A checklist for action this year.
A piece of legislation as far ranging as the Pension Protection Act (PPA) demands in-depth ongoing analysis of the enacted provisions and the supporting regulations and notices that the departments of Labor and Treasury will issue in the coming months. However, some of the provisions related to defined contribution (DC) plans are effective as of the first plan year following December 31 of this year; other provisions went into effect on August 17, the date of enactment. Thus, calendar-year DC plan sponsors should evaluate the effect of these provisions on their plans’ operations and be prepared to implement any changes that may be needed before January 1, 2007; in some cases in time for notices that must be issued by December 1, 2006.
In the corresponding chart, items listed in the Things to Consider column identify those PPA provisions that may require DC plan sponsors’ attention sooner rather than later.