Monthly Archives: July 2020

Well, I was right about auto enrollment

People are flawed, except for saints and Popes. One of my many flaws is that I enjoy being right. I love predicting things and being right (such as the end of revenue sharing, and a former employer going out of … Continue reading

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It’s not 95%

Obi-Wan Kenobi once said that only Siths deal in absolutes. Having an ERISA expert saying publicly that there is a 95% that the recently proposed new, new Fiduciary rule (or is it new, new, new?) will be implemented, it’s not … Continue reading

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Don’t forget that the RMD Rules are different for 2020

While the 4 Questions during the Passover holiday asks why this night is different than all other nights, the Internal Revenue Service (IRS) has reminded us that this year for required minimum distributions (RMDs) are different than all other years. … Continue reading

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We will get PEP guidance soon

With less than six months before the launch of pooled employer plans (PEPs) comes word that the Department of Labor (DOL) has some proposed regulations on tap. The Office of Management and Budget’s Office of Information and Regulatory Affairs website … Continue reading

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That Termination Fee

Signing up with a third-party administrator (TPA) is like getting married, you come in with the best of intentions and you never think that things won’t work out. In 22 years of being an ERISA attorney, I have never met … Continue reading

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The Rosenbaum Law Firm Review

My latest newsletter can be found here

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The threat of cyber theft from 401(k) accounts is real

The Matt Hutcheson and Jeff Richies of the world that steals from 401(k) plans where they are the fiduciary will ultimately get caught because when you steal millions, the plan sponsor and other plan providers will notice. Someone stealing from … Continue reading

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ERISA litigators are always at the cutting edge

While every large 401(k) plan is a target for a class-action lawsuit over costs, I believe the years of litigation and fee disclosure regulations will exhaust the number of class-action lawsuits, as well as courts taking a more negative view … Continue reading

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The future of conferences

With COVID still in full bloom, I’m concerned over the future of national conferences. While NAPA is trying to hold their postponed event from April in September at Universal Studios in Orlando, they have wisely added a virtual feature for … Continue reading

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No one will be happy with the Fiduciary Rule

I used to joke that no matter what I did, I could never make my parents happy. The same can be said with any attempt to change the fiduciary rule. This is going to be the Department of Labor’s (DOL’s) … Continue reading

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