The historical timeline of cash balance pension plans encompasses several key milestones and significant events that have shaped the evolution and adoption of these retirement benefit structures. These events highlight the legal, regulatory, and industry developments that have influenced the design, acceptance, and understanding of cash balance pension plans. The following is a detailed account of these milestones:
1. 1985: Introduction of Cash Balance Plans
The concept of cash balance pension plans emerged in the mid-1980s as an alternative to traditional defined benefit (DB) plans. The first known cash balance plan was established by the Xerox Corporation in 1985. This marked the beginning of a new era in retirement plan design.
2. 1999: Legal Clarity with Revenue Ruling 99-27
The Internal Revenue Service (IRS) issued Revenue Ruling 99-27 in 1999, providing legal clarity on the tax treatment of cash balance plans. This ruling confirmed that cash balance plans could comply with the age discrimination rules under the Employee Retirement Income Security Act (ERISA).
3. Late 1990s to Early 2000s: Rapid Adoption and Controversy
During this period, cash balance plans gained popularity among employers due to their potential cost savings and portability. However, controversy arose as some employees and advocacy groups claimed that these plans discriminated against older workers, resulting in lawsuits against companies like IBM and
Bank of America.
4. 2006: Pension Protection Act (PPA)
The PPA, enacted in 2006, introduced significant reforms to the pension landscape, including provisions related to cash balance plans. It clarified the legal framework for hybrid plans like cash balance plans, addressing concerns about age discrimination and providing guidance on interest crediting rates and vesting requirements.
5. 2010: Final Regulations on Age Discrimination
In response to ongoing litigation and concerns about age discrimination, the IRS issued final regulations in 2010 to provide clearer guidance on how cash balance plans should be structured to comply with the age discrimination rules under ERISA.
6. 2014: Supreme Court Ruling on Age Discrimination
The Supreme Court case of Tibble v. Edison International in 2014 addressed the fiduciary duty of plan sponsors to monitor and remove imprudent investments from retirement plans. Although not specific to cash balance plans, this ruling emphasized the importance of prudence in plan design and management.
7. 2019: Proposed Regulations on Interest Crediting Rates
The IRS issued proposed regulations in 2019 to address concerns about the use of interest crediting rates in cash balance plans. These regulations aimed to provide clearer guidance on how to determine a reasonable interest crediting rate, ensuring that plan participants receive fair and adequate benefits.
8. Ongoing Developments and Adoption
Cash balance plans continue to evolve, with ongoing developments in plan design, legal interpretations, and regulatory guidance. Many employers have adopted cash balance plans as part of their retirement benefit offerings, attracted by their flexibility, portability, and potential for cost savings.
It is important to note that the historical timeline of cash balance pension plans is subject to ongoing changes and developments. As laws, regulations, and industry practices evolve, the landscape of cash balance plans will continue to shape the retirement benefits landscape for both employers and employees.