Susan Quintanar

The Drought Is Over: Recent Legislation Affecting Retirement Plans

BENJAMIN F. SPATER and SUSAN QUINTANAR, May, 2018   New legislation provides several significant modifications affecting retirement plans, effectively eliminating the legislative drought experienced in recent years. Bipartisan Budget Act of 2018 (the “Act”) Hardship Withdrawals Effective for plan years beginning after December 31, 2018, the Act liberalizes the hardship withdrawals provisions for plans that include […]

Missing Participants: Gone but Not Forgotten

SUSAN QUINTANAR and BENJAMIN F. SPATER, December 2016 Plan administrators know all too well the practical challenges associated with the timely payment of benefits to plan participants, especially in those cases where individuals remain unresponsive to plan communications and are presumed missing. Last year, both the Department of Labor (“DOL”) and the Internal Revenue Service […]

Late Deposits — A Timely Topic

SUSAN QUINTANAR, December 2015 —  Plan sponsors need to remain attentive about ensuring that elective deferrals are deposited into their 401(k) plans on a timely basis. Plans may be subject to a higher risk for audit where late deposits are concerned, especially in those cases where there has been a pattern of recurring delinquent deposits […]

Revenue Ruling 2014–9 and Revised Form 5310: Uncertain Compliance Standard for Rollover Contributions

SUSAN M. QUINTANAR and BENJAMIN F. SPATER — On April 3, 2014, the Internal Revenue Service (“IRS”) issued Revenue Ruling 2014-9, which expands on previous IRS guidance addressing how a plan administrator may “reasonably conclude” that a potential rollover contribution is a qualified distribution and will not adversely affect the recipient plan’s qualified status. This […]