Glossary

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401(a)
A 401(a) is a retirement plan that employers set up and that meet the qualification requirements of the Internal Revenue Code (IRC), Section 401(a). Section 401(a) defines 401(a) qualified trusts and details the various qualification rules of a 401(a) plan. Each state has specific laws governing 401(a) plans and a 401(a) plan must be either created or organized in the United States. Under a 401(a) plan, the employer determines the amount of money to be contributed each year (i.e. by the employee, the employer or both), vesting schedules and eligibility requirements that may be tied to job performance as a way to retain key employees. Under 401a, employers are allowed to create different 401a plans for different groups of employees, giving the employer flexibility in creating different incentive programs for specific employee categories. However, there are specific non-discriminatory requirements (i.e. detailed in IRC Section 401(a)5) that a 401(a) plan must adhere to. Funds from 401(a) plans may be distributed through lump-sum payments, rollovers, or annuity payments.

401(a)(9)
Tax code section requiring minimum distributions after age 70 ½.

401(k) Plan
A defined contribution plan offered by a corporation to its employees, which allows employees to set aside tax-deferred income for retirement purposes, and in some cases employers will match their contribution dollar-for-dollar. Taking a distribution of the funds before a certain specified age will trigger a penalty tax. The name 401(k) comes from the IRS section describing the program.

401(k) Profit Sharing Plan
A type of profit sharing plan that includes an elective salary deferral provision. The employer typically has the ability to make a matching contribution that is tied to the elective salary deferral, as well as a profit sharing contribution that is allocated to all eligible participants.

401(m)
Tax code section requiring nondiscrimination testing of employer matching and after tax contributions (see Actual Contribution Percentage).

402(g) limit
Test to ensure that the total of each participant’s elective deferrals has not exceeded the calendar year limit

403(b) Plan
Also known as a tax-sheltered annuity (TSA) or a tax-deferred annuity (TDA), is an employer sponsored retirement savings plan for employees of not-for-profit organizations, such as colleges, hospitals, foundations and cultural institutions.

415 Limit
Test to ensure that the total of each participant’s allocated contributions, including deferrals, and forfeitures for the limitation year (generally the same as the plan year) has not exceeded the annual additions limit.

457 Plan
A tax-deferred retirement savings plan available to state and municipal employees. Like traditional 401(k) and 403(b) plans, the money contributed and any earnings that accumulate are not taxed until withdrawn.

A

Accrued Benefit
A benefit that an employee has earned (or accrued) through participation in the plan. In a defined contribution plan, the participant’s accrued benefit is the balance in his or her individual account at a given time. In a defined benefit plan, the accrued benefit is determined as specified by the plan.

ACP Test
Also known as the Actual Contribution Percentage Test. An anti-discrimination test that compares the amount of match contributed to highly compensated employees to the amount of match contributed to non-highly compensated employees.

Actual Contribution Percentage Test
An anti-discrimination test that compares the amount of match contributed to highly compensated employees to the amount of match contributed to non-highly compensated employees.

Actual Deferral Percentage Test
An anti-discrimination test that compares the amount of match contributed to highly compensated employees to the amount of match contributed to non-highly compensated employees.

ADP Test
Also known as the Actual Deferral Percentage Test. An anti-discrimination test that compares the amount deferred by highly compensated employees to the deferrals of non-highly compensated employees.

Affiliated Service Group
Two or more entities having a service and possible ownership relationship.

Age-weighted Profit Sharing
A type of profit sharing allocation where participant’s age, or length of time until retirement, is factored into the allocation formula on an individual basis, so older participants receive a larger proportionate share of the contribution.

ASPPA
The American Society of Pension Professionals & Actuaries or ASPPA is a national organization for career retirement plan professionals. The membership consists of the many disciplines supporting retirement income management and benefits policy.

Asset Allocation
The process of diversifying a portfolio of investments among various classes of assets.

Audit CAP
Audit Closing Agreement Program. Audit CAP is available to correct any operational failure, provided the defect does not involve a diversion or misuse of plan assets, or an abusive tax avoidance transaction, for which correction rules outside of EPCRS apply.

Automatic Contribution Arrangement
Also known as Automatic Enrollment. The practice of enrolling all eligible employees in a plan and beginning participant deferrals without requiring the employees to submit a request to participate.

