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Mercer's estimates just published this morning: https://www.mercer.com/insights/law-and-policy/mercer-projects-2026-retirement-plan-limits/

I didn't think I could restate the MPP as a PSP. There will be no deferrals allowed. Just a straight PSP. If I can really just restate the MPP as a PSP then that would be the easiest. Thank you!

I’m familiar with Nevin’s views on many topics, including his recent things-that-make-me-mad lists. Especially his observations about illogical or intemperate extrapolations and observations. Rather, I’m thinking about stuff that might lead an EBSA employee to think it’s worthwhile to start an EBSA investigation, or at least an inquiry. And I’m not thinking about queries that might lead to a subtle point, but rather those that can suggest a realistic possibility of a breach. For example: late contributions? Did the plan have any non-cash contributions? Did the plan fail to provide required blackout disclosures? Did the plan have any (nonexempt) reportable transactions? Is the plan covered by fidelity-bond insurance? My time since I last regularly advised a Form 5500 work group likely is longer than yours. But I remember how often a customer furnished for the service provider’s assembly responses that were factually wrong for the question asked. And often perversely so, suggesting a possible violation or breach when none there was. I suggest there’s an opportunity for service providers to do a value-add for customers, especially those that administer small plans. And guarding against unconsidered responses to a Form 5500 query might help service providers too. (I don’t intend anything that would aid those who sell to fear, or exploiting perceived or even actual weaknesses in a retirement plan’s administration.)

Whatever ERISA and the Internal Revenue Code might permit a plan to provide, there might be three layers of documents to read. Do the plan’s governing documents provide for using forfeitures to pay or reimburse plan expenses? (Just yesterday, I reviewed a set of plan documents, made using a big recordkeeper’s IRS-preapproved documents, that read strictly preclude using forfeitures on plan expenses.) Does the service agreement obligate the recordkeeper to process the plan trustee’s reimbursement of a plan expense the employer paid? Does the service agreement set restrictions or conditions on processing amounts from forfeitures? (Recognizing that many plan sponsor-administrators get little or no legal advice, a service provider might narrow its obligations or set conditions to manage risks that the service provider is criticized for “allowing” a plan’s administrator to do something it ought not to have done.) Does the trust agreement or custodial-account agreement provide for the trustee or custodian to reimburse a plan expense the employer paid? If a reimbursement is provided or not precluded, what conditions does the agreement set for showing the trustee or custodian that the reimbursement is proper? This is not advice to anyone.