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IRS Releases 2020 Adjusted Qualified Plan Limitations

The Internal Revenue Service released the cost-of-living adjusted qualified retirement plan limitations effective January 1, 2020.  For ease of reference and comparison to prior years, we have placed the adjusted limitations in the table below.  For more information, refer to the Internal Revenue Service’s news release and Notice 2019-59 and to the Social Security Administration’s October 10, 2019, fact sheet.

Qualified Plan Limits

Type of Limitation 2020 2019 2018 2017 2016 Elective Deferrals (401(k), 403(b), 457(b)(2) and 457(c)(1)) $19,500 $19,000 $18,500 $18,000 $18,000 Section 414(v) Catch-Up Deferrals to 401(k), 403(b), 457(b), or SARSEP Plans (457(b)(3) and 402(g) provide separate catch-up rules to be considered as appropriate) $6,500 $6,000 $6,000 $6,000 $6,000 SIMPLE Salary Deferral $13,500 $13,000 $12,500 $12,500 $12,500 SIMPLE 401(k) or regular SIMPLE plans, Catch-Up Deferrals $3,000 $3,000 $3,000 $3,000 $3,000 415 limit for Defined Benefit Plans $230,000 $225,000 $220,000 $215,000

Employer CCPA FAQs #9: May an employer become subject to the CCPA because of a corporate transaction?

As our series of FAQs regarding the California Consumer Privacy Act (“CCPA”) continues we are examining the scope of the law’s jurisdiction.    These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

As a reminder, the CCPA is a new privacy law that applies to data collected about California-based employees.   The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.

For US employers who have not had to comply with the GDPR, the requirements of the CCPA will likely require a new analysis of the treatment of employee-data and implementation of updated or new data policies.  For employers with European operations, one key area of interest is the degree to which the CCPA aligns with the European

Employer CCPA FAQs #8: Does the CCPA apply to non-profit employers?

As our series of FAQs regarding the California Consumer Privacy Act (“CCPA”) continues we are examining the scope of the law’s jurisdiction.    These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

As a reminder, the CCPA is a new privacy law that applies to data collected about California-based employees.   The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.

For US employers who have not had to comply with the GDPR, the requirements of the CCPA will likely require a new analysis of the treatment of employee-data and implementation of updated or new data policies.  For employers with European operations, one key area of interest is the degree to which the CCPA aligns with the European

Deep Dive: DOL Appeals Federal Court’s Association Health Plan Ruling and Issues Interim Guidance

As we predicted in our last Deep Dive, the Department of Labor (DOL) has appealed the District Court for the District of Columbia’s ruling in State of New York, et al. v. United States Department of Labor, et al. which vacated key portions of the DOL’s association health plan regulation (AHP Rule). The DOL filed its Notice of Appeal with the federal district court (D.D.C.) on April 26.

In response to the Court’s ruling (and before filing its appeal) the DOL had published a Q&A-style discussion of the ruling’s impact. After filing its appeal, the DOL published an official statement (DOL Statement) outlining interim guidance for previously-formed AHPs and employers who began participating in an AHP in reliance on the AHP Rule. The DOL Statement clarifies that these employers and AHPs may continue their coverage for

Employer CCPA FAQs #7: If an employer is based in California, will the CCPA requirements apply to all employee data held by the employer?

As our series of FAQs regarding the California Consumer Privacy Act (“CCPA”) continues we are examining the scope of the law’s jurisdiction.    These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

As a reminder, the CCPA is a new privacy law that applies to data collected about California-based employees.   The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.

For US employers who have not had to comply with the GDPR, the requirements of the CCPA will likely require a new analysis of the treatment of employee-data and implementation of updated or new data policies.  For employers with European operations, one key area of interest is the degree to which the CCPA aligns with the European

Employer CCPA FAQs #6: Does an employer need to generate revenue in California in order for CCPA to apply?

As our series of FAQs regarding the California Consumer Privacy Act (“CCPA”) continues we are examining the scope of the law’s jurisdiction.    These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

As a reminder, the CCPA is a new privacy law that applies to data collected about California-based employees.   The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.

For US employers who have not had to comply with the GDPR, the requirements of the CCPA will likely require a new analysis of the treatment of employee-data and implementation of updated or new data policies.  For employers with European operations, one key area of interest is the degree to which the CCPA aligns with the European General Data

Employer CCPA FAQs #5: Does an employer have to be “established” in the United States for U.S. data privacy and security laws, and particularly the CCPA, to apply?

As our series of FAQs regarding the California Consumer Privacy Act (“CCPA”) continues we are examining the scope of the law’s jurisdiction.    These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

As a reminder, the CCPA is a new privacy law that applies to data collected about California-based employees.   The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.

For US employers who have not had to comply with the GDPR, the requirements of the CCPA will likely require a new analysis of the treatment of employee-data and implementation of updated or new data policies.  For employers with European operations, one key area of interest is the degree to which the CCPA aligns with the European General Data

Deep Dive: Association Health Plan Considerations following the Court Order Vacating the DOL’s Final Rule

On March 28, 2019, the Federal District Court for the District of Columbia issued an opinion and order vacating key portions of the Department of Labor’s regulation, published in June 2018, which had expanded the definition of “employer” under Section 3(5) of ERISA (the “AHP Rule”), thereby broadening the scope of association health plans (“AHPs”).  According to the Court, it is unreasonable to interpret “employer” as including working owners and groups that do not have “a true commonality of interest” and doing so leads to “absurd results” and is an “end run” around the Affordable Care Act.  The Court’s opinion was issued with immediate effect and has cast doubt on the future use of AHPs, especially self-insured AHPs.

As background, the AHP rule was promulgated in response to President Trump’s October 12, 2017, Executive Order, which directed the DOL to expand access to and

Employer CCPA FAQs #4: What information is not “Personal Information” under the CCPA?

This post is part of our series of FAQs examining the California Consumer Privacy Act (“CCPA”)  that should help employers with operations in California to determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

By way of background, the CCPA is a new privacy law that will go into effect in early 2020. Because the CCPA refers to “consumers” many HR professionals do not realize that the CCPA, as currently enacted, also applies to data collected about California-based employees. Please see our recent blog post for a summary of which employers will be subject to the CCPA and the key requirements of the law.

Although the law will not be in effect until next year, employers who must comply should be addressing compliance obligations now.  For U.S. employers who have not had to comply

Employer CCPA FAQs #3: As used in the CCPA, do the terms “personal data,” and “personal information” mean the same thing? 

In the coming weeks we will be releasing a series of FAQs examining the California Consumer Privacy Act (“CCPA”)  of particular importance to employers.  These FAQs should help employers determine if they are required to comply with the CCPA and if so, what steps their HR professionals and IT departments should take to be in compliance.

By way of background, employers with operations in California should be aware of the CCPA, a new privacy law that applies to data collected about California-based employees.   Because the CCPA refers to “consumers” many HR professionals don’t realize that the Act, as currently drafted, applies to data collected about California-based employees. Please see our recent blog post summarizing the CCPA for employers.

The CCPA will go into effect in early 2020, and employers who must comply should be addressing compliance obligations now.  For U.S. employers who have not had to

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