Ary Rosenbaum - The Rosenbaum Law Firm P.C.

When there is a plan restatement process, every retirement plan document provider adds some tweaks and removes some tweaks from their plan document.

For the Cycle 3 restatement process, I’ve noticed that most plan documents have removed the separate bonus deferral election that could allow participants a separate election where they could defer up to 100% of their bonus (not that I ever got one).

So if a plan sponsor has the election or still allows the same treatment of bonus deferrals like they do ordinary deferrals, I think now is the time to see what they’re doing and what they should be doing with the plan statement process underway.