As you make decisions about Sally and Norm, such as whether they should contribute to their 401(k) account or pay for their twins’ college education, the game shows how their 401(k) balances change. The game also throws in some twists, such as an unexpected illness, in an attempt to replicate real life.

The game plays a little slow but is entertaining enough to recommend. Take a few minutes during this Memorial Day weekend to see how you do. We played this game over lunch today at my office, and were very surprised that only one person was able to answer every question correctly. (hat tip to BenefitsLink.com)

[tags]Pension Protection Act, ppa, Boston College, Center for Retirement Research, Get Rich Slow, fun, online game, ERISA[/tags]

[tags]Pension Protection Act, ppa, Trucker Huss, Barbara Pletcher, ERISA[/tags]

Today, the Treasury and the Internal Revenue Service released Notice 2008-41, authorizing the creation of a support group dedicated to helping companies avoid imposition of penalties from the inadvertent violation of Internal Revenue Code Section 409A. Dubbed 409AA, it guides companies and their advisors through a 12-step program designed to uncover areas of potential trouble. The Notice also specifies that commitments to participate must be received in writing in the year prior to commencement of the program, that shortening the number of steps is absolutely prohibited and that changes to the program will require participants to start 5 years later than originally scheduled.

Here are the 12 – steps:

1.     I will never get into conversations as to whether it is 409A or 409-Cap-A.

2.     I will never pronounce Dan Hogan’s name in a Colonel Klink voice.

3.     I will not respond to transition relief with, “Oh no! Not again!”

4.     I will not engage in debates whether nonqualified needs a hyphen.

5.     I will not correct the use of “hardship”, even though I know it means “occurrence due to an unforeseeable emergency”.

6.     I will not care whether leap year impacts the 6 month or 12 month rules.

7.     I will not print out all the Notices, proposed regs, and final regs just to see the look on a client’s face when they hear the sound of the stack hitting the table.

8.     I will avoid conversations asking how the underpayment penalty is really calculated.

9.     I will respond to every question with “What does the plan document say?” and ignore the eye rolling.

10.     I will preface every response with “I don’t give legal advice, but…”.

11.     I will not demand additional transition relief must push the compliance date out 5 years (maybe).

12.     I will not ask my employer whether our company plans are 409A-compliant.

[tags]Pension Protection Act, PPA, April Fool’s Day, Kevin Segal, MullinTBG, humor, ERISA[/tags]

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]