In the Blogosphere. . .

Someone is compiling articles and links related to the stock option backdating saga here. (It certainly would take a separate blog to keep up with all of them.) RothCPA.com talks about changes in the law regarding COLI insurance and charitable…

Someone is compiling articles and links related to the stock option backdating saga here. (It certainly would take a separate blog to keep up with all of them.)

RothCPA.com talks about changes in the law regarding COLI insurance and charitable deductions under the Pension Protection Act here.

Professor Paul Secunda points out a new article by Professor John H. Langbein in a post at the Workplace Prof Blog: Langbein on Judicial Review of Benefit Denials under ERISA. (Professor Langbein has been mentioned in previous posts which you can access here.)

Some Recommended Reading in the Blogosphere. . .

Someone is compiling articles and links on stock option backdating here. RothCPA.com talks about changes in the law regarding COLI insurance and charitable deductions under the Pension Protection Act here. Professor Paul Secunda points out a new article by Professor…

Someone is compiling articles and links on stock option backdating here.

RothCPA.com talks about changes in the law regarding COLI insurance and charitable deductions under the Pension Protection Act here.

Professor Paul Secunda points out a new article by Professor John H. Langbein in a post at the Workplace Prof Blog: Langbein on Judicial Review of Benefit Denials under ERISA. (Professor Langbein has been mentioned in previous posts which you can access here.)

Seventh Circuit Opines: IBM’s Cash Balance Plan Not Age Discriminatory Under ERISA

A victory for IBM and cash balance plans in general: "Kathi Cooper v. IBM Personal Pension Plan and IBM Corporation." Some readers may enjoy the more casual tone of this opinion written by Circuit Judge Frank Easterbrook. (Read more about…

A victory for IBM and cash balance plans in general: “Kathi Cooper v. IBM Personal Pension Plan and IBM Corporation.”

Some readers may enjoy the more casual tone of this opinion written by Circuit Judge Frank Easterbrook. (Read more about Judge Easterbrook here from How Appealing.) Here are some notable quotes from the opinion:

(1) “. . . [The district court’s] approach treats the time value of money as age discrimination. Yet the statute does not require that equation. Interest is not treated as age discrimination for a defined-contribution plan, and the fact that these subsections are so close in both function and expression implies that it should not be treated as discriminatory for a defined benefit plan either. The phrase “benefit accrual” reads most naturally as a reference to what the employer puts in (either in absolute terms or as a rate of change), while the defined phrase “accrued benefit” refers to outputs after compounding. That’s where this litigation went off the rails: a phrase dealing with inputs was misunderstood to refer to outputs.

(2) “Nothing in the language or background of §204(b)(1)(H)(i) suggests that Congress set out to legislate against the fact that younger workers have (statistically) more time left before retirement, and thus a greater opportunity to earn interest on each year’s retirement savings. Treating the time value of money as a form of discrimination is not sensible.”

(3) “Our conclusion that “benefit accrual” (for defined-benefit plans) and “allocation” (for defined-contribution plans) both refer to the employer’s contribution rather than the time value of money between contribution and retirement has the support of regulations that the Treasury Department proposed. (Appropriations riders have prevented the Treasury from taking final action on the draft regulations, but they still help to inform our understanding of the statute.)”

(4) “As far as we can see, ours is the first appellate decision to address the status of cash-balance plans under §204(b)(1)(H)(i). The class directs our attention to two decisions from other circuits that it says supply helpful analysis. Miller v. Xerox Corp. Retirement Income Guarantee Plan, 447 F.3d 728 (9th Cir. 2006); Esden v. Bank of Boston, 229 F.3d 154 (2d Cir. 2000). As the class reads them, these opinions stand for two important propositions. First, that an “accrued benefit” in a cash-balance plan is an annuity at normal retirement age. Second, that there is a “fundamental” distinction between defined-contribution and defined-benefit plans. Both of these propositions are correct, and both of them are irrelevant.”

(5) “. . . [A] plaintiff alleging age discrimination must demonstrate that the complained-of effect is actually on account of age. One need only look at IBM’s formula to rule out a violation. It is age-neutral.”

(6) “An employer is free to move from one legal plan to another legal plan, provided that it does not diminish vested interests—and this transition did not.”

