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If it’s a prototype formatted ftwilliam document, it’s a “Note” in the adoption agreement. These “notes” are generally not reminders or FYI’s, but are plan provisions that must be followed.

This was settled with Revenue Ruling 2019-19. If the check was written in 2024, it is reported by the plan as 2024 income to the participant. Any withholding is reported as withholding in 2024. Yes, the timing may seem unfair. Yes, the circumstances of the delay in cashing the check may have been beyond the control of the participant (lost in the mail, wrong address, the dog ate the check). None of this by itself changes the year of taxation for distribution. A case possibly may be made for a genuinely missing participant. Here is an excellent write-up about RR 2019-19 - https://www.blankrome.com/publications/questions-after-irs-guidance-uncashed-401k-checks Enjoy!

IRS guidance for Catch-Up contributions is scheduled to be published on Monday. See https://public-inspection.federalregister.gov/2025-00350.pdf for 57 pages of weekend reading. Guidance for Auto Enrollment is scheduled to be published on Tuesday. See https://public-inspection.federalregister.gov/2025-00501.pdf for 62 pages of additional reading. This is only 2 weeks after the effective date of the respective SECURE 2.0 provisions, so we will at least have some feedback on how accurate our guesses have been about the details.

I can't offer any quantitative insights, and I'll refrain from anecdotal observations or conjecture. However, I'll note that there are at least 3 distinct definitions of "actuary" when it comes to retirement, and which of these you mean might affect your analysis: Enrolled actuaries Individuals with a credential from any of the five U.S.-based actuarial organizations Individuals working in an actuarial capacity, regardless of whether they have obtained any credentials For example, federal law only recognizes definition 1 with respect to ERISA and the tax code, and only those actuaries may certify a plan's actuarial report, its funded status, its PBGC variable-rate premium, or its sufficiency for a standard termination. However state law might expand that to include actuaries under definition 2 for some purposes. And some people under definition 3 might have a job title of Actuary.