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There are 5 HCEs operating their solo 401(k) profit sharing plans with pro rata profit sharing allocation formulas.  NHCEs were hired in 2024 and became eligible in 2024 but there was no plan covering them.  The employer wants to retroactively adopt a PSP effective 2024 covering the NHCEs as permitted under SECURE 2.0 with a new comparability allocation formula, and cross test the contributions in all six plans.  To me, this seems permissible and not a cutback, because the NHCEs had not earned a right to the allocation formula.  Am I missing something?  Thank you!

We have a situation where the HCEs have had a separate 401(k) plan since 1/1/2025.  They want to establish a new safe harbor 401(k) plan for the NHCEs effective 10/1/2025.  Is there an issue with HCEs being eligible to defer since 1/1/2025 and NHCEs being eligible to defer effective 10/1/2025.  Does it matter if they elect a safe harbor match or safe harbor nonelective?

It may be cleaner to have a safe harbor plan effective 1/1/2026 but, thinking out loud, is it possible to have a safe harbor effective 10/1/2025 and the NHCEs have a missed deferral opportunity for the first three quarters of the year?

Thanks for any insights.

Did not come across this situation before.

Companies A & B are controlled group

Company A sponsors plan # 001

They want to add 2 more plans but the want company B to be the sponsor

Are the new plans required to be #002 and #003?

Thanks

The CPI-U for July 2025 was published with a value of 323.048. If inflation is 0% in August and September, based on Tom Poje's spreadsheet, some of the dollar limits for 2026 are projected to be:

NOT Official yet, of course:

Deferral limit: $24,500 (up from $23,500)

Catchup: $8,000 (up from $7,500)

Compensation Limit: $360,000 (up from $350,000)

Annual Addition Limit: $72,000 (up from $70,000)

DB Limit: $290,000 (up from $280,000)

HCE: $160,000 (unchanged)

Key Employee: $235,000 (up from $230,000)

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We have a level-funded plan.  Some employees pay a portion of the premium (those in HSAs), but it is mostly employer paid.

We are expected to have a refund/surplus this year.  Do we keep it, or are we required to allocate it to employees?  If we are required to allocate to employees, is it just to those who pay premiums on a pro-rata basis?  If employee's paid 10% of the premium, and employer paid 90%, do we allocate 10% to employees?  

As much guidance as you can give, I'd be grateful for!

Just curious if this sounds correct.  If we have a plan with auto-enrollment, we are using our "normal" enrollment forms, normal meaning no auto-enroll language on them.  The individual elects to participate or not.  If the plan sponsor has a newly eligible employee complete this form (yes/no) for enrollment, the auto-enrollment is really a non-issue, correct?  It seems simple to me:  We have the auto-enroll language in the document and SPD, but if we have a clear yes/no from the participant on the form whether they want to participate or not, auto-enrollment is avoided altogether.  

Are we missing anything here?

Thank you

In the past, a terminated participant with a vested benefit payable from a pension plan had to be provided with annuity options (actually, the normal form of benefit) if the lump sum value of their benefit exceeded $5,000. In other words, terminees with a vested lump sum value of less than $5,000 could simply be paid a cash lump sum. Did this threshold go up to $7,000 with the SECURE Act? If so, then I would think a terminee with a vested lump sum value of less than $7,000 could just be paid a cash lump sum for plan years beginning in 2025.

Does anyone disagree with this?

Thanks!

A lot of participation agreements include a space for you to enter the merger effective date of a participating employer's plan (e.g. in the event of the acquisition of another entity's stock and the merger of their plan into the main plan).  The challenge that is always there is we don't necessarily know exactly when the assets are moving (at least not in time to execute relevant documents). My preference has always been to have the merger effective date be coincident with the transfer of assets to simplify reporting and to not commingle the plans with 2 recordkeepers.

Would an effective date of "Coincident with the transfer of assets from the trustee or custodian of the ABC 401(k) Plan, which is expected to take place on or about September 15, 2025." be sufficient?

Recently I was lucky enough to receive the PenChecks NIPA scholarship to go for either a AKS or APA designation. I don't currently have any official designations so it's a very exciting thing. I know NIPA and ASPPA both do similar things but in different ways. My firm has never really invested in continuing education but I've convinced by boss to invest in it as I really would like to start getting official recognition. That said, memberships to ASPPA and NIPA are expensive and required to keep a certification, and I'd hate to end up in a sunk cost fallacy sticking with NIPA if ASPPA might be more useful. A couple questions:

• I know NIPA offers a kind of equivalency system for designations from some other institutions (for example, ERPA qualifies you for AKS 1, 2, APA 1-4). Does ASPPA have anything like this where a AKS or APA designation would be able to be converted to an ASPPA designation in the case we chose to switch?
• What's the cost difference look like between being a NIPA member and obtaining CE credits each year for their qualifications vs at ASPPA? We're a relatively small firm and it'd be at least somewhat of a consideration.

Any insights would be very helpful, thank you.

The Internal Revenue Service has had six people lead the agency this year.

Now, Billy Long is out as IRS commissioner, with the Secretary of the Treasury serving as acting commissioner.

The deputy commissioner position is vacant.

The chief of staff role is vacant.

More than half the officer positions are vacant or “(acting)”.

What do we imagine about the pace of new examinations in 2025?

So, as far as I can tell, an "applicable collectively bargained plan" means maintained under a collectively bargained agreement ratified before 12/20/2019. Does this mean that if the agreement is "re-ratified" - or more recent than 12/20/2019, then the amendment deadline is 12/31/2026, as opposed to 12/31/2028? It would seem so, although that doesn't make a lot of sense to me...

Hi, 

Plan is terminating and the termination date is 07/31/2025.  The Plan sponsor wants to do a annual employer match true -up contribution which usually occurs in Jan for the pervious year.  They calculate the match throughout the year on a pay-check-by paycheck basis.

1) Since the plan is terminating I believe they should calculate and contribute to the plan for the period Jan 01-July 31 it will be for a short plan year correct? 

2) Should they wait until next year to do the contribution or can they do the calculation now and contribute? 

Hi,

I know that almost all DB plans provide that the 3 highest salary years for the salsry average must be consecutive. However, is it allowed to provide for the salary average to be any 3 highest years, even if not consecutive. A bit generous, but for an owner only plan it might be preferred?

It appears that if not consecutive the it creates a definitely determinable issue?

Thank you

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Holding company has 15 wholly owned subsidiaries which all have separate qualified plans (mostly 401k plans). 

Does anybody have any tips/tricks for simplifying the process of performing (or avoiding?) coverage (and other?) testing across the controlled group? 

I'm not as familiar with Governmental Plans, but have a governmental hospital who is wanting to exclude a class of employees who choose to receive a higher compensation and give up their rights to participate in the plan?  Is this allowable?  I know they aren't governed by ERISA, so I wasn't sure what classes of employees could be defined to be excluded in the plan document.  This hospital has a 457(b) and a separate 401(a) for the employer match.  Thank you so much for any guidance you may have.

The Plan has a number of real estate properties held under the trust, including several that receive rent payments.  I believe that rents received from assets under the trust a part of the investment return.  My logic is that the properties are owned by the trust, and any rents received would be "investment earnings" and not contributions.  Am I off base?