Sandra G. Rolitsky

Counsel

Cleveland
T +1.216.861.6165
F +1.216.696.0740

Overview

Sandra Rolitsky focuses her practice primarily on tax-qualified retirement plans. She advises on day-to-day administration and compliance issues, interactions with governmental oversight agencies (e.g., Internal Revenue Service, Department of Labor) and the integration of plans acquired through corporate acquisitions.

Sandra works with in-house counsel and human resource managers to resolve plan issues in light of the client’s objectives and concerns. She assists in developing internal procedures to facilitate compliance, provides guidance on the correction of plan failures and formulates plan design changes where possible to accomplish the client’s objectives. With respect to governmental oversight agencies, Sandra provides clients with advice and hands-on support in responding to examination and audit inquiries, and in formulating requests for rulings and determinations. She is experienced in integrating client plans acquired through corporate transactions and assists clients in accomplishing the desired treatment of such plans through amendment, freeze, termination and/or merger.

Select Experience

  • Formulated methodology under IRS Employee Plans Compliance Resolution System for plan sponsor to correct missed 401(k) deferrals and related matching contributions under various circumstances, including the use of an incorrect definition of compensation, improper hold-out of newly eligible employees and in plans with auto-enrollment features.
  • Formulated alternative design for a 401(k) plan loan program to enable loan refinancing as an alternative to default.
  • Provided instruction to the in-house staff of a plan sponsor regarding the ERISA duties imposed on plan fiduciaries.
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Experience

  • Formulated methodology under IRS Employee Plans Compliance Resolution System for plan sponsor to correct missed 401(k) deferrals and related matching contributions under various circumstances, including the use of an incorrect definition of compensation, improper hold-out of newly eligible employees and in plans with auto-enrollment features.
  • Formulated alternative design for a 401(k) plan loan program to enable loan refinancing as an alternative to default.
  • Provided instruction to the in-house staff of a plan sponsor regarding the ERISA duties imposed on plan fiduciaries.
  • Provided advice and formulated a methodology for the plan administrator to charge administrative expenses to plan assets consistent with ERISA.
  • Secured a “no action” letter from the U.S. Department of Labor regarding the late deposit of participant loan payments through an application to the Voluntary Fiduciary Compliance Program.
  • Secured a private letter ruling from the IRS approving a request for change in funding method for the surviving pension plan of the sequential merger of several plans.
  • Secured a compliance statement through applications to the IRS Voluntary Compliance Program:
    • approving the adoption of a retroactive amendment to correct overpayments made to certain pension plan participants.
    • providing a waiver of excise taxes for failure to process minimum required distributions and approving the proposed correction regarding missing and non-responsive participants.
  • Effectuated the merger of defined benefit and defined contribution plans acquired through corporate acquisitions into the client’s existing plans, including the identification and drafting of required plan amendments; identification and carry forward of protected benefits, rights and features; filing of required Forms 5310-A; and drafting and providing of required participant notices.

Recognitions and Memberships

Prior Positions

  • Deloitte Consulting LLP, Washington Rewards Policy Center of Excellence: Manager (2007 to 2013) 
  • Calfee, Halter & Griswold LLP
    • Partner (2004 to 2007)
    • Associate (1999 to 2004)
    • Senior Attorney (1994 to 1999)  
  • The Huntington Trust Company: Assistant Vice President (1991 to 1994)

Admissions

  • District of Columbia
  • Ohio
  • Michigan

Education

  • J.D., University of Detroit Mercy School of Law, 1980; Articles Editor, University of Detroit Journal of Urban Law
  • B.A., Psychology, University of Michigan