Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back once again with Kristin Ryan, an Audit Senior Manager and one of the faces of the PKF Texas Employee Benefit Plan team. Kristen, welcome back to the Playbook.
Kristin: Thanks for having me.
Jen: So, we’ve had a webinar on it, you’ve done some Entrepreneur’s Playbooks on it, but there’s so much to cover between the SECURE Act and the CARES Act. What else do our folks need to know?
Kristin: Yeah, absolutely. A lot has happened this year since we spoke last, as everyone’s aware, so we’ve learned a lot in that time period, and there’s been IRS notices that have come out as well to help try to provide some guidance to everyone. A lot of plans have made changes, so a lot of people viewing are probably familiar with coronavirus-related distributions and loans, so we’re helping clients with implementation on that, with amendments they need to make to the plan, pitfalls that they may see. And then one thing to be looking out for is SECURE 2.0, so that’s going to be coming to us sometime— expected to be passed sometime in 2021.
Jen: Have the changes in people’s working environment changed how people handle their employee benefit plans?
Kristin: Yeah, absolutely. So, that’s something, as auditors, we have to be very aware of and our plan sponsors, as well, and administration. A lot of the challenges are around remote working. Committees haven’t been meeting regularly like they were in the past, so best practice is to meet at least quarterly; that hasn’t necessarily been happening. So, with all these regulation changes, there’s time sensitive things that need to be addressed, and committees are not meeting, so they’re not having these crucial discussions. And then just back to kind of the remote working, processes have changed, so controls have changed, things like that. We have to be aware of how things have changed and things may have fallen through the cracks with people still working from home or just dealing with personal challenges at home.
Jen: Now, I understand that there’s been some relief for plan sponsors in terms of layoffs, furloughs, that type of thing. What else can you share about that?
Kristin: Yeah, so the relief is around late remittances. So, the DOL has very strict guidelines on remittances and the timing from when you take employee funds out of payroll and when you remit to the plan, but they’ve said if it’s a coronavirus-related time frame or delay that they’re not going to penalize plan sponsors for that. So, it’s a very grey area.
We’re suggesting a lot of documentation so that if, at some point, IRS or DOL comes after our clients, they’ve got that documentation as to why they did not remit on time. And then furloughs and layoffs – just want to mention that because there is a lot of grey area around that as well – so our clients need to be seeking oversight council to make sure that they don’t have a personal plan termination, or in cases of like eligibility, the way they operate the plan hasn’t changed based on somebody having to undergo a layoff or furlough. So, those are just things to keep in mind.
Jen: Well, with SECURE Act 2.0 coming, I’m sure we’ll get you back to talk a little bit more once you’ve had a chance that it’s passed and you’ve had a chance to read it. We will get you back here. Sound good?
Kristin: Sounds great.
Jen: Perfect. For more information about this topic, visit www.pkftexas.com/BenefitPlanAudits. This has been another thought leader production brought to you by PKF Texas – The Entrepreneurs’ Playbook. Tune in next week for another chapter.