ML BeneBits

EXAMINING A RANGE OF EMPLOYEE BENEFITS
AND EXECUTIVE COMPENSATION ISSUES
The SECURE 2.0 Act of 2022 (SECURE 2.0) made a number of changes in law intended to simplify the administration of retirement plans, including through the expansion of the Internal Revenue Service (IRS) Employee Plans Compliance Resolution System (EPCRS), which is currently set forth in Revenue Procedure 2021-30. EPCRS furthers the goal of ensuring that tax-qualified retirement plans operate in compliance with the Internal Revenue Code of 1986, as amended (the Code), by providing a mechanism for sponsors and administrators of those plans to correct certain documentary and operational errors that may arise in plan administration.
The SECURE Act 2.0 makes changes to the US employer retirement plan system with respect to both single employer plans and to “applicable collectively bargained plans.” Applicable collectively bargained plans are defined in the statute as plans maintained pursuant to one or more collective bargaining agreements between employee representatives and one or more employers, i.e., multiemployer plans.