan adopted. Employers must now amend and restate their written plan documents to conform to the way the plan has been operated, by incorporating the changes made by the PPA.

The IRS issued a Revenue Procedure that implemented a formal (and complicated) system under which all plan documents are required to be restated by specified dates depending upon the type of plan document and the employer EIN. This Revenue Procedure does, however permit Plan Sponsors who use pre-approved plans, i.e., prototype and volume submitter, to extend the due date to April 30, 2016.

Why does the restatement consist of?

Once the plan has been reviewed, additional requested changes have been made (if any) and the restated documents are drafted, they should be read very carefully. The final signature-ready documents may consist of the following:

  1.  A restated Plan Document or Adoption Agreement;
  2.  A resolution adopting the restated document;
  3. A separate trust document in some cases; and
  4. A restated Summary Plan Description that must be distributed to all participants and beneficiaries.

 Are there any special considerations when replacing one plan document with another?

Special care must be taken to ensure that certain benefits called “protected benefits” are not unintentionally eliminated or reduced. Protected benefits include forms of distributions such as lump sums and annuities and timing of distributions such as an early retirement provision.

Should my restated plan be filed with the IRS for a Determination Letter?

An employer may apply for a Determination Letter, a document issued by the IRS formally recognizing that the plan meets the qualifications for tax-advantaged treatment. The IRS has already reviewed the language used in the pre-approved plans mentioned above, prototype and volume submitter.

Those employers using pre-approved plans automatically have assurance that the language used in their plan satisfies the IRS requirements (assuming no changes are made to what was approved).

Employers who adopt pre-approved plans that have coverage or nondiscrimination issues or have made modifications to the document will generally want to apply for a Determination Letter.

Can we rely on the Determination Letter?

Yes. The Determination Letter can be viewed as a type of insurance policy. If you follow the approved terms of the plan and the operational processes that were submitted for review (if such processes were submitted), then the IRS will not disqualify your plan. This is true even if the IRS made a mistake in approving a particular plan provision or process (as long as the Determination Letter application was accurate).

Does the IRS charge a fee for a Determination Letter?

The IRS generally charges a User Fee to review a “Determination Letter” application. This fee is between $200 and $ 1,800, depending on the plan’s design and the type of plan document. However, this fee may be waived for certain small employers that establish new plans.

 What does it cost for the plan restatement?

The cost of restating a plan will vary, depending primarily on the type of plan. Factors that affect the plan restatement cost include:

  1.  Plan design
  2. Plan sponsor demographics
  3.  Number of contribution types;
  4.  Type of plan document structure
  5.  Preparation of IRS Determination Letter submission, if applicable

No two plans or companies are exactly alike so an appropriate fee is based on the specific facts and circumstances. The cost to restate the plan for IRS compliance may be paid from the plan assets if permitted by the plan document.

What happens if I fail to amend or restate my plan on a timely basis?

If you miss the deadline for amending or restating your plan, then you can avoid plan disqualification by using an IRS correction program. Under this program, the IRS will require that you pay a sanction and submit an updated plan. The sanction can vary depending on the circumstances.  However, it is significantly higher if the IRS discovers the missed deadline than if you voluntarily go to the IRS when you discover the missed deadline. In addition, there would be the cost associated for our services to update the plan and prepare the application to the IRS.

 Should I consider making any plan design changes now?

Yes. You should review your plan as part of the restatement process. Plan design changes can be more efficiently done as part of the restatement process.

Conclusion

It is the responsibility of the plan fiduciary to ensure that the plan is updated and signed by the  April 30, 2016 deadline. Because the restatement process can be time consuming it is important that this task is included in the planning process to ensure the restatement deadline is met.

Image: Can Stock Photo, Inc.

The Deluge of Affordable Care Act Regulations: What Employers Need to Know

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There has been a deluge of regulatory activity involving the Affordable Care Act (“Obamacare”), or the ACA. Some developments, such as the general postponement of the employer mandate until 2015 (and the recent postponement until 2016 for employers with 50-99 full time equivalent employees), have received significant press attention. Others involve details of interest primarily to lawyers and insurance companies.

The most recent ACA regulatory developments that may be of interest to employers and HR professionals include

  1. Wellness Programs
  2. The Mini-Med Plan Lives On?
  3. Discrimination Ban

Here are the details.

