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And the plan must have the safe harbor provisions. It is not considered safe harbor if the plan does not say it is safe harbor.

No. A match of 100% on the first 6% satisfies the ADP and ACP safe harbor (assuming no allocation conditions, vesting rules, notice requirements, etc. are satisfied). The 4% rule you reference comes into play when a discretionary match is funded in addition to a safe harbor formula. If there is a discretionary match in addition to a safe harbor match, then to satisfy ACP safe harbor, the match cannot take into account more than 6% of pay and the match contribution cannot exceed 4% of pay.

The concept of a recordkeeper requesting an indicator is separate from administering Roth catch-ups. As the honorable WCC notes the recordkeepers want the indicator for targeted communications and also for monitoring after end of the year. But I am not aware of any recordkeepers doing more than that- so in reality regardless of whether an indicator is shared with the recordkeeper payroll providers are effectively responsible for the administration.

What does the recordkeeper’s service agreement provide? How, if at all, does the recordkeeper adjust its records if the contribution arrives much later than the expected pay date? How, if at all, does the recordkeeper adjust its records if the contribution never arrives? If the date a contribution is posted is sooner than the date the contribution purchases mutual fund shares or collective investment trust units, how would a participant check whether her account balance is correctly determined? If a contribution is invested before the trustee or custodian or its agent has money from the employer, is the service provider’s loan sufficiently documented to meet the prohibited-transaction exemption? Could the posted dates affect in which plan year a trustee or custodian reports and certifies a contribution amount? Could the posted dates affect in which limitation year the plan’s administrator assumes an amount is an annual addition? Did the plan’s administrator accept the recordkeeper’s service agreement without reading it?

I am curious about why the industry doesn't view this as purely a payroll function. While an RK needs DOBs for various reasons and can use them to determine whether a participant's catch-up needs to be returned because they are not the proper age, there is no other reason to collect SS wages except for this new rule. Why can't this responsibility be put on payroll companies to ensure they do it properly? They have all the records.