Susan Mangiero over at Pension Risk Matters has posted a letter a pretty good letter to Pension Santa. Susan’s focus is fiduciary matters and risk, so her letter focuses on these topics.
I second Susan’s letter, and add this item to my letter to Pension Santa:
- knowledge of, and the requisite guidance to create, any amendments required to be signed by December 31, 2008, well before that date. In a perfect world, no later than July 1st is a good date to know what must be created and signed by December 31st so plan sponsors will receive all plan document updates in one package instead of the slow trickle throughout the year which we have seen since the IRS released Rev. Proc. 2005-66;
- Model Notices from the IRS and Dept. of Labor containing sufficient language to send to plan sponsors unaltered so that it is easy to avoid the $1,000/day fine proposed by the Dept. of Labor, published as the Proposed Regulation on Civil Penalties Under ERISA section 502(c)(4) (hat tip to BenefitsLink.com);
[tags]Pension Protection Act, ppa, DOL, civil penalties, 502(c)(4), Susan Mangiero, ERISA[/tags]