Automatic Enrollment
The practice of enrolling all eligible employees in a plan and beginning participant deferrals without requiring the employees to submit a request to participate. After the Pension Protection Act of 2006, there are two new Automatic Contribution Arrangements, the EACA and the QACA options. See definition in this section.

Automatic Rollover
The transfer of a small amount of funds, less than $5,000, from one IRA to another owned by the same person without the owner's authorization.

B

Basis Point
A term used to express fees, expenses, or loads relating to investments. A basis point equals one one-hundredth of one percent, e.g., .01% equals 1 basis point.

Beneficiary
A person designated by a participant or by the plan who may become entitled to a benefit under the plan.

Blackout period
A period of time when participants are not permitted to take loans, obtain distributions, or direct investments. A blackout period most commonly occurs during a conversion of plan's assets from one provider to another provider.

Bond Fund
A debt security issued by a government or corporation promising repayment of a specified amount, plus interest, by a stated date.

Break in Service
Generally, a 12-month computation period in which an employee is credited with no more than 500 hours of service.

C

Cafeteria Plan
Also known as a Section 125 plan. A plan which allows participants to choose between cash and qualified benefits e.g., health insurance, health flexible spending account to pay for or reimburse medical expenses, day care reimbursement account). The individual is giving up cash compensation to purchase “welfare” type benefits.

Cash or Deferred Arrangement
A qualified profit sharing or stock bonus plan that gives a participant an option to take cash or to have the employer contribute the money to a qualified profit sharing plan as an “employer” contribution to the plan (i.e., an “elective deferral”). These arrangements are often referred to as “401(k) plans.”

Cash-Out (Mandatory)
Applies to plans that have a provision in their document that forces the distribution of a terminated participant. This can happen without the participant's consent, but is only allowed if the benefit is less than $5,000. Unless the participant elects otherwise, amounts greater than $1,000 must automatically be rolled over into an IRA. Distributions of $1,000 or less can be distributed directly to the participant. Distributions are subject to federal withholding tax, and are subject to the 10% early withdrawal penalty if not rolled over. 

Catch-up Contributions
A catch-up contribution allows people over age 50 to make additional contributions to their 401(k) and/or individual retirement accounts. The catch-up contribution provision was created by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), so that older individuals would be able to set aside enough savings for retirement.

Cliff Vesting
A cliff vesting schedule vests 100% of employer contributions after a specified number of years of service. After three years of service, benefits must be fully vested.

CODA
A qualified profit sharing or stock bonus plan that gives a participant an option to take cash or to have the employer contribute the money to a qualified profit sharing plan as an "employer" contribution to the plan (i.e., an "elective deferral"). These arrangements are often referred to as “401(k) plans."

COLA
An adjustment made to Social Security and supplemental security income in order to adjust benefits to counteract the effects of inflation. COLAs are generally equal to the percentage increase in the consumer price index for urban wage earners and clerical workers (CPI-W) for a specific period.

Control Group
Businesses that share common ownership. Depending on the percentage of ownership, companies under a controlled group (common control) must be treated as one company for retirement plan purposes. For a corporation, a controlling interest means ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, or at least 80 percent of the total value of shares of all classes of stock.

Conversion
The process of changing from one service provider to another.

D

Deemed IRA Contributions
Voluntary employee contributions that are made to a qualified plan and designated by the employee to be treated as an IRA contribution. These contributions are permitted for plan years beginning on or after January 1, 2003, if the plan allows for them.

Defined Benefit Plan
Such plans define the benefits to be received at retirement. The employer determines, within IRS limits, the level of benefits, such as a fixed monthly payment or a certain percentage of compensation. Contributions are made annually to fund these benefits based on the benefit formula stated in the plan document.

Defined Contribution Plan
Individual accounts are set up for participants and benefits are based on the amounts credited to these accounts (through employer contributions and, if applicable, employee contributions) plus any investment earnings on the money in the account.

DEFRA ’84
Deficit Reduction Act of 1984. One portion of the Act was the Tax Reform Act of 1984 (TEFRA).

DFVCP
The Delinquent Filer Voluntary Compliance Program is designed to encourage voluntary compliance with the annual reporting requirements under the Employee Retirement Income Security Act (ERISA). Gives delinquent plan administrators a way to avoid potentially higher civil penalty assessments by satisfying the program’s requirements and voluntarily paying a reduced penalty amount.

