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For an age 60-63 catch-up, is 2026’s inflation adjusted amount $12,000 or $11,250?

On the day the Bureau of Labor Statistics released September’s Consumer Price Index measures:

John Feldt said $12,000. https://benefitslink.com/boards/topic/80106-2026-cola-projection-of-dollar-limits/#comment-354029

Mercer said $12,000. https://www.mercer.com/insights/law-and-policy/mercer-projects-2026-retirement-plan-limits/

But Milliman said $11,250. https://www.milliman.com/en/insight/2026-irs-limits-forecast-final-estimates

Can smart BenefitsLink people resolve which is correct?

Here’s the adjustment rule [I.R.C. § 414(v)(2)(E)(i)]:

(E) Adjusted dollar amount. For purposes of subparagraph (B), the adjusted dollar amount is —

(i) in the case of clause (i) of subparagraph (B), the greater of —

(I) $10,000, or [and]

(II) an amount equal to 150 percent of the dollar amount which would be in effect under such clause for 2024 for eligible participants not described in the parenthetical in such clause[.]

If an active (not a 5% owner) participant is 80 years old and dies during the year, does the beneficiary have to take and RMD? The participant is of RMD age but was not required to take them as they were still actively employed.

Participant was 0.3% partner in law firm in 2024. Still working.

No ownership in 2025

Turns 73 during 2025.

Is he required to take an RMD which would be due 4/1/2026?

Interesting situation here. A new plan in 2025. Long story short, they withheld deferrals from many payrolls and did not submit. They have since submitted, using DOL calculator for interest, and will file with the DOL under VFC program. As part of the VFC filing, they will submit a copy of the 5330 proving payment of the interest.

So, must this 2025 5330 filing, for the 2025 year, be submitted electronically? In July of 2025, the IRS said this:

Treas. Reg. 54.6011-3(a) requires a taxpayer to file Form 5330, Return of Excise Taxes Related to Employee Benefit Plans, electronically for taxable years ending on or after December 31, 2023, if the filer is required to file at least 10 returns of any type during the calendar year that the Form 5330 is due. Treas. Reg. 54.6011-3 (b) and Instructions for Form 5330 also provide, on an annual basis, exclusions from electronic filing requirements in cases of undue hardship.

Form 5330 can be filed electronically using the IRS Modernized e-File (MeF) System through an IRS authorized Form 5330 e-file provider. Currently, IRS has only one authorized e-filing provider for the Form 5330. As a result of the lack of authorized e-file providers for the Form 5330, the IRS has determined that a filer is permitted to file a paper Form 5330 for the 2024 taxable year. The filer should document that the reason for not filing electronically and filing a paper Form 5330 is the lack of authorized vendors.

Seems to me that since this 5330 is being filed under the same timeframe and basic circumstances, that this waiver should prove valid and allow paper filing. Thoughts? Thanks.

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Have been the EA for about 25 DB plans (mostly stand alone) for a TPA where we billed the TPA after we did the valuation which was a mutual understanding though nothing in writing. For 10 years payments came but early 2024 they stopped and have been sporadic since though valuation work done and forms submitted through 2024 plan year. Last partial payment was in July and outstanding fees are up to $30k, most for 2 plan years. What would be ethical ways to proceed to get paid (assuming will not be doing any further work for this TPA and not suing based on past experience):

a) contact plan sponsors directly regarding the situation,

b) provide names of plans to another TPA with the expectation they would contact the plan sponsors,

c) amend 5500 fililngs for unpaid years (since we have filing authorizations) removing the SB,

d) 1099 the TPA for the $30k,

e) publicly name the TPA (like on this message board) as a warning to others?

Are none, some, or all of these worth a try or are there better options?

I have a client that would like to offer individual brokerage accounts (as an alternative to investing in a platform) for accounts over a certain threshold of assets (let's say $50,000+).  Is this discriminatory?

A client asked about the following situation:

* Employee becomes a highly paid participant ("HPP") for 2027 subject to the mandatory Roth catch-up rules.

* Although the plan has adopted a "deemed Roth election" feature, employer never provided notice to the employee that she was an HPP for 2027 and, thus, was required to make catch-up contributions on a Roth basis.

* HPP makes pre-tax deferrals in 2027 up to the 402(g) limit and the statutory catch-up limit.

The client asks "what is the required correction?"  My thoughts are as follows:

* The client cannot move the pre-tax catch-up contributions to the HPP's Roth deferral account, because the deemed Roth election feature does not apply (due to the fact that the HPP was not given an opportunity to opt out of the deemed Roth election feature).

* In this case, the pre-tax catch-up deferrals (and earnings) are distributed to the HPP under the mandatory Roth catch-up regulations.

* However, I don't think this is the full correction.  I believe there has been a failure to provide the HPP with an opportunity to elect and make catch-up contributions.  Accordingly, this error must be corrected by the employer making a QNEC as set forth in Rev. Proc. 2021-30, Appendix A, Section .05(2)(g)(4)(a) ("Improperly excluded employees:  catch-up contributions only").

Have I thought this through correctly?  Thanks in advance.

Is there a limit to the amount of rollovers a participant can take, using the 60-day window to repay the distribution/roll it into an IRA?  I believe it's limited to one per year, but I just wanted to confirm.

Thank you!

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We're a TPA/recordkeeper who works almost completely in conjunction with 3(38) advisory firms to provide plans. As it stands we don't do anything in regards to investment lineups on the plans, that's chosen exclusively by whatever advisor is the 3(38) on that plan. We're toying with the idea of creating a very stripped-down, basic 401(k) plan to sell as a "plan in a box" of sorts for very small companies unable to afford our standard tier. One of the issues is that such a plan would require an investment lineup, and having an advisor with a bps fee on the plan doesn't seem ideal for this structure.

We absolutely don't want to take on 3(21) / 3(38) liability, which is why we've never thought about this before. However, I've heard recently from some sources that 3(21) responsibility is triggered only if it's plan-specific advice given to a sponsor. Supposedly, I've heard that some record keepers are able to essentially say "here's our standardized fund line-up, you as a sponsor can either adopt it or choose your own funds to use" and in doing so, the plan sponsor remains the fiduciary for 3(21)/3(38) purposes.

Anyone have any further insight on this?

I have seen this issue in another post, however, it did not specifically address an owner only 401k plan.  The employer is a Sub-S Corp with no other employees.   The plan requires 1 year of service, 1000 hours with duel entry dates.  Is there an exception for the owner's spouse to enter the plan without satisfying the service requirement? Or should I amend the plan to eliminate the service requirement and then re-amend it back if and when he hires a new employee.  He is considering a new hire in the next year or two.

Does anyone know what the following means in the PPD document - plan elects a 6 month eligibility (not consecutive and no hours required), elapsed time is not marked but actual hours is marked. The adoption agreement notes that this is passage of time and not elapsed time and no minimum hours of service is required. My question is do you still have to apply the 1000 hour in a 12 month period failsafe? How would any break in service provision work? Thanks!

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Normally, for 2026, the plan would need to be amended to allow the increased limit by 12/31/2025? Has there been any guidance on allowing a later amendment date, due to the fact that the legislation only passed this Summer? I haven't seen anything. Doesn't really matter to me, as I don't do cafeteria plan amendments, but just curious.

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Plan currently has no excluded employees. Client want to "exclude" most ACTIVE part-time employees by Amending the plan to use the "20 hours per week" exclusion.

This idea makes me uncomfortable. Seems more like a violation of "once-in always-in."

And, I also understand the related issue of the 20 hour per week rule being impacted by the LTPT rule.