Wellness Programs

Recently issued regulatory FAQs deal with a number of topics including wellness programs that punish tobacco users with higher premiums. The expanded rules provide details on how employers can offer a reward of up to 50 percent of the cost of group health plan coverage for tobacco non-users or, alternatively to smokers who participate in programs that are directed at preventing or reducing tobacco use. The highlights of the new FAQs include:

A compliant wellness plan that charges tobacco users a premium “surcharge” (that is, it offers a premium reduction for non-use) must also make the premium reduction available for employees who complete tobacco cessation education program that is offered at the time of initial enrollment or annual reenrollment.

For smokers who do not undertake the cessation education program, the premium surcharge can remain in place for the balance of the plan year. This is because the plan is not required (but is permitted) to provide another opportunity to enroll in the program later in the plan year.

Wellness programs which condition any premium “reward” on attaining a particular standard (such as obtaining a stated weight reduction or cholesterol level) must offer a reasonable compliance alternative to those who cannot attain the standard because it is medically inappropriate.

The FAQs make it clear that the participants’ doctor (not a physician working for the program) should recommend an alternative compliance activity, such as participation in a weight reduction program for a participant who cannot attain a stated weight reduction for medical reasons.

The wellness program, not the individual’s doctor, can then select a specific compliance activity (such as a particular weight loss program) but cannot be involved in the determination of whether that program should be offered to any particular participant for medical reasons.

For now, older smokers in particular may have a reprieve from the maximum premium penalties permitted under ACA rules. This is because of the ACA enrollment system that restricts the disparity in premiums between younger and older workers. This “glitch” will restrict enforcement of the maximum premium penalty at least until June, 2014 in accordance with a White House announcement. Market forces and state-imposed limits may also restrict smoker surcharges, which now average around 15 percent of premiums.

The Mini-Med Plan Lives On?

For larger employers, the prospect of covering their employees with a “fixed-indemnity” plan is still alive under the ACA.

A recent Wall Street Journal article reports that AlliedBarton Security Services is offering its employees a low cost, non-compliant fixed indemnity plan as an alternative to a plan that meets ACA requirements. It expects that many of its security guard employees will elect the inexpensive coverage (say $80 per month) that pays a fixed amount for specific services regardless of actual cost. This would include plans that, for example, pay a flat $70 for a doctor visit and $20 towards each prescription. Catastrophic coverage is not included and the plan can carve out areas from coverage such as hospitalization and mental health services.

This type of coverage has been criticized as substandard but still be may popular with younger, low paid workers who can spend less on cheaper coverage and even incur a penalty for not having ACA-compliant coverage for less cost than the cost of their employer’s more expensive plan.

The bottom line for employers is that, if they offer at least one plan that meets ACA requirements, they may not be penalized by failing to offer “affordable coverage” to their employees. Regulators are aware of this situation and do not view it favorably.

Recent guidance provides different requirements for fixed-indemnity group and individual policies, and it is unclear how these rules will impact group health plans when the employer mandate kicks in for larger employers in 2015.

Discrimination Ban

The ACA extended a ban on discrimination in health care benefits that has applied to self-insured plans for years to fully insured plans. The ban prohibits group health insurance plans from favoring highly compensated employees in terms of eligibility for such benefits or the value of such benefits.

The general intent is to prohibit employers from offering enhanced or subsidized health care benefits to highly compensated management employees while at the same time not providing equivalent health benefits to rank and file employees.

Enforcement of the new ACA provisions, which contain severe financial penalties for non-compliance, was formally postponed until publication of new IRS regulations which were expected to be in place by 2014.

Recently, Treasury officials have advised that there will be further delay while the IRS wrestles with related regulatory concerns including the thorny issue of whether an employer violates the ACA non-discrimination rules if it offers the same coverage to all employees and rank and file employees choose to obtain coverage elsewhere, such as through a government sponsored health insurance exchange. While the IRS sorts this out, no enforcement action will be taken.

However, it is still advisable for employers with fully insured plans to avoid obvious mistakes, such as offering executives free or subsidized health coverage, providing health coverage only to management employees, and making benefits available to dependents of highly paid executives that are not available on equivalent terms to dependents of other covered employees.

Employers should avoid offering extended group health coverage (other than as required by COBRA) to departing executives as part of a severance package. This practice not only violates the ACA non-discrimination rules that the IRS is likely to finalize, but also ignores the terms of the group health plan, which typically extend coverage only to employees who satisfy an active employment requirement.