Direct Rollover
A distribution to an employee made in the form of a direct trustee-to trustee transfer from a qualified retirement plan to an eligible retirement plan.

DOL
The Department of Labor administers the non-tax (regulatory and administrative) provisions of ERISA. The Department issues opinion letters and other pronouncements, and requires certain information forms to be filed.

E

EACA
An Eligible Automatic Contribution Arrangement enables employers to unilaterally enroll employers in their 401(k) plans at a specified percentage of compensation and invest contributions in government approved default investment funds without fear of fiduciary liability, and without being subject to state garnishment law restrictions. The arrangement can allow for the 90-day opt out provision.

EBSA
The Employee Benefits Security Administration is an agency of the Department of Labor responsible for protecting the integrity of retirement plans, health plans and other employee benefits.

EESA
The Emergency Economic Stabilization Act is one of the bailout measures taken by Congress in 2008 to help repair the damage from the subprime mortgage crisis. The act gives the Treasury Secretary the authority to buy up to $700 billion of troubled assets and restore liquidity in financial markets.

EGTRRA
Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA)

Elective Contributions
Also known as elective deferrals or 40(k) contributions. The amount of money the employee elects to contribute towards his/her 401(k) plan. As qualified elective contributions are tax deferred, the employer actually reduces the participant's income by the amount of the elective contribution. The accumulations and earnings in a 401(k) plan build on a tax deferred basis as well.

Eligibility
The determination of when an employee becomes a participant in the plan.

Entry Date
The date or dates specified in the Adoption Agreement at which a participant can begin receiving a contribution.

EPCRS
The Employee Plans Compliance Resolution System is a comprehensive IRS correction program that allows plan sponsors to correct plan defects voluntarily.

ERISA
The Employee Retirement Income Security Act of 1974 is the basic labor law covering qualified plans and incorporates both the pertinent Internal Revenue Code provisions by reference and labor law provisions.

ERISA Bond
ERISA regulations require that all pension plans, including 401(k) plans, be insured by an "ERISA bond" which has a payout equal to 10% of plan assets, or $500,000 (maximum of $1,000,000), whichever is less. There is no difference between an ERISA bond, fiduciary and fidelity bonds. All three respond to claims involving dishonest acts on the part of asset investment advisors or the employer. The fidelity, ERISA and fiduciary bonds cover against losses due to a criminal act.

ERPA
An Enrolled Retirement Plan Agent is an individual who has been approved by the IRS to practice before the IRS on certain retirement plan issues. An ERPA is similar to an Enrolled Agent.

ESOP
An Employee Stock Ownership Plan is an employee benefit plan intended to motivate employees by giving them a stake in the firm's success through equity participation. Purchase of shares by employees is funded by a loan (usually from a bank) guaranteed by the employer. This plan costs little or nothing to the employer because the loan principal is paid off from the dividend payment to the employees, and the loan interest is a tax deductible expense.

F

Fidelity Bond
ERISA regulations require that all pension plans, including 401(k) plans, be insured by an "ERISA bond" which has a payout equal to 10% of plan assets, or $500,000 (maximum of $1,000,000), whichever is less. There is no difference between an ERISA bond, fiduciary and fidelity bonds. All three respond to claims involving dishonest acts on the part of asset investment advisors or the employer. The fidelity, ERISA and fiduciary bonds cover against losses due to a criminal act.

Fiduciary
Any person (individual or corporation) who exercises discretionary authority orcontrol over the management or disposition of plan assets.

Forfeiture
A loss of benefits under the plan, a vesting concept relates to the loss of a participants non-vested benefit when certain events occur.

G

GATT ’94
General Agreement on Tariffs and Trade Act (part of the Uruguay Round Agreements Act)

Graded Vesting Schedule
A schedule used for vesting purposes, in which the vesting occurs over a period of five to 15 years. A six year graded vesting schedule, a common vesting schedule, is where vesting starts with the second year of service at 20% and the participant fully vests after the sixth year of service.

GUST ’94
Acronym used to refer to a collection of laws that changed some of the rules that apply to retirement plans GATT, USERRA, SBJPA and TRA of ’97.

