For years, catch-up contributions were one of the few simple things left in the 401(k) world. If you were 50 or older, you could defer more. Payroll processed it. Providers administered it. Plan sponsors rarely thought about it beyond approving the annual limit increase. No one worried about litigation exposure tied specifically to catch-ups because, frankly, there wasn’t much to fight over. That era is ending. Between SECURE 2.0’s income-based Roth catch-up mandate, the new age-60-to-63 “special catch-up,” and the operational reality of fragmented payroll systems, catch-up contributions are about to become one of the most common—and most misunderstood, sources of compliance failure in retirement plans. And when things go wrong, plan sponsors won’t be the only ones in the crosshairs. Providers will be blamed, whether that blame is fair or not. This isn’t a future problem. It’s a slow-motion collision already underway.
Please see full publication below for more information.
