Before IRAs’ custodial-account agreements next are amended (by December 31, 2027), those accounts will have been operated for about eight years with at least some in-operation provisions different than the ostensible written provisions.

How does an individual learn which provisions are real, and which are displaced by Internal Revenue Code and other law changes?

Remember, many, perhaps most, of an IRA’s tax-sensitive provisions call for an individual to administer her account. Often, a custodian is protected in following the account holder’s instructions.

Why does the IRS not allow an agreement to state provisions by referring to the Internal Revenue Code?

Any insight, articles, or other resources anyone can share that would address the following questions:  (1) Can different plans sponsored companies a part of the same controlled group stop offering coverage for weight loss medications?; (3) Can companies within the same controlled group decline to offer coverage for weight loss medications while others offer it?  Even if they participate in the same welfare plan? (3) Can a plan limit or exclude new to market weight loss medications (non injectables)?

I maintain HDHP family coverage that covers me, my 24-year-old daughter, and my husband. Coverage for my husband is secondary to Medicare (Medicare became primary in March of 2025). My 24-year-old daughter is a qualifying relative for 2025 and therefore I will claim her as a dependent on my 2025 tax return.

I contributed the full family contribution limit to my HSA for 2025 and plan to again for 2026. However, my husband's Medicare advisor recently told me that just because I have family coverage does not necessarily mean I can contribute the family contribution limit. If just my husband and I were in the HDHP, and he has coverage elsewhere (Medicare), my understanding is that I could only contribute the self-only limit. However, since my daughter is also covered, I was under the impression that I could contribute the family contribution limit.

I'm having trouble finding anything definitive that says whether a qualifying relative who is a child is treated differently from a dependent child (under age 19 or full-time student under 24) in this instance.

I'm hoping that @BrianGilmore in particular can answer whether I still qualified/qualify for the family contribution limit for 2025 and 2026. If not, I assume I'll need to withdraw money from my HSA for part of 2025 (would have qualified for the family contribution limit until my husband's Medicare became primary) and also lower my contribution for 2026 going forward, correct?

And a follow-up question - if I was still eligible to contribute the full family contribution amount for 2025, but it turns out that my daughter is not a qualifying relative for 2026 (that is, she makes over $5,050 for the year), and I have made the full family contribution amount for 2026 before I know that she is not a qualifying relative, is there a consequence (penalty) other than having to withdraw the overage from my HSA? In other words, should I take the safer approach of lowering my contribution to the self-only limit and possibly forego the tax savings associated with the higher contribution amount?

Thanks for any help!

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We have a terminating plan whose final forms need to be filed by January 31, 2026.  We completed them in Relius Web Client several months ago but the client failed to sign the forms until after January 1st.  We had to redo the forms on the Form Year 2025 forms to send them through Web Client.  The issue now is that the plan needs an 8955-SSA which is not yet available.  We do have everything set up so that if needed we could submit directly through the FIRE system but i am having no luck coming up with a template for  manual submission.  Does anybody have any resources for a format or am I missing a way to create it in Relius (Admin or Web Client)

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Bloomberg this morning features an article about micro retirement plans. Isabelle Lee, Wall Street Pushes Solo 401(k)s as More Americans Work for Themselves, Bloomberg (Jan. 23, 2026, 6:00 AM EST).

We need not repeat an observation that there is no such thing as a Solo 401(k) plan. Rather, let’s recognize the sales label for what many businesspeople believe it describes: an individual-account (defined-contribution) retirement plan the plan sponsor and its owner expect to use for participation by only one worker, the owner.

BenefitsLink neighbors, what are you seeing happen in this space:

Do more users of these plans recognize that, to run a plan without trouble, one needs a TPA’s services?

Are there many who try to be a do-it-yourselfer (until it fails)?

Aside from a failure to file a Form 5500 return, which other errors are detected?

Are CPAs and other tax preparers a useful alternative for filing Form 5500 returns? Or, not so much?

Beyond a Form 5500 return, what are other failure points?

As a non-DC person, I am trying to understand how this works.

A 50+ year old sole-prop client (no employees and reading online about it) contributing very large amount into a CB plan and 6% PS plus pre-tax deferral is asking me about restructuring her 401k plan with mega backdoor Roth.

Any comments on what can be done are appreciated.

Hi all,

A participant satisfies the eligibility requirements of 21 and 3 months in August 2025. Because of a mix-up at the Plan Sponsor HR's department, they were not provided enrollment materials (SPD & Annual Notice) at that time. This seems to constitute an MDO, with necessary corrections outlined in EPCRS.