H

Hardship Withdrawal
A hardship withdrawal occurs when you take money out of your 401(k) or other qualified retirement savings plan to cover a pressing financial need. You must qualify to withdraw by meeting the conditions your plan imposes in keeping with IRS guidelines. If you're younger than 59 1/2, you may have to pay a 10 percent penalty, plus income tax, on the amount you withdraw, and you may not be permitted to contribute to the plan again for a period of time.

HCE
Also known as a Highly Compensated Employee. Anyone who is a 5% owner of a company or who received more than $110,000 in compensation in 2011 (the compensation limit is adjusted annually).

HEART
The Heroes Earnings Assistance and Relief Tax. Amended the Internal Revenue Code of 1986 to provide benefits for military personnel, and for other purposes.

Highly Compensated Employee
Also known as a Highly Compensated Employee. Anyone who is a 5% owner of a company or who received more than $110,000 in compensation in 2011 (the compensation limit is adjusted annually).

I

In-Service Distribution
A withdrawal of vested money from a qualified plan to an employee who is still actively employed.

Integrated Profit Sharing Plan
A plan that takes into account either benefits or contributions made under Social Security.

Internal Revenue Code
All federal tax laws. The Internal Revenue Code is found as Title 26 of the United States Code, a collection of all federal laws.

IRA
Individual retirement accounts are self-directed investment accounts that provide the incentive of tax-deferred or tax-free earnings on assets in the account. If you earn income, or are married to someone who does, you can put up to $5,000 per year in an IRA in 2011. If you're 50 or over, you can invest an additional $1,000.

IRS
This is an agency of the Treasury Department, headed by the Commissioner of Internal Revenue, charged with enforcing the tax laws. Included in IRS functions are issuances of interpretations of the tax law, auditing of tax returns, and making criminal investigations.

J

JCWAA ’02
Job Creation and Worker Assistance Act of 2002.

Joint & Survivor Annuity
An annuity payable at least annually for the life of the participant, with a survivor annuity payable for the life of the participants spouse following the participants' death.

K

Key Employee
A participant who, at any time during the plan year is (1) an officer whoearns more than $130,000 as indexed, (2) a more-than-5 percent owner of the employer, or (3) a more-than-1 percent owner earning more than $150,000.

L

Life Annuity
An annuity payable at least annually for the life of the participant, with no benefits payable after the participants’ death.

Lump Sum Distribution
A one-time payout of assets in an account, typically a retirement savings account. When you retire or change jobs, you can take a lump-sum distribution as cash, or you can roll over the distribution into an individual retirement account (IRA).

M

Mandatory Contributions
Employee contributions that are required as a condition of participation in the plan, or as a condition for receiving benefits or contributions under the plan.

Matching Contributions
Employer contributions that are made on account of elective contributions or employee contributions; also includes forfeitures that are allocated as matching contributions

Multiple Employer Plan
A single plan maintained by more than one unrelated employer.

Mutual Fund
A single account designed to create a portfolio of individual investments that may help to reduce the risk of owning individual investments.

N

Net Asset Value (NAV)
The market value of one share of a mutual fund. A mutual fund must determine its NAV at least once each business day, usually at the close of business of the New York Stock Exchange. It is calculated by taking the value of all of the fund’s assets (closing market price for all securities plus cash and receivables), less expenses, and dividing by the number of outstanding shares.

New Comparability Formula
Also known as Class Allocated. New Comparability is a retirement plan design that allows business owners to allocate a more significant share of the tax qualified contributions to the accounts of select employees (such as owners or key employees) as compared to the other eligible employees.

NHCE
Employees who are not highly compensated. Generally, they are employees who earned less than $110,000 in 2011 (indexed for inflation). See highly compensated employees.

Non-elective contributions
Employer contributions (other than matching contributions) with respect to which the employee may not elect to have the contributions paid to the employee in cash or other benefits instead of being contributed to the plan.

Non-Highly Compensated Employee
Employees who are not highly compensated. Generally, they are employees who earned less than $110,000 in 2011 (indexed for inflation). See highly compensated employees.

Non-qualified Deferred Compensation Plan
An arrangement under which an employer provides deferred compensation to an eligible employee or allows independent contractors to defer compensation that would otherwise be currently payable for services rendered, but under a set of rules that makes them “non qualified” for purposes of the tax code.

