Nicolas Deguines

Internal Revenue Service Updates the Employee Plans Compliance Resolution System under Revenue Procedure 2021–30

T. KATURI KAYE and NICOLAS DEGUINES, August, 2021  On July 16, 2021, the Internal Revenue Service (IRS) released Revenue Procedure 2021-30, an updated version of the Employee Plans Comp­liance Resolution System (EPCRS), which we will refer to in this article as the “EPCRS Update.” This article summarizes the significant changes and revisions made by the […]

Ninth Circuit Approves ERISA Forum Selection Clauses

NICOLAS  DEGUINES and R. BRADFORD HUSS, June, 2021  The United States Court of Appeals for the Ninth Circuit, in the recent case of In re Becker, No. 20-72805, 2021 WL 1219745 (9th Cir. Apr. 1, 2021), upheld the use of forum selection clauses in Employee Retirement Income Security Act of 1974 (ERISA) governed plans as […]

DOL Issues New Cybersecurity Guidance — What Plans and Service Providers Need to Know

JENNIFER WONG and NICOLAS DEGUINES, April 29, 2021  On April 14, 2021, the Department of Labor’s (DOL) Employee Benefit Security Administration (EBSA) issued its first cybersecurity guidance for plan sponsors, plan fiduciaries, recordkeepers, and plan participants.1 Intended to complement EBSA’s regulations on electronic records and disclosures to plan participants and beneficiaries, the guidance is comprised […]