(7) “Litigation cannot compel an employer to make plans more attractive (employers can achieve equality more cheaply by reducing the highest benefits than by increasing the lower ones). It is possible, though, for litigation about pension plans to make everyone worse off. After the district court’s decision IBM eliminated the cash-balance option for new workers and confined them to pure defined-contribution plans. . . Whether that is good or bad (for employees or society as a whole) is not for us to say. What we can and do conclude, however, is that the decision may again be made freely, governed by private choice rather than legal constraint.”

While the Pension Protection Act of 2006 passed by Congress last week (discussed here) contains some relief for cash balance plans, the relief is only prospective. Thus, this decision handed down by the Seventh Circuit is highly significant.

(Hat Tip: Benefitslink.com)

Seventh Circuit Opines: IBM’s Cash Balance Plan Not Age Discriminatory Under ERISA

A victory for IBM and cash balance plans in general: "Kathi Cooper v. IBM Personal Pension Plan and IBM Corporation." Some readers may enjoy the more casual tone of this opinion written by Circuit Judge Frank Easterbrook. (Read more about…

A victory for IBM and cash balance plans in general: “Kathi Cooper v. IBM Personal Pension Plan and IBM Corporation.”

Some readers may enjoy the more casual tone of this opinion written by Circuit Judge Frank Easterbrook. (Read more about Judge Easterbrook here from How Appealing.) Here are some notable quotes from the opinion:

(1) “. . . [The district court’s] approach treats the time value of money as age discrimination. Yet the statute does not require that equation. Interest is not treated as age discrimination for a defined-contribution plan, and the fact that these subsections are so close in both function and expression implies that it should not be treated as discriminatory for a defined benefit plan either. The phrase “benefit accrual” reads most naturally as a reference to what the employer puts in (either in absolute terms or as a rate of change), while the defined phrase “accrued benefit” refers to outputs after compounding. That’s where this litigation went off the rails: a phrase dealing with inputs was misunderstood to refer to outputs.

(2) “Nothing in the language or background of §204(b)(1)(H)(i) suggests that Congress set out to legislate against the fact that younger workers have (statistically) more time left before retirement, and thus a greater opportunity to earn interest on each year’s retirement savings. Treating the time value of money as a form of discrimination is not sensible.”

(3) “Our conclusion that “benefit accrual” (for defined-benefit plans) and “allocation” (for defined-contribution plans) both refer to the employer’s contribution rather than the time value of money between contribution and retirement has the support of regulations that the Treasury Department proposed. (Appropriations riders have prevented the Treasury from taking final action on the draft regulations, but they still help to inform our understanding of the statute.)”

(4) “As far as we can see, ours is the first appellate decision to address the status of cash-balance plans under §204(b)(1)(H)(i). The class directs our attention to two decisions from other circuits that it says supply helpful analysis. Miller v. Xerox Corp. Retirement Income Guarantee Plan, 447 F.3d 728 (9th Cir. 2006); Esden v. Bank of Boston, 229 F.3d 154 (2d Cir. 2000). As the class reads them, these opinions stand for two important propositions. First, that an “accrued benefit” in a cash-balance plan is an annuity at normal retirement age. Second, that there is a “fundamental” distinction between defined-contribution and defined-benefit plans. Both of these propositions are correct, and both of them are irrelevant.”

(5) “. . . [A] plaintiff alleging age discrimination must demonstrate that the complained-of effect is actually on account of age. One need only look at IBM’s formula to rule out a violation. It is age-neutral.”

(6) “An employer is free to move from one legal plan to another legal plan, provided that it does not diminish vested interests—and this transition did not.”

(7) “Litigation cannot compel an employer to make plans more attractive (employers can achieve equality more cheaply by reducing the highest benefits than by increasing the lower ones). It is possible, though, for litigation about pension plans to make everyone worse off. After the district court’s decision IBM eliminated the cash-balance option for new workers and confined them to pure defined-contribution plans. . . Whether that is good or bad (for employees or society as a whole) is not for us to say. What we can and do conclude, however, is that the decision may again be made freely, governed by private choice rather than legal constraint.”

While the Pension Protection Act of 2006 passed by Congress last week (discussed here) contains some relief for cash balance plans, the relief is only prospective. Thus, this decision handed down by the Seventh Circuit is highly significant.