O

OBRA ’86
The Omnibus Budget Reconciliation Act of 1987 contained provisions affecting the minimum funding standards in the section of the Act also known as the Pension Protection Act of 1987.

P

PBGC
Pension Benefit Guaranty Corporation - A nonprofit corporation, functioning under the jurisdiction of the Department of Labor, that is responsible for insuring benefits to participants of certain defined benefit plans. PBGC was created by the Employee Retirement Income Security Act of 1974 to encourage the continuation and maintenance of  private-sector defined benefit pension plans, provide timely and uninterrupted payment of pension benefits, and keep pension insurance premiums at a minimum.

Permitted Disparity
Method of computing and allocating non elective contributions under an employer sponsored plan, where the allocation method results in participants, with compensation above the integration level receiving a higher percentage of contribution .

Plan Administrator
The person an employer chooses to manage the organization's retirement savings plan, usually within the company.

Plan Document
The written document setting forth the terms of the plan, including the eligibility and vesting requirements, how benefits are determined, and when benefits may be distributed.

Plan Sponsor
An employer who offers the plan to employees. The sponsor is responsible for choosing the plan, the plan provider and the plan administrator, and for deciding which investments will be offered through the plan.

PPA 2006
The Pension Protection Act. Legislation signed into law on August 17 2006, for which the primary goal was to protect and enhance the retirement savings and pension provisions.

Prototype Plan Document
Usually a two part document. One part is the Basic Plan Document that contains language and definitions, which are the same for all plans. The other part is an Adoption Agreement, which is a fill-in-the-blank document containing employer information and specific plan provisions.

Q

QACA
A Qualified Automatic Contribution Arrangement is an automatic contribution arrangement must provide a specified schedule of automatic contributions, an employer contribution, and notices to participants describing the plan provisions. The QACA satisfies the Safe Harbor rules and is deemed to pass most non-discrimination tests.

QDIA
Qualified Default Investment Alternative. The Pension Protection Act of 2006 (PPA) includes a provision which insulates plan fiduciaries from liability associated with an approved default investment option.

QDRO
A Qualified Domestic Relations Order is a judgment, decree or order that creates or recognizes an alternate payee's (such as former spouse, child, etc.) right to receive all or a portion of a participant's retirement plan benefits.

QJSA
Qualified Joint And Survivor Annuity. An annuity payment from a qualified plan or 403(b) account that provides a life annuity to the participant and a survivor annuity for the spouse after the participant’s death.

QKA
The Qualified 401(k) Administrator credential was created by ASPPA for retirement plan professionals who work primarily with 401(k) plans.

QMAC
Qualified Matching Contributions are matching contributions that are 100% vested at all times and that are subject to the same distribution restrictions as elective contributions.

QNEC
Qualified Non elective Contributions are a non-elective contributions that are 100% vested at all times and that are subject to the same restrictions of distribution as elective contribution.

QPA
The Qualified Pension Administrator (QPA) credential was created by ASPPA to recognize professionals who are qualified to perform the technical and administrative functions of qualified plan administration. QPA's assist employers, actuaries, and consultants in performing functions such as determination of eligibility benefits, computation of benefits, plan recordkeeping, trust accounting and disclosure, and compliance requirements.

R

REA ‘84 (Retirement Equity Act)
The act that makes it mandatory for employees with spouses to be in receipt of retirement income from a pension plan in the form of a joint life and survivorship annuity, unless the employee's spouse waives that right in writing. This is to prevent the employee from writing the spouse out of the benefit income.

Rollover
A distribution in which assets from one tax-deferred or tax-free investment to another.

Roth 401(k)
A 401(k) feature that allows employees to make elective contributions on an after-tax basis. Qualified distributions from these plans, including both the Roth contributions and their associated earnings, are distributed tax-free.

S

Safe Harbor Plan
Pre-approved IRS language using specifically-named events that are deemed to meet the IRS requirements for the issue employer is required to make contributions for each employee. The employer contributions in Safe Harbor 401k plans are immediately 100% vested.

SBA of ‘96 (Small Business Jobs Protection Act of 1996)
Act which include provisions that provided tax relief for small businesses, protect jobs, and increased the take home pay of workers.

