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Boo! Hiss!! Tom, good to see your name on the board again!

Consider the requirement to have an expectation of repayment before issuing the loan. When payment is by payroll deduction, there is a high level of confidence. If the loan request is on the eve of layoff, maybe not so much.

@Peter Gulia Im not 100% sure. I know that my document provider removed all mentions of domestic partnership, civil union, and other formal relationships from both basic plan documents and adoption agreements. I have seen similar language in other cycle 2 documents, and while I haven't reviewed the basic plan documents in depth, I don't recall seeing any cycle 3 adoption agreements that include formal relationships that are not marriage.

What do you call a wreath made up of $100 bills? A wreath 'a Franklin, of course. Merry Christmas all.

Over the 40+ years I’ve been working with retirement plans, the Internal Revenue Service has been remarkably consistent about recognizing an employer’s honest effort to meet tax law, especially when the relevant law is ambiguous and the IRS has not published guidance. It might help for the plan’s sponsor/administrator to document its reasoning for its good-faith interpretation.

That's bad.....! But good. Merry Christmas!

Just speculating, the comment from @Effen might be the source of your "greater than". Also, having two actuaries opine on a contribution implies a change of actuary (?), so maybe there are some census data questions to address.

There may be more current info from the IRS, but the last I looked at this, there was some controversy concerning a requirement to add auto enrollment to a Safe Harbor Non-ERISA plan (as opposed to a Non-Electing Church plan which is by law, not ERISA and, also, clearly exempt from the SECURE 2.0 Auto Enrollment procedures and rules) . The initial assumption was that there was no exception for a Safe Harbor Non-ERISA plan but those of us who work in this area pointed out that the auto enroll provisions could cause the sponsor to assert a level of control which could make the plan ERISA. A recent ASC broadcast reiterated this concern. There may be, further, some state law considerations: A Non-ERISA plan is subject to state law and there are states which still have auto enrollment prohibitions. Except for any Non-Electing Church plans which you may have, I would set aside these Safe Harbor Non-ERISA plans and keep looking for more clarity on this point as the Cycle 2 403(b) pre-approved documents come out and become available for use.

All determined at the appropriate interest rates used for maximum deductible contributions.

This is to share with you the happy news that today is the 25th anniversary of the first day on which the BenefitsLink Newsletter began daily publication. I didn't see this coming when I decided to go daily in 1999, at age 41. (The newletters had begun four years earlier, but they weren't being published every day.) The free information must be helping employee benefits practitioners to help their clients, which translates to the ability of employers to effectively run and fund programs that improve the lives of so many millions of working people (and retirees, and beneficiaries), even if most of them wouldn't know (or want to know) the difference between an ERISA and an eraser. What a noble endeavor, to be an employee benefits practitioner! Some lawyers and TPAs and other benefits practitioners have found work through our job board that's been running since 1996, which means they've gone to new workplaces and sometimes new cities, which means some of them have met people they wouldn't have met otherwise, which means some of them have fallen in love and then had children... which means there are people walking around on the planet now who wouldn't be here but for this "web site" thingie that started in 1995, and then the idea of sending "newsletters" by "email." None of that would have been possible without readers. The existence of "BenefitsLink babies" didn't occur to me until one day about 10 years ago, but I kept it quiet -- at that time, they were still teenagers! True to form, I and my business partner and wife Lois Baker (formerly an employee benefits lawyer, whom I met on CompuServe in 1990 while trading ERISA questions using dial-up modems) have failed to do any marketing of this happy day. But as I sat here at the keyboard today I had the idea that we would get so much joy by celebrating the occasion with readers. I hope this hasn't come across as a commercial but instead is the lifting of an E-flute of cyber-champagne -- here's to employee benefits practitioners everywhere! It's a wonderful community, and for 25 years now and still counting, we are so happy to be a part of it.

IMHO, BenefitsLink has changed, for the better, the way benefits professionals do their jobs. Attaboy Dave!