The Internal Revenue Service (IRS) issued Revenue Procedure 2016-4 outlining annual procedures for requesting letter rulings.
In
the guidance, the IRS says a section has been added to note that
opinion and advisory letters will be issued to 403(b) pre-approved plans
and provide information regarding the process in obtaining such
letters.
In April 2013, the agency issued Revenue Procedure 2013-22 establishing the program
and providing an instruction manual for how the program works. The
deadline for submitting applications for opinion and advisory letters
regarding the acceptability under Section 403(b) of the Internal Revenue
Code of the form of prototype plans and volume submitter plans was
April 30, 2015.
Though 403(b) plan sponsors had to adopt a
written plan by December 31, 2009, they will be able to restate their
plans to adopt one of the prototypes when the IRS makes them available.
Those plan sponsors that did adopt their written plans by the 2009
deadline, will also be given a remedial amendment period to
retroactively correct plan operational failures—i.e. plan operational
practices that did not conform to document requirements or features.
In
anticipation of this, to encourage employers who sponsor 401(a)
qualified retirement plans and 403(b) plans to correct plan failures
through the IRS’ Voluntary Correction Program (VCP), the IRS reduced the general VCP fees
for most new submissions made on or after February 1, 2016. The agency
also added references to 403(b) pre-approved plans in its user fee guidance.
Another notable change is that the letter ruling guidance has been
modified to clarify that the IRS Employee Plan Compliance Resolution
System (EPCRS) covers SIMPLE plans and 457(b) plans.
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Every January, Bob Doll, senior
portfolio manager and chief equity strategist for Nuveen Asset Management,
makes 10 predictions about the markets and the economy for the year.
Last year, shadowed by anxiety
and uncertainty, Doll says, proved mostly unrewarding for investors. China’s
slowdown and the long-anticipated Fed liftoff, as well as a late-year commodity
prices meltdown and continued terrorism threats presented headwinds for stocks.
Doll notes that the fundamental
issue of weak corporate earnings was most responsible for equities’ lackluster
progress. The combination of a strong U.S. dollar and falling oil prices acted
as a drag on revenues and earnings. It wasn’t surprising that energy, materials
and some industrial companies faced problems. What was somewhat surprising,
however, was that the benefits of lower oil prices only marginally lifted
earnings from consumer-oriented and other “energy-using” segments of the market.
This year brings good news (a
recession is unlikely, Doll believes), bad news (it’s difficult to see
significant market gains), as well as ugly news (in order to make money, tactical
moves may be likely).
Retirement plan advisers will
have their work cut out for them, according to Doll, and the need for advice will
only go up when they can’t simply fall back on index funds. “When the market’s
up, say 15% every year, it doesn’t matter,” he tells PLANADVISER. People can buy
the index and ride the wave. “But we don’t have that anymore and people will
have to work harder”—both as fund managers and as investors.
Plan participants who are
nearing retirement obviously have more challenges than younger ones, Doll says.
Younger participants, especially those just starting out, simply need to be actively
investing their money, and leveraging the power of dollar-cost averaging and a
long time horizon. “How many 20-year periods has the stock market not outperformed everything else?” he
asks. “Answer: zero! They should be in the stock market! Jumping out at the bottom
is what makes bottoms, just like careening in at the top makes tops.”
NEXT: Will active
management trump index funds in a volatile market?
Market conditions may motivate
more plan sponsors to turn to active management strategies, Doll believes, but “managers
are going to have to show the results to justify the money coming their way.”
Plan sponsors and advisers will
have to pick good managers, Doll says, “managers that have a process that makes
good sense and that have some history of outperformance.” But outperformance is
just one factor. “You cannot judge on the past three years or just look at past
performance.”
Factoring in the manager’s process
means weighing several considerations, a combination of manager changes and how
the actual process changes. “Is there reason to believe that a process is going
to work over time?” Doll points out. “No one can guarantee a one-year return.”
For this year, Doll forecasts
Treasury rates will rise, but high yield spreads will fall. He notes that for
several years Treasury yields have been rising unevenly, and that many people
forget (or perhaps missed altogether) that 10-year Treasury yields bottomed at
1.43% in July 2012. Since then, rates
have meandered irregularly higher as economic growth advanced and the Fed
continued to make slow moves toward normalization.
U.S. equities will experience a
single-digit percentage change for the second year in a row, Doll predicts, for
the first time in almost 40 years. Markets rarely deliver single-digit returns,
he observes, even though the average long-term annual rate of return for
equities is in the high single digits. And it is especially rare for equities
to do so in consecutive years. The last time this happened in the U.S. was 1977
and 1978. He believes a large upside or a large downside move (meaning a
double-digit percentage gain or loss) is unlikely.
Doll’s forecast for S&P 500
earnings: they will make limited headway as consumer spending advances are
partially offset by oil, the dollar and wage rates. In 2015, the constant pressure
on earnings was the most significant headwind for equities. Doll does not
expect the dollar to climb as significantly as it did in 2015, and he believes
oil prices are bottoming, twin headwinds that should ease.
NEXT: Look for these 10
things to happen in 2016
Upward pressure on wages,
however, could emerge as a new problem for earnings. Higher levels of consumer
spending should provide modest revenue growth, and ongoing corporate buybacks
should allow some degree of earnings growth.
Bob Doll’s predictions for 2016
are:
U.S. real gross domestic product (GDP) remains below 3% and
nominal GDP below 5% for an unprecedented tenth year in a row.
U.S. Treasury rates rise for a second year, but high yield
spreads fall.
S&P 500 earnings make limited headway as consumer spending
advances are partially offset by oil, the dollar and wage rates.
For the first time in almost 40 years, U.S. equities experience
a single-digit percentage change for the second year in a row.
Stocks outperform bonds for the fifth consecutive year.
Non-U.S. equities outperform domestic equities, while non-U.S.
fixed income outperforms domestic fixed income.
Information technology, financials and telecommunication
services outperform energy, materials and utilities.
Geopolitics, terrorism and cyberattacks continue to haunt
investors but have little market impact.
The federal budget deficit rises in dollars and as a percentage
of GDP for the first time in seven years.
Republicans retain the House and the Senate, and capture the
White House (as long as Trump is not the nominee).
Every
year, Doll also scores his previous year’s forecast. He gives himself seven out
of 10 for 2015. He incorrectly predicted a 3% growth in U.S. GDP and said U.S.
equity mutual funds would show their first significant inflows since 2004. He marked
as “half correct” two calls: that U.S. equities would enjoy another good yet
volatile year, as corporate earnings and the U.S. dollar rose, and that oil
prices would fall and then end the year higher than where they began.