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ARTICLE · 30 SEPTEMBER 2026

Benefits Counselor - September 2026

Reinhart, Boerner, Van Deuren SC
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The IRS proposes new electronic rollover procedures and minimum funding rules for retirement plans, while federal courts weigh in on pension risk transfers, ERISA preemption, and arbitration clauses.

United StatesEmployment and HR
Reinhart Boerner Van Deuren S.C.
Reinhart Boerner Van Deuren S.C.
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RETIREMENT PLAN UPDATES

IRS Proposes Rules for Electronic Rollovers

In Notice 2026‑49, the Internal Revenue Service (IRS) proposed standardized procedures intended to make retirement plan rollovers faster and more efficient. These procedures would allow for direct communication between plans and facilitate electronic fund transfers as opposed to paper checks. The proposed guidance, provided as a series of sample forms for optional use with corresponding procedural steps, would apply to transfers between two retirement plans or between a retirement plan and an individual retirement account (IRA). Additionally, the proposal seeks to protect personal information via encryption and a unique “rollover identification number” for each specific transaction.

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