SCP
The Self Correction Program allows a plan sponsor that has established compliance practices and procedures the ability to self-correct insignificant operational failures at any time without contacting the IRS and without payment of any fee or sanction.

Self Directed Brokerage Account
Allows you to select from thousands of publicly traded mutual funds in addition to your Plans’ core investment options.

SEP IRA
Simplified employee pension. A defined contribution plan in which employers make contributions to individual employee accounts (similar to IRAs). Employees do not contribute to the plan.

SIMPLE 401(k) Plan
Savings Incentive Match Plan for Employees. A type of defined contribution plan for employers with 100 or fewer employees in which the employer matches 100% of employee deferrals up to 3% of compensation or provides nonelective contributions up to 2% of compensation. These contributions are immediately and 100% vested, and they are the only employer contribution to the plan. SIMPLE plans may be structured as individual retirement accounts (IRAs) or as 401(k) plans.

SIMPLE IRA Plan
Savings Incentive Match Plan for Employees. A type of defined contribution plan for employers with 100 or fewer employees in which the employer matches 100% of employee deferrals up to 3% of compensation or provides nonelective contributions up to 2% of compensation. These contributions are immediately and 100% vested, and they are the only employer contribution to the plan. SIMPLE plans may be structured as individual retirement accounts (IRAs) or as 401(k) plans.

Summary of Material Modification (SMM)
A summary of amendments and changes made to the plan that is distributed to participants in the interim period until a new SPD is distributed.

Summary Plan Description (SPD)
A document describing the features of an employer-sponsored plan. The primary purpose of the SPD is to disclose the features of the plan to current and potential plan participants. ERISA requires that certain information be contained in the SPD, including participant rights under ERISA, claims procedures and funding arrangements.

T

Tax-Sheltered Annuity Plan
Also known as a 403(b) plan or a tax-deferred annuity (TDA), is an employer sponsored retirement savings plan for employees of not-for-profit organizations, such as colleges, hospitals, foundations and cultural institutions.

Top Heavy Minimum
The top-heavy minimum benefit in a defined benefit plan must not be less than the employee’s average compensation multiplied by the lesser of 2% times the number of years of service, or 20%.

Top Heavy Plan
A plan in which 60% of account balances (both vested and non-vested) are held by certain highly compensated employees.

Top Paid Group
Employees who are among the highest paid 20% of all the employees of the employer. See Highly Compensated Employee.

TRA ‘86 (Tax Reform Act Of 1986)
Sweeping revisions to the income tax laws, enacted by the United State Congress in 1986, that lowered tax rates and eliminated many tax shelters.

Trustee
The individual, group of individuals, bank, or trust company having fiduciary responsibility for holding plan assets. 

U

USERRA ‘94
(The Uniformed Services Employment and Reemployment Rights Act) protects service members' reemployment rights when returning from a period of service in the uniformed services, including those called up from the reserves or National Guard, and prohibits employer discrimination based on military service or obligation.

V

Valuation Date
Refers to a point in time in which an asset is assigned a dollar value. It is a term often used in reference to valuation of assets to be distributed upon occurrence of an event, or a periodic determination of worth for reporting purposes.

Vesting Schedule
The structure for determining participants' right to company contributions that have accrued in their individual accounts. In a plan with immediate vesting, company contributions are fully vested as soon as they are deposited to a participant's account. Cliff vesting provides that company contributions will be fully vested only after a specific amount of time, and that employees who leave before this happens will not be entitled to any of the company contributions (with certain exceptions for death, disability or retirement). In plans with graded vesting, vesting occurs in specified increments.

Volume Submitter Plan
Documents that look like individually-designed documents and have been preapproved by the IRS.

Voluntary Correction Program (VCP)
Used when a plan sponsor is under examination and qualification defects are discovered. In the program the plan sponsor and the IRS negotiate an appropriate settlement, typically resulting in larger sanctions than under the VCP program designed to handle the more common and less flagrant plan defects submitted to the IRS for review upon payment of a user fee.

W

WRERA
The Worker, Retiree, and Employer Recovery Act of 2008 provides a number of relief provisions for qualified plan sponsors and their beneficiaries and individual retirement arrangements. These include provisions for required minimum distribution relief for 2009, special rules for Roth-to-Roth rollovers, and expansion of rollovers for non spouse beneficiaries.