From:                                         BCG Pension Risk Consultants <>

Sent:                                           Monday, August 27, 2018 2:19 PM

To:                                               Terry McCauley

Subject:                                     The Pension Insider July 2016 - Volume 65, Edition 1



The Pension Insider


The Pension Insider is a monthly newsletter developed for individuals who work in the pension arena. The Pension Insider was created to share ideas, success stories, coming events and industry specific articles.



July, 2016 - Volume 65, Edition 1



IRS Requesting DB Lump-Sum Payment Window Information 

 DB plan sponsors requesting a determination letter should identify whether the plan has risk transfer language.
By Rebecca Moore Editor | Plan Sponsor | July 14, 2016

The Internal Revenue Service (IRS) has said applicants requesting determination letters for their defined benefit (DB) plans should identify whether the plan has lump-sum risk transfer language in either the cover letter to their application or an attachment.

For plans that do, they must also identify the appropriate plan section and whether the plan satisfies one of the conditions in Notice 2015-49. In Notice 2015-49, the IRS announced its intent “to amend the required minimum distribution regulations under § 401(a)(9) of the Internal Revenue Code to address the use of lump-sum payments to replace annuity payments being paid by a qualified defined benefit pension plan.” Effective July 9, 2015, DB plan sponsors may no longer offer a lump-sum window to participants who have begun receiving installments.

On its website, the IRS says if the plan sponsor advises that the plan has risk transfer language and satisfies one of the four conditions in Notice 2015-49, the agency will review the plan document to verify that it satisfies the qualification requirements of the Code. The plan’s determination letter will contain a favorable caveat providing reliance on the risk transfer language. Click Here for full article 

Additional links: IRS Announces Halt to Certain Lump-Sum Offerings  | Notice 2015-49 | New Process for Defined Benefit D-Letter Applications


Parting Thoughts 

 JUST OUT OF REISH | Published in June 2016

 Key advice for plan sponsors
By PLANSPONSOR staff| *Fred Reisch | June 2016

This is my last column for PLANSPONSOR magazine. I’ve written these monthly columns for more than a decade; however, at some point, all things come to an end. With the heavy burdens of my legal practice, and particularly with the increase in client needs because of the Department of Labor (DOL)’s fiduciary regulation and exemptions, now is the time. 
In closing, I want to leave you with some parting thoughts:

  • Most plan sponsors want to do the right thing and, in fact, are making good faith efforts to provide quality investments and services to their participants. But, for the system to work, it takes more than that.
  • Many plan sponsors pay too much attention to plan features and nowhere near enough to plan results. Appealing investments and attractive websites are good to have, but are far less important than operating a plan that results in adequate retirement benefits. Somehow, the cart has been placed before the horse. Where else in the business world is so much emphasis placed on being attractive and so little on the bottom line? Click Here for full article

*Fred Reish is a partner in Drinker Biddle & Reath LLP’s employee benefits and executive compensation practice group and chair of the financial services ERISA team.

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ANNUITY RATES Standard Pension Closeout/Terminal Funding Case Rates:

(No lump sums, no disability or unusual provisions)

Immediates - 2.08%

Deferreds - 2.48%

50/50 Split of Immediates and Deferreds - 2.28%



BCG Pension Risk Consultants

We specialize in settling pension liabilities for terminating and ongoing pension plans.

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