Mercer Select US - DB pension sponsors implementing lump sum restrictions need not notify retirees

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DB pension sponsors implementing lump sum restrictions need not notify retirees

Pension plan sponsors implementing PPA’s lump sum restrictions do not need to notify individuals in pay status who no longer can elect a lump sum regardless of the PPA restriction, according to an IRS newsletter. The guidance helps sponsors facing an October deadline under ERISA Section 101(j) to notify participants and beneficiaries of restrictions that took effect on Oct. 1 or the earlier AFTAP certification date. But the newsletter’s scope is narrow, so plan sponsors should review with counsel whether notices must be provided more broadly given their plans’ terms. (Select News, 14 Oct 2009)

Full text of Employee Plan News (IRS, 13 Oct 2009) (PDF)

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