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Everything posted by Lois Baker
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Cross-reference between ERISA and the U.S. Code can be found here.
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Might find something useful here as well: https://benefitslink.com/research.html
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"Oldie but Goodie": The Inte-Greater The IRS Checklist for Permitted Disparity (Publication 4962) describes the formulas in some detail.
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DM = "direct message", some folks use "PM" = "private message" Click on the individual's user name in any post or reply; you'll land on their profile. To the right of their username (usually about mid-screen), you should see a blue button that says "Message" -- click on that, and you'll be able to send them a private message. If/when they reply, you should see a notification -- look to the top right of the page; to the left of your user name, you'll see an envelope. A badge should appear there if you have any unread messages. You can set your profile to receive an email whenever a DM is sent to you: Click on your user name (top right) => Account Settings => Notifications (at the right, on the "Overview" tab)
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Deja Vu on the Wayback Machine!
Lois Baker replied to CuseFan's topic in Computers and Other Technology
One of the really nice things about the Wayback Machine is that it automatically scrapes pretty much all of the federal government websites, all pages, all the time. It also automatically scrapes a whole host of other websites, somewhat regularly (i.e., not necessarily every day). Wayback also offers an API for automated bulk archiving and retrieval. And of course, individual pages can be submitted/archived by anyone with web access. And most of the archived pages/sites are functional - meaning most of the links on archived pages themselves connect to archived copies of those linked pages. There are other archives (in addition to perma.cc, there's archive.today), but AFAIK, web.archive.org is the only one that is working to save basically functional websites (not just individual pages), and without human intervention. And it goes back ... forever (in internet terms). Here's 12/10/1997 ... 11/2/1996 ... and 10/30/1996. (In addition to the Wayback Machine, the Internet Archive provides a repository of text, music, software and more -- it's a real treasure.) -
SECURE 2.0 Roth treatment of catch-up contributions
Lois Baker replied to youngbenefitslawyer's topic in 401(k) Plans
IRS Notice 2024-80: "The Roth catch-up wage threshold for 2024, which under section 414(v)(7)(A) is used to determine whether an individual’s catch-up contributions to an applicable employer plan (other than a plan described in section 408(k) or (p)) for 2025 must be designated Roth contributions, remains $145,000." https://www.irs.gov/pub/irs-drop/n-24-80.pdf -
As of this morning, it appears HHS has removed nearly all of the Section 1557 subregulatory guidance (FAQs and Fact Sheets). Entries still appear in search results on the HHS website (as of noon-ish on Feb. 5), but the content itself is gone. (Also see the link here to OCR's Section 1557 section -- it's broken.) Archived copies should generally be available at web.archive.org (although I didn't check for each and every missing page), but it does appear that the current guidance/enforcement may be changing.
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Unfortunately, that series was discontinued in 2017, at the request of the author. The WaybackMachine does have archived content, dating from 2001 through 2017. (Obviously, that doesn't reflect any legislative or regulatory developments since then.) If you're not familiar with the WaybackMachine, it's an incredible resource maintained by a non-profit organization that has preserved not only web pages but other digital content for many years.
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RMD Rollover Timing
Lois Baker replied to Gilmore's topic in Distributions and Loans, Other than QDROs
Recent article that may (or may not) provide useful info for this specific situation: https://irahelp.com/slottreport/the-qcd-dance/ -
Consider also the timing: the next 2 weeks are holiday weeks (meaning very little gets done in a normal year), and this is the end of an administration (meaning little regulatory/guidance work would be issued over the next month -- or more). Last shