A Roundup of Recent DOL and IRS Retirement Plan Guidance


By Ian Berger, JD
IRA Analyst

There’s been a flurry of recent government regulation of company retirement plans. Here’s a quick summary:

Electronic Disclosure of Retirement Plan Documents

On May 27, 2020, the Department of Labor published a final regulation making it easier for employers to issue retirement plan notices to participants electronically. Notices can be posted on a website or mobile app or delivered via email. Employees who prefer hard copies can opt out of electronic delivery and receive paper disclosures instead. The DOL rule applies only to retirement plan notices required under ERISA (e.g., summary plan descriptions). It does not apply to notices required by the Internal Revenue Service or employer health plan communications.

Employers are not required to use the new regulation. They may instead rely on an existing DOL rule allowing electronic disclosure in limited situations. Or, they can furnish paper documents by hand-delivery or by regular mail. The new rule is effective July 27, 2020.


Q: I am 71 years old as of March 2020. Does the SECURE Act permit me to open a new spousal IRA account this year?


Q: For COVID "special" Aug 31 rollovers, am I allowed to return my 401(k) required minimum distribution (RMD) to my IRA?


Q: If someone took two IRA distributions earlier in 2020 that were considered RMDs, and now wishes to repay the cumulative amount back into the same IRA, are there any rules about the number of rollover deposits they can make in order to do so? Must it be done in 1 transaction, or 2, or could it be spread out across even more?


Q: Once the RMD’s for 2020 were suspended, I withdrew what would have been my RMD from my traditional IRA and deposited it in my Roth IRA. Can I now withdraw that amount from my Roth and repay it to my traditional IRA?


Q: Am I allowed to convert my inherited traditional IRA to a Roth IRA?


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