Image: Can Stock Photo, Inc.

Money really does grow on trees, but you have to be able to see it

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The individual checking his email pictured above is someone who didn’t see the money tree. He’s a graduate student that was part of a research study cited in the Original Research Article, Failure to see money on a tree: inattentional blindness for objects that guided behavior by Ira E. Hyman Jr., Benjamin A. Sarb and Breanne M. Wise-Swanson.

The term Inattentional Blindness , the focus of the study, is a psychological lack of attention not associated with any vision defects or deficits.

The researchers say that they documented a new form of Inattentional Blindness in which people fail to become aware of obstacles that had guided their behavior. In one of the two studies cited, they found

Cell phone talkers and texters were less likely to show awareness of money on a tree over the pathway they were traversing. Nonetheless, they managed to avoid walking into the money tree. Perceptual information may be processed in two distinct pathways – one guiding behavior and the other leading to awareness. We observed that people can appropriately use information to guide behavior without awareness.

Of the 396 people they observed, only 12 people (3%) walked into the tree branches. The remaining 97% were able to register the tree enough to avoid it, but not being aware enough to take the money. In fact, they did not observe any individual who walked into the tree stopping to take the money.

In other words, Inattentional Blindness occurs when paying attention to one thing causes an individual to miss what others may see as obvious.

Maybe like an employee not contributing to a 401(k) plan that has an employer match?

Just asking.

Understanding the Importance of Family Businesses

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According to research conducted by the Cox Family Enterprise Center, 80 percent of the world’s businesses are family-owned, and 60 percent in the U.S. In fact, in this country, family-run businesses account for more than half of the gross domestic product.

Perhaps neither of the first two statistics are surprising. But, consider that nearly 35 percent of Fortune 500 companies are family-owned businesses. Many large companies also fall into this category, including Ford, Wal-Mart, Lowes and Ikea.

What impact do family-owned companies have? They account for 60 percent of total U.S. employment, and 78 percent of all new jobs. In regard to gender issues, more than 25 percent of family firms expect the next CEO to be a woman.

Despite the diversity in terms of size and industry, family businesses have several characteristics in common. A 2012 article in the Occupational Digest published by the British Psychological Society, What’s So Special About Family Firms?, discusses some of these characteristics.

First, many family businesses are run by owners who have a long-term and generational perspective. In many cases, they see themselves as stewards for the future.

Second, family businesses tend to operate more informally than other businesses. Handshake deals are not uncommon, and things can get done more quickly.

Third, trust-based relationships are an important part of how and with whom they do business. Family businesses form more long-term relationships with suppliers and advisors.

Fourth, meritocracy is not always at work within family businesses. It’s not always the best person who gets hired and promoted. Family nepotism can lead to underperforming companies.

With family businesses making up such an important part of the economy, it’s important that we understand how family businesses view the current economic and regulatory environment.

Family businesses are increasingly concerned about the role government policy is playing in their business planning and future growth. Last year’s Family Enterprise USA Annual Survey of family firms indicated that 91 percent, up from 82 percent the year before, said that external factors were a greater threat to the future of their family business.

According to the survey, this indicates “an even more heightened sensitivity to the role government policy and uncertainty is playing in business planning and development.”

As to government policies affecting family businesses, and all business for that matter, it keeps coming back to the same public policy issues in no particular order. This list is also not all-inclusive: the size of government deficits, reforming the tax code, immigration reform, health care and the minimum wage.

With the current political divide and 2014 being an election year, there is little doubt that much of what worries family business leaders will remain uncertain and will not be resolved.

Editor’s Note: This article originally appeared as an Op-Ed in the Deseret News for which I did the research.

Image: Three Circle Family Business System Model developed in 1982 by Renato Tagiuri and John A. Davis of the Harvard Business School. The family business system is described by the Venn diagram as three independent but overlapping subsystems: business, ownership, and family. An individual in a family business system can be in one of the seven sectors created by the three circles.

The Case of the Vanishing Advisor

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That’s not someone from a Sherlock Holmes story. But it could be very well be my old college buddy Bob (not his real name, of course).

Bob was of the era in which aspiring stockbrokers went to New York immediately upon graduation to be trained by one of the wire houses. Bob came back home as a full-fledged Registered Representative with his new Series 7, and immediately launched his investment career.

