News & Analysis as of

Internal Revenue Code (IRC) 401k Benefit Plan Sponsors

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Vesting doesn’t help with retention

I have worked at places that were so unpleasant that I consider myself lucky the vesting schedule was only six years. If they had the option, I’m convinced they would have implemented a 20-year vesting schedule. For me,...more

Miller Canfield

IRS Issues Proposed Regulations on Secure 2.0 Catch-Up Provisions

Miller Canfield on

The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more

Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

Shipman & Goodwin LLP on

The most recent wave of ERISA litigation is focused on the use of plan forfeitures in 401(k) plans, with the newest case, Armenta v. WillScot Mobile Mini Holdings Corp. being filed just last week. Although, for years, many...more

Seyfarth Shaw LLP

Catching-Up on Catch-Up Contribution Changes

Seyfarth Shaw LLP on

New proposed regulations issued by The Department of Treasury and IRS provide guidance on the provisions related to catch-up contributions that were included under SECURE 2.0 Act of 2022 (“SECURE 2.0”)....more

Eversheds Sutherland (US) LLP

Time to catch-up on your New Year’s regulations: IRS “super” and Roth guidance

On January 10, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations related to two new catch-up contribution provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0): (1) the...more

Bricker Graydon LLP

Act 3: To Roth or Not to Roth - That Is No Longer the Question for Some Catch-Up Eligible Individuals

Bricker Graydon LLP on

The IRS this past Friday issued proposed regulations regarding mandatory Roth catch-up contributions. SECURE 2.0 amended the catch-up contribution provisions of the Code....more

The Wagner Law Group

IRS Provides Guidance on Application of SECURE 2.0 Act’s Coverage of Long-Term, Part-Time Employees

The Wagner Law Group on

In Notice 2024-73, the Internal Revenue Service (“IRS”) issued guidance on the application of certain non-discrimination rules to long-term, part-time employees in Internal Revenue Code (“Code”) Section 403(b) plans subject...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (3): Automatic Enrollment (3)

SECURE 2.0 was enacted on December 29, 2022. Among its provisions is a requirement that “new” 401(k) plans and private sector 403(b) plans must automatically enroll their eligible employees, but not until the first plan year...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Annuities in 401(k) Plans

As Michael Corleone said in the very underrated “The Godfather Part III”, “Just when I want to get out, they keep bringing me back in.”...more

Nelson Mullins Riley & Scarborough LLP

IRS Reminder: Deadlines Extended for Retirement Plan Amendments but Compliance Still Required

On September 12, the IRS reminded plan sponsors to review and comply with IRS Notice 2024-02 (the “Notice”), which extended and consolidated deadlines for employers and others sponsoring 401(k), 403(b), 457(b) and other...more

Carlton Fields

2024 IRS Guidance on Employee Benefits

Carlton Fields on

Employee benefits or employee benefit issues can arise anytime you are providing employees something of value other than direct cash compensation. Engagement is very important. I hear it talked about a lot at 401(k) committee...more

Patterson Belknap Webb & Tyler LLP

Interim Guidance on Matching Qualified Student Loan Payments

Until recently, employer matching contributions under qualified plans were required to be conditioned solely upon employee contributions made to the plan. However, one of the many changes enacted by the Consolidated...more

Patterson Belknap Webb & Tyler LLP

Does Your Retirement Plan Need a 'PLESA'?

Pension-Linked Emergency Savings Accounts (“PLESAs”) are a special retirement plan feature created under SECURE ACT 2.0. PLESAs were first permitted to be made available to participants as of January 1, 2024. PLESAs, which...more

Verrill

Retirement Plans: What Categories of Employees may be Excluded?

Verrill on

We are often asked about the permissibility of excluding certain categories of employees from participating in an employer’s tax-qualified retirement plan. This post provides a high-level summary of what is and is not...more

Bricker Graydon LLP

403(b) Plans - Not Your Average Salary Deferral Plan

Bricker Graydon LLP on

Congress continues to pass laws that move 403(b) plans ever closer to 401(k) plans, but 403(b) plans remain distinct. Understanding these differences allows you to maintain a compliant plan that best serves the needs of your...more

Davis Wright Tremaine LLP

New IRS Guidance on Long-Term, Part-Time Employee Retirement Plan Participation

New proposed regulations clarify how employers should implement retirement plan eligibility rules for long-term, part-time ("LTPT") employees. While some questions remain, the proposed regulations provide a number of welcome...more

Dickinson Wright

Mastering Retirement Plan Forfeitures: A Deep Dive into IRS’s 2023 Proposals & Fiduciary Litigation Trends

Dickinson Wright on

When a participant terminates employment without being fully vested in their qualified retirement plan account, the non-vested portion of the account is a “forfeiture.” While forfeitures are a common element of most...more

Faegre Drinker Biddle & Reath LLP

IRS Announces 2024 Retirement Plan Limits

The IRS recently announced the 2024 cost-of-living adjustments to various benefit and contribution limits applicable to retirement plans. The IRS modestly increased the applicable limits for 2024. The following limits apply...more

Harris Beach Murtha PLLC

Enhancing Retirement Readiness Using Employer Matching Contributions on Qualified Student Loan Payments

Harris Beach Murtha PLLC on

Many employees who have had to resume repaying their federal student loans this month may find it harder to continue contributing to their employers’ retirement plans. For some employees, there simply is no room in the family...more

Verrill

Next Steps for Making Collective Investment Trusts Available to More Retirement Plans

Verrill on

Collective investment trusts (“CITs”) have become an increasingly popular choice for 401(k) plan investment menus over the past decade, consistent with a trend toward lower-cost investment options that has been driven, in...more

Eversheds Sutherland (US) LLP

Unlocking the process: Guide to ERISA individual prohibited transaction exemptions

Since 1996, the US Department of Labor granted more than 1,200 individual exemptions from the ERISA prohibited transaction rules. One of the distinctive features of ERISA is its prohibition, in ERISA section 406 as a...more

Faegre Drinker Biddle & Reath LLP

Day of the Dead…lines: Updating Your Plan’s Safe Harbor Notice

As the end of year approaches, now is the time for safe harbor 401(k) plan sponsors to prepare their annual safe harbor notices. 401(k) Plans that satisfy nondiscrimination testing via the employer contribution safe...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

When the IRS talks, it’s time to listen

When the Internal Revenue Service develops a laundry list of the things that they will focus on, when it comes to retirement plans, we need to listen. The IRS Tax Exempt and Government Entities Compliance Governance...more

Williams Mullen

Plan Sponsors Should Review Restated Pre-Approved Plan Documents with Care

Williams Mullen on

Employers using pre-approved plan documents for their defined contribution retirement plans, such as 401(k) plans, should carefully review restated adoption agreements and basic plan documents that may be issued by their...more

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