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Robert Richter

By Robert Richter | 12/29/2023
Call it the not so Solo 401(k). We’ve received questions from some American Retirement Association (ARA) members regarding the impact of the long-term part-time employee rules (LTPTE rules) on Solo 401(k) plans. Many sponsors of Solo 401(k) plans were given advice, and established plans with the... READ MORE
By Robert Richter | 10/5/2023
Many (if not most) defined contribution plan documents provide that the plan administrator may use forfeitures to reduce contributions, pay plan expenses, or allocate to participants as additional benefits.  In fact, the Treasury Department and IRS recently suggested that plans be drafted this way... READ MORE
By Robert Richter | 6/27/2023
We are all painfully aware of the complexity of the tax and labor laws we work with. It is, therefore, no surprise that Congress makes drafting mistakes when amending these laws—particularly with voluminous and technical laws, such as the SECURE 2.0 Act of 2022. Unfortunately, once enacted, many... READ MORE
By Robert Richter | 9/10/2022
The IRS in Notice 2022-33 extended the deadline for employers to adopt plan amendments for the SECURE Act as well as the required minimum distribution (RMD) provisions of the CARES Act.[1] We’ve heard that many providers are moving forward with amendments for these provisions despite the extension... READ MORE
By Robert Richter | 9/22/2021
Editor’s Note: The House Ways and Means Committee recently approved funding provisions for the Build Back Better Act of 2021, including   several retirement plan provisions (starting on page 665, and summarized here.)   That part of the bill is aimed at limiting the ability of high-income... READ MORE
By Robert Richter | 9/22/2021
Editor’s Note: The House Ways and Means Committee recently approved funding provisions for the Build Back Better Act of 2021, including   several retirement plan provisions (starting on page 665, and summarized here.)   That part of the bill is aimed at limiting the ability of high-income... READ MORE
By Robert Richter | 9/21/2021
Editor’s Note: The House Ways and Means Committee recently approved funding provisions for the Build Back Better Act of 2021, including several retirement plan provisions (starting on page 665, and summarized here.)   That part of the bill is aimed at limiting the ability of high-income... READ MORE
By Robert Richter | 9/2/2020
The laws are changing constantly—and plan documents have to be updated to keep up. Here’s how you can help your plan sponsor clients avoid trouble.  For IRS pre-approved plans (prototype and volume submitter plans), this means restating documents based on cycles set up by the IRS. But if you miss... READ MORE
By Robert Richter | 4/20/2020
What could getting to the chocolate center of a hard candy have to do with an expanded loan repayment period? Read on. Some of you (older) readers might remember the Tootsie Roll Pop ad where a scholarly looking owl was asked how many licks it takes to get to the center of a Tootsie Roll Pop. One... READ MORE
By Robert Richter | 4/14/2020
A common question regarding the CARES Act distribution, loan and required minimum distribution (RMD) waiver provisions[i] is whether these provisions are optional or mandatory. In most cases, they are optional – but in the retirement world there are very few questions where a short answer will... READ MORE
By Robert Richter | 4/9/2020
A common question regarding the CARES Act distribution, loan and required minimum distribution (RMD) waiver provisions[i] is whether these provisions are optional or mandatory. In most cases, they are optional—but in the retirement world there are very few questions where a short answer will... READ MORE
By Robert Richter | 4/7/2020
A common question regarding the CARES Act distribution, loan and required minimum distribution (RMD) waiver provisions[i] is whether these provisions are optional or mandatory. In most cases, they are optional—but in the retirement world there are very few questions where a short answer will... READ MORE
By Robert Richter | 3/30/2020
In the wake of the Coronavirus outbreak, one of the countless issues facing plan sponsors and practitioners alike is determining a participant’s employment status, more specifically whether there has been a severance of employment.  This determination must be made in order to apply a wide variety... READ MORE
By Robert Richter | 7/3/2019
The Treasury and IRS have proposed regulations designed to encourage adoption of multiple employer plans (MEPs)  – though they’re not final yet. Specifically, the proposed regulations would provide an exception to the “one bad apple” rule for certain MEPs. A MEP is a plan adopted by two or more... READ MORE

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