IN BRIEF: In April of this year, the Supreme Court issued its unanimous opinion in Cunningham v. Cornell University, holding that in order to successfully state a claim that a defendant entered into a prohibited transaction in violation of Section 406 of ERISA, a plaintiff need not also plead that […]
Benefits Quarterly
Catch-Up Contribution Changes: Are you Caught Up?
The SECURE 2.0 Act of 2022 made significant changes to retirement plans, some of which became effective immediately and others that have gradually become effective in recent years. Two of the changes that recently became effective were the increased catch-up contribution limits for participants ages 60 to 63, and the […]
Congress Eases Employers’ ACA Reporting Burdens; IRS Supplements New Laws with Necessary Guidance
Since 2016, employers subject to the Employer Shared Responsibility provisions of the Affordable Care Act (the “ACA”) (i.e., “applicable large employers”) have been required to annually report certain information regarding their offers of group health coverage to the IRS and to applicable employees. Each year since, applicable large employers have […]
New Developments in the CTA: FinCEN and the U.S. Department of the Treasury Offer Temporary Compliance Relief
On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or enforcement actions against any companies for failing to file or update beneficial ownership information (BOI) reports required under the Corporate Transparency Act (CTA) by the current deadline of March 21, 2025. […]
File Your CTA Beneficial Ownership Report with FinCEN on or prior to March 21, 2025
As of February 18, 2025, FinCEN filing obligations under the Corporate Transparency Act (CTA) are required. The nationwide injunction previously imposed by the U.S. District Court for the Eastern District of Texas, Smith v. U.S. Department of the Treasury, has been lifted by that court. By changing course, the Texas […]

