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Recent thread on this. In short, you must comply with the Roth catch-up requirement in 2026 on a reasonable and good faith basis, and you must comply with the final rule in 2027.

We haven't done (nor will we) any formal quantitative analysis of this question. I CAN say that it is darned few, in general. An administrative PIA all out of proportion to the end results. Somewhat typical of many of the SECURE/2.0 changes...

My understadnign is no. W2 reportinb (Box 1) is completely unchanged. The participant is eligible to claim a deduction on their 1040. Same for overtime. I realize not all plans use the W-2 definition of wages but the same logic applies. This is solely a new deduction for people to claim. it is does not eliminate income.

Because the plan document specifies a new comp allocation, which is not a safe harbor formula, you have to satisfy the general test (aka the rate group test). However if you calculate your rate groups on allocation rates, instead of on accrual rates, then everyone should be in the same rate group and the test should pass easily. You don't need the gateway because you're not cross-testing. You also don't need the ABPT unless your rate group is less than 70% coverage (which is unlikely to happen, unless, as Lou mentioned, there is an allocation condition that isn't met by a large number of NHCEs).

I would agree with this interpretation if all notices were consistent. For example, If you have the information necessary for the communication in the SPD, but then have a subsequent annual notice with more generic language like "The Company may, in its sole discretion, make a matching contribution on your behalf...", it would be an issue.

Absolutely, just wanted to hear this from another TPA as the question is vague. Client has can balance and 401k, separately pass 401a4 on their own. He was reviewing my 5500s (2023) and thought the answer should be "yes", he may be audited if the answer "no". I mentioned the wording is ambiguous, issue is whether the two plan NEED to be aggregated in order to pass a4.; and not "does the plan pass 401a4. My question, for 2024, the CB does not pass but the 401k does. Which 5500-SF should be answered with a "no".

Here are the instructions for Line 14a on the SF: "Line 14a. A multiple-employer plan should skip this question. Check "Yes" if this plan was permissively aggregated with another plan to satisfy the requirements of Code sections 410(b) and 401(a)(4). Generally, each single plan must separately satisfy the coverage and nondiscrimination requirements. However, an employer generally may designate two or more separate plans as a single plan for purposes of applying the ratio percentage test of Treasury Regulations section 1.410(b)-2(b)(2) or the nondiscriminatory classification test of Treasury Regulations section 1.410(b)-4. Two or more plans that are permissively aggregated and treated as a single plan for purposes of the minimum coverage test of Code section 410(b) must also be treated as a single plan for purposes of the nondiscrimination test under Code section 401(a)(4). See Treasury Regulations sections 1.410(b)-7(d) and 1.401(a)(4)-9(a) for more information." Unfortunately, the question is structured where the answer for most plans is "No", which is a negative response, which leads clients to think something is wrong. Something like: "Did this plan satisfy the coverage and nondiscrimination requirements without relying on permissive aggregation with one or more other plans?"