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Christopher T. Collins

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Christopher T. Collins is Chair of the Executive Compensation & Employee Benefits group. He assists employers on all aspects of employee benefits, focusing on retirement and welfare plan design, qualification and compliance. He frequently advises employers regarding benefit issues in connection with mergers and acquisitions and U.S. Department of Labor and Internal Revenue Service correction programs.

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Starting January 1, 2024, a new Illinois law will require employers in the greater Chicago metropolitan area with 50 or more covered employees within one mile of a fixed-route public transit service to provide their full-time employees with pre-tax public transit benefits.  This type of benefit program allows eligible employees to elect pre-tax reductions from their pay to purchase transit passes for use in commuting to and from work.  Transit passes covered by the program include fare cards and passes for public transportation. Continue Reading New Law Requires Greater Chicago Metropolitan Area Employers to Provide Pre-Tax Transit Benefits

In late 2022, Congress passed the SECURE Act 2.0, which, along with other items, introduced a new rule requiring that catch-up contributions made by highly compensated employees be made on a Roth after-tax basis only. Less than one year later, and only a few months before this new rule was to go into effect, the IRS issued Notice 2023-62, which provides highly anticipated transition relief for the Roth catch-up contribution rule by extending the compliance period by two years.Continue Reading Just Dropped: IRS Provides Relief on Roth Contributions for HCEs

In January 2022, the Supreme Court held in Hughes v. Northwestern University, 142 S. Ct. 737, that courts must apply a context-specific inquiry to determine whether plan participants state plausible breach of fiduciary duty claims against plan fiduciaries for violations of the Employee Retirement Income Security Act (“ERISA”) when selecting and monitoring investment funds and recordkeeping services under a plan.  In so doing, the Supreme Court reversed the Seventh Circuit’s decision in Divane v. Northwestern University, 953 F.3d 980 (7th Cir. 2020) (now known as Hughes), stating “The Seventh Circuit erred in relying on the participants’ ultimate choice over their investments to excuse allegedly imprudent decisions by [Northwestern fiduciaries].”  142 S. Ct. at 742.  Hughes is pending before the Seventh Circuit on remand.Continue Reading Seventh Circuit Applies Hughes v. Northwestern University to Dismiss