With the passage of a massive $1.9 trillion Covid-19 stimulus bill, comes much-needed pension funding relief for single-employer pension plan sponsors, along with significant aid to multiemployer pension plan sponsors. As prior relief provisions began to wear away this year, plan sponsors were looking at higher, and in some cases unsustainable, contribution payments over the coming years.
The American Rescue Plan Act of 2021 (ARPA) contains two key provisions that together will result in significant reductions in future contribution requirement for single-employer pension plans:
On Friday, May 15th, the US House of Representatives passed the Health and Economic Recovery Omnibus Emergency Solutions Act, appropriately donned the HEROES Act. This $3 trillion bill reaches just about every corner of the country – and the economy – impacted by the Coronavirus. Perhaps the most interesting provision for those of you reading this update will be the much-anticipated and needed pension relief for defined benefit plan sponsors.
The Window Opens for Retiree Cashouts
In the past, the IRS has implicitly prohibited the offer of a lump sum payment in lieu of a monthly annuity – except in the case of a plan termination – to retirees already in pay status. For plan sponsors seeking to remove risk and lower PBGC premiums, this constrained the population eligible for a lump sum window to terminated vested participants. However, the IRS never formalized its position on this, leaving plan sponsors to wonder what options they had.
The IRS has finally issued a statement that a new mortality table will be required for plan years beginning in 2018. While most plan sponsors have implemented RP-2014 for accounting purposes, the updated mortality table (first released in 2014) had not been adopted by the IRS for funding purposes (minimum required contribution and lump sum calculations). The proposed table will mirror that used for accounting purposes and is expected to increase liabilities and lump sums by approximately 5%. This makes 2017 the last year to implement a lump sum window before the mortality improvements increase the cost. A window typically takes three to four months to accomplish, so don’t wait. Contact us now for a complimentary analysis of the financial savings that can be realized through this and other derisking strategies.
Over the past several years, many plan sponsors have implemented a “de-risking” strategy that allowed them to offer lump sums, equal to the value of future annuity payments, during a temporary “window” period to former employees, including retirees in pay status. While this strategy was particularly popular with the terminated vested population who had not yet begun their annuity payments, it was also permissible to offer it to retirees who were currently receiving an annuity. The advantages of such a window included lowering PBGC premiums and shrinking plan liability, thereby reducing future risk and volatility.
On Friday, August 8, 2014, President Obama signed into law the Highway and Transportation Funding Act of 2014, which will come to be known to pension plan sponsors as HATFA. HATFA modifies the 2012 pension funding relief, known as MAP-21, by providing an extended reprieve from low interest rates, which for plan sponsors translates to a higher funded status and lower required contributions through 2020. Much like MAP-21, the pension provisions are being used to partially fund highway and transportation improvements by reducing tax-deductible contributions required to be made to pension plans. The law does not decrease the ultimate cost of a plan but merely defers contributions to future plan years.
Everyone has their own perspective on government’s role in our daily lives. Is it there to provide aid and assistance or is meant to merely provide the framework for us to govern ourselves? In the context of the US pension plan system, what started out as a framework for the provision and funding of retirement benefits, has evolved most recently into a pattern of government assistance – but to what end? Is it intended to benefit the employees, the plan sponsors or the government itself?
In the summer issue of Confero Magazine, Erica Harper writes about the 2012 phenomenon experienced by many pension plan sponsors who watched their funded status decrease in a year with big gains in the stock market. This article explains what happened and how a liability-driven investing (LDI) approach can address this dilemma. Check out her article, “With Markets Going Up, Why Does My Funded Status Keep Going Down?” If you’d like to learn more about an LDI approach for your pension plan, please contact us at info@harperdanesh.com or call us at 585-319-4218.
As part of a recently-enacted law known as MAP-21 (“Moving Ahead for Progress in the 21st Century”), defined benefit plan sponsors were promised significantly lower contribution requirements through the “stabilization” of the interest rates used for pension funding purposes. With each month bringing historic interest rate lows, this was welcome relief for most plan sponsors.
Plan Sponsor’s Prayers Answered – Pension Funding Legislation Brings Immediate Relief
Much-anticipated and needed pension funding relief is expected to be approved by the House and Senate this week. As part of a transportation bill, the legislation intends to increase tax revenue by significantly reducing the tax-deductible contributions required to be made to pension plans – a welcome reprieve for plan sponsors who are finding their 2012 contribution requirements at the highest levels ever.
As defined benefit sponsors are all too aware, interest rates continue to drop, causing pension liabilities and contributions to reach all-time highs in 2012. In response to this, a bipartisan bill was introduced and approved by the Senate on Wednesday, allowing pension plans to base their liabilities on interest rates averaged over 25 years, instead of the current two-year averaging. The next step is for the House to approve a similar measure.
Harper Danesh LLC, a full-service actuarial consulting and retirement planning services firm, is excited to announce its first anniversary, as well as its recent purchase of the historical converted carriage house where their office has been located in downtown Rochester’s East End District.
Less than a year ago, Erica Harper and Rob Danesh enjoyed well-established, successful careers at one of the largest employee benefits consulting firms in the world. Despite their promising futures, last Fall, the two Rochester-natives made the bold decision to leave a world of job stability behind and start their own actuarial consulting and retirement planning services firm.
Harper Danesh LLC, an actuarial consulting and retirement planning services firm, is excited to announce the grand opening of its offices in Rochester, NY. Partners Erica Harper and Robert Danesh are native to upstate New York and are pleased to bring their services to the local and national business community.