(Hat Tip: Benefitslink.com)

Compilation of Links Pertaining to the Pension Protection Act of 2006

The 907-page Pension Protection Act of 2006 passed last week by Congress is sure to keep benefits lawyers busy for years to come. I have compiled a collection of links pertaining to the Act, some of which I am hoping…

The 907-page Pension Protection Act of 2006 passed last week by Congress is sure to keep benefits lawyers busy for years to come. I have compiled a collection of links pertaining to the Act, some of which I am hoping to house permanently over in a sidebar section on the right:

See also the following articles from the Wall Street Journal:

Compilation of Links Pertaining to the Pension Protection Act of 2006

The 907-page Pension Protection Act of 2006 passed last week by Congress is sure to keep benefits lawyers busy for years to come. I have compiled a collection of links pertaining to the Act, some of which I am hoping…

The 907-page Pension Protection Act of 2006 passed last week by Congress is sure to keep benefits lawyers busy for years to come. I have compiled a collection of links pertaining to the Act, some of which I am hoping to house permanently over in a sidebar section on the right:

See also the following articles from the Wall Street Journal:

More on the Pension Protection Act of 2006 . . .

From the Wall Street Journal: Bill to Aid 401(k) Investors Raises Bias ConcernThe Big Pension Bill: Is That All There Is? Also, from Reuters: US senators expect to solve airline pension dispute Finally, many thanks to the Pension & Benefits…

From the Wall Street Journal:

Also, from Reuters:

Finally, many thanks to the Pension & Benefits Weblogger for staying up most of the night to create this great effective date outline here (completed at 3:48 in the morning!) of the 907-page bill. See also this helpful commentary here on how the PPA will affect lump sum distributions. Excerpt:

Various provisions under the Pension Protection Act of 2006 (H.R. 4) affect the valuation and distribution of lump sum distribution of the value of a participant’s accrued benefits under a defined benefit pension plan. . .

. . . For a pension plan other than a hybrid pension plan, the amount of a lump sum distribution will be valued using the 3-segment yield curve introduced by PPA for pension funding. [PPA §302] For the lump sum valuation, the yield curve is based on the rates for the month before the distribution, rather than on the 24-month average used for the plan’s funding. Lump sum amounts should generally be lower under the new rates than under the pre-PPA determination, which is based on 30-year Treasury bond rates, with the largest cuts going to youngest employees. The new rates take effect during a 5-year transition period beginning in 2008.

Frist Comments on Pension Legislation

Thanks to the TaxProf Blog for this link to Senator Frist's recent comments on the proposed pension legislation (discussed in this previous post here). More on the ongoing battle over the legislation here….

Thanks to the TaxProf Blog for this link to Senator Frist’s recent comments on the proposed pension legislation (discussed in this previous post here). More on the ongoing battle over the legislation here.

Final Regulations: Comparability Requirements for Employer Contributions to Health Savings Accounts

In August of 2005, proposed regulations (REG-138647-04) pertaining to HSA comparability requirements were issued. The proposed regulations clarified and expanded upon the guidance regarding the comparability rules for HSAs published in IRS Notice 2004-2 and in Notice 2004-50 (2004-33 IRB…

In August of 2005, proposed regulations (REG-138647-04) pertaining to HSA comparability requirements were issued. The proposed regulations clarified and expanded upon the guidance regarding the comparability rules for HSAs published in IRS Notice 2004-2 and in Notice 2004-50 (2004-33 IRB 196), Q & A-46 through Q & A-54. Today, the IRS has issued final regulations (which you can access here) adopting the provisions of the proposed regulations with certain modifications.

One of the modifications is that the final regulations provide additional guidance on how employer HSA contributions are made through a cafeteria plan:

Specifically, the final regulations provide that employer contributions to employees’ HSAs are made through the cafeteria plan if under the written cafeteria plan, the employees have the right to elect to receive cash or other taxable benefits in lieu of all or a portion of an HSA contribution (i.e., all or a portion of the HSA contributions are available as pre-tax salary reduction amounts), regardless of whether an employee actually elects to contribute any amount to the HSA by salary reduction. The final regulations also provide several examples that illustrate the application of the cafeteria plan exception to the comparability rules.