But that was then, and this is now. Registered Reps are now called Financial Advisors or Wealth Managers. Firms like Bob’s may have gone through one or more ownership changes or may not even exist anymore. And folks like Bob? Just like the rest of the aging population, they’re retiring.

Cerulli Associates, Inc. the international research firm, provides us some telling statistics:

  • At the end of 2009, 36% of brokers were age 55 or older.
  • Between 2004 and 2009, the total number dropped 1% percent to 334,000.
  • In 2011, the number fell by approximately1.3% or 40,000.

Cerulli projects that the number will decline by another 18,600 over the next five years.

It not just the numbers of advisors that concerns the investment firms. It’s the amount of assets involved. Accenture, the international management consulting firm, estimates that financial advisers past the age of 60 control $2.3 trillion of client assets.

Who is going to replacement them? Reuters columnist, Mark Miller, writes about what many see as a coming brain drain,  Wanted: Financial advisers who aren’t about to hang it up. Miller points out that

The adviser shortage points to an area of opportunity for young people and midlife career changers. The Certified Financial Planner Board of Standards (CFP Board), which grants the CFP certification, is working with colleges and universities to develop and operate CFP training programs, and 360 institutions are participating, a figure that has jumped 30 percent over the past four years.

In the meantime,  with training programs cut back, the emphasis has been recruiting experienced advisors with established books of business.

But waiting in the wings is something that would make Will Smith cringe: what John Shmuel writing in the Financial Post calls the Rise of the robo-advisor. In reality, they are automated advice firms using complex computer algorithms to manage portfolios.

These firms are still in the start-up phase, but growing fast. Wealthfront which calls itself  “the world’s largest & fastest-growing automated investment service” has over $1 billion in client assets since its launch in December, 2011.

Who can say how much these automated services will penetrate the human investment advisory marketplace. If we extend the concept under the umbrella of artificial intelligence which has experienced quantum growth, it could be huge.  As to the social consequences and ethics of artificial intelligence, that’s another matter.

Image from May 2010 issue of Claims Magazine.

IRS Establishes Pilot Penalty Relief Program for Late Form 5500 – EZ Filings

That’s the collective sigh of relief by those business owners who, for whatever reason, haven’t filed Form 5500-EZ for their retirement plans.

It’s a big deal especially for those business owners with so-called Solo-K plans.

401(k) plans were introduced in 1978, but it took a tax change starting in 2002 to allow business owners to contribute substantially more that they would with IRAs, SIMPLEs, and SEPs.

Those new rules applied to both incorporated and unincorporated businesses. Any business that employs only the owner and his or her spouse is a candidate-including C corporations, S corporations, single member LLCs, partnerships and sole proprietorships.

Now practically every major financial service company, e.g., insurance companies, brokerage firms, and mutual funds, offers a low cost Solo 401(k) plan. So far so good.

There’s a flashing yellow compliance light. A Solo-K like a regular 401(k) plan must meet certain ERISA and Internal Revenue Code requirements. And one of those requirements is the obligation to file Form 5500-EZ if plan assets exceed $250,000 even if the business owner (and spouse) are the only participants.

Sometimes that requirement gets lost in translation, and a self-employed or small business owner whose plan exceeds that threshold doesn’t file the return. It may be because he or she missed the filing after being exempt for several years before the $250,000 threshold was crossed, or just didn’t get or read the memo.

Form 5500-EZ is due no later than 7 months after the end of the plan year unless extended 2 ½ months. If not filed timely – or at all – the IRS can assess substantial penalties, i.e., $25 per day, up to $15,000 per return.

Relief, however, is available to those plans covering more than just business owners. These plans can take advantage of the Department of Labor’s Delinquent Filer Voluntary Compliance (DFVC) program. Penalties are capped at $750 for one delinquent Form 5500 and $1,500 for more than one year, however many years are involved. Many employers take advantage of the DFVC program.

Until recently, business owners were out of luck since they were not eligible for the DFVC. But on May 9, 2014, the IRS published Rev. Proc. 2014-32 establishing a temporary one-year Pilot Program providing administrative relief from the imposition of penalties for failure to timely file Form 5500-EZ and similar filers.

If you’re a business owner who hasn’t filed your retirement plan’s Form 5500-EZ, the meter is ticking. The relief provided under this revenue procedure becomes effective June 2, 2014 and will remain in effect until June 2, 2015.

Image: Phew bumper stickers and other Phew gifts are available at Zazzle.

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