What if the participant received the enrollment materials well advance of their entry date, say on their date of hire in May. My recollection is that this is permissible, but I know certain other items have a 'reasonable period' defined with 'no fewer than 30 no more than 90 days prior' language. If this is permissible, would this no longer constitute an MDO since the participant received enrollment materials and could have made a deferral election on the Plan's website at any time?

Hoping someone can direct me to the governing regs themselves. Appreciate y'all!

I represent a multiemployer apprenticeship fund which leases office space from its building to a union appointing trustees to the fund. From my reading of the 2025 VFCP, it does not appear that the leasing of office space between the union and the fund is eligible for correction under VFCP. Does anyone think differently on this?

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An involuntarily terminated participant is demanding her former employer make up lost earnings on more than six years of "late deposits" of employee deferrals because they were not made within 7 business days of being withheld from her pay.  The former employee is also demanding that all similarly situated participants be "made whole," as well.

At https://www.irs.gov/retirement-plans/retirement-plans-faqs-regarding-simple-ira-plans, IRS says, "You must deposit employees' salary reduction contributions to their SIMPLE IRAs within 30 days after the end of the month in which the amounts would otherwise have been payable to the employees in cash, according to IRS rules. . . The Department of Labor rule for deposit of the salary reduction contributions may be stricter. They do have a 7-business day safe harbor rule."

The SIMPLE IRA Plan Sponsor Guide from the Capital Group similarly states, "For SIMPLE IRA plans, employee contributions must be remitted as soon as they can be reasonably segregated from company assets, but in no event later than 30 days after the last day of the month the contributions were withheld. For plans with fewer than 100 participants, employee contributions deposited no later than the 7th business day following withholding by the employer will be considered timely."

All deferrals were deposited within 30 days after the end of the month in which they were withheld, though at least arguably, the amounts might readily have been contributed within 7 business days.  Is the employer at risk of liability for lost earnings on amounts not deposited within 7 business days (or such longer permissible time by which it would have been practicable to do so)?

This former employee appears determined to hold the employer "accountable" and has threatened to have the Department of Labor investigate.  Might the employer also be liable for excise taxes or other penalties if it is determined that it could reasonably have deposited amounts earlier than it did?

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A participant who is above 59 1/2 years of age is seeking a distribution of excess deferrals (they paid $20,500 above the 402(g) limit) and attributable income ($2,452) to a ROTH 401k. The client made the contributions in 2022 to two separate employer plans, so neither plans were able to detect the over-contribution. Both are contributions were ROTH. The client is still employed by both employers and both allow in-service withdrawals. The participant caught the error and reported to both administrators and employers. 

How would you code the 1099-R?

1. Would you process this as a "normal" distribution (Code 7). The IRS instructions for forms 1099-R from 2025 states that "Use Code 7: (a) for a normal distribution from a plan, including a traditional IRA, section 401(k), or section 403(b) plan, if the employee/taxpayer is at least age 59 1/2..."

or 

2. would you use code 8—Excess contributions plus earnings/excess deferrals (and/or earnings) taxable in 2025. (this information is Instructions for Forms 1099-R and 5498 (2025). It states "Use Code 8 for a corrective IRA distribution under section 408(d)(4), unless Code P applies. Also, use this code for corrective distributions of excess deferrals, excess contributions, and excess aggregate contributions, unless Code P applies. See Corrective Distributions, earlier, and IRA Revocation or Account Closure, earlier, for more information."

or is there some other coding of the 1099-R?

Thanks!

I’ve been reading through the final SECURE 2.0 Roth catch-up regs and trying to picture what this actually looks like in real life starting in 2026.

On paper it’s simple: prior-year wages over the threshold → catch-ups must be Roth.

In practice, it feels like this touches a lot of systems that don’t talk cleanly:
payroll → prior-year wage history → contribution coding → plan admin → audits → corrections.

Curious how people think this will go.

Where do we expect the biggest problems?

• payroll pulling the wrong wage data
• employers mis-certifying eligibility
• misclassified catch-ups getting deposited
• cleanup/corrections later
• audit documentation
• something else?

And realistically — who ends up dealing with the mess when it happens? 

I didn't see a date - has anyone heard anything from recordkeeping platforms? I'm just assuming we use the new ones (modified if we feel like it) as reasonably possible.

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