Top 10 401k Audit Problems

February 4, 2014

When the Internal Revenue Service (IRS) launched a series of “LESE [Learn, Educate, Self-correct and Enforce] examinations” last year, one of its intentions was to discover trends in compliance failure among qualified retirement plans.

Here are the most frequently cited compliance errors.  By avoiding these mistakes, compliance experts say sponsors can go a long way toward navigating—or avoiding—IRS audits.  Full article over at Plan Sponsor.

1. Failing to amend plan design to comply with current law in a timely fashion

2. Failing to procure adequate fidelity bonding

3. Not following plan terms for loan and distribution processing. 

4. Neglecting to allocate contributions and forfeitures in keeping with the plan terms.

5. Failure to properly run nondiscrimination tests.

6. Failure to deposit elective deferrals into the trust in a timely manner.

7. Using an incorrect definition of compensation per the plan terms

8. Failing to monitor plan contributions to ensure they do not exceed dollar limits or the deductible limit for employers.

9. Distributions of excess deferrals are incomplete, not timely or improperly calculated.

10. Not filing the final Form 5500. 

Pro Tip:  The IRS chose plans with invalid business codes on their 5500’s – if you can’t get your own business code right, what are the chances you are running your 401(k) plan properly!

@tomob


Fidelity sued by employees over 401k plan AGAIN

January 16, 2014

Reported over on the FRA PlanTools blog Fidelity is being sued by their own employees again.

The plaintiffs here generally allege that the fiduciaries to the Fidelity in-house plan violated ERISA sections 404 and 406 because Fidelity failed to rebate back the revenue sharing it collected from the all Fidelity mutual fund lineup in the plan beyond what would have been reasonable and permitted.

The plaintiffs claim the plan should have negotiated a direct recordkeeping arrangement with Fidelty, like other large plans do. They claim that all the way back to 2007, a reasonable per head fee would have been $20-$27. Instead, they claim that Fidelity was collecting approximately $335 per head through the revenue sharing from the plan.”

This is the problem with bundling – even in the new era of full fee disclosure.  It is still way too hard to separate the cost of administration from the cost of investment management.  I can only hope that this continues to force the issue of full, clear and explicit fee disclosure for 401(k) service providers.

@tomob


401k Plan Sponsor Focus

December 18, 2013

401k Plan Sponsor Focus

Good research from Putnam describing the necessary shift in focus from individual fund investment returns to overall plan performance as measured by retirement readiness.


Top 5 Things Plan Sponsors Should Do in 2014

December 18, 2013

Good article from Plan Sponsor on how to keep your retirement plan on track to make sure employees have enough $$ to retire.


401k Balances and Contributions Going Up

December 18, 2013

In this story from HR Executive we can see that 401(k) balances are going up.  Contributing factors include increased contributions by both participants and employers and market returns.  Hopefully this trend continues.


Grilled and Smoked Turkey #thanksgiving

November 21, 2013

Because it’s Thanksgiving!

Last year we had family in for Thanksgiving so we had to cook dinner. Throwing caution to the wind, I decided to try not one, b2 Turkeysut two new (to me) methods of cooking the turkeys. (This is a somewhat risky strategy because as you know the turkey is the linchpin of Thankgiving dinner – so I was more than a little nervous.

I grilled one bird on the Weber, and smoked the other on the Traeger.

Drumroll please . . . They came out great. We ate right on time – 4:00 PM and both birds were very well cooked. The smoked turkey on the Traeger took about 5.5 hours. The turkey on the Weber only took 2.75 hours.

I cooked both to an internal temperature (instant read thermometer) of 170 degrees and then took them off. Preparation was simple. Two 15 lb fresh organic turkeys (from the local food co-op) brought to room temperature and then dressed with a simple rub of olive oil, salt, pepper and finely chopped fresh sage, rosemary and thyme. I chopped up some apples, drenched them in the rub and put them in the cavities – just for flavor. (No stuffing.)

For cooking, I ran the Traeger on high for about 45 minutes and then turned it down to medium for about the next 4 hours. I then ran it on high for about 30 minutes to get up to 170 degrees. No turning, no basting, etc. On the Weber, I just followed their instructions from the website. Turkey in the middle with drip pan underneath. About 75 coals in two piles (on either side of the turkey) then add 8 briquettes per side per hour. That was it.

I was pretty surprised that they came out as well as they did – and will definitely do it again. They tasted great and there was no messy turkey pan to clean!

TO’B


Obama 2012 And The Future Of Media Buying

June 20, 2013

2012-01-26_1327587338This is an awfully long article to slog through, but it was from the NYT Magazine, so I guess the long form is understandable.

The callout on the article “The Obama Campaign’s Digital Masterminds Cash In” is mostly true to form – focusing on the people and personalities involved – but somewhere around page 5 (can’t believe I got that far) it grabbed my interest.

Behavioral TV Ad Buying; It’s Time to Ditch Demographics

The Obama campaign used social data to guide their media buying.  They had a list of 15 MM persuadable voters (culled from FB and other sources) and a plan to focus on putting messages in front of those 15 MM people at the lowest possible cost.

They did not do this with demographics.  They did it with behavioral data.  They crossed the “persuadable voter list” with actual viewing data sourced from set-top box data provider Rentrak who had lots and lots of individual level viewing data.  (For instance, Rentrak had 100,000 people in its Denver sample, some 20,000 of whom were on the Obama list; Nielsen had a total of 600 people in Denver.)

They crossed these two data sources using a third-party to “anonymize” the data, avoiding privacy concerns.  The output guided them to buying micro-targeted ads – think “Judge Joe Brown” in the middle of the afternoon instead of the evening news.  The Obama campaign ran twice as many cable ads on more that twice as many channels as the Romney campaign did.  Over 566k ads on more than 100 cable channels.

Remember the key driver for this optimization – observed behavior – not demographics.  They identified 15 MM persuadable voters (mostly via Facebook) and then figured out exactly which TV shows those people watched.

Implications for marketers are obvious.  The technology is available for behavioral segmentation (persuadable voters) and targeting (what shows they actually watch) right now.  All marketers will be doing this within 10 years, but who will do it now to drive competitive advantage?

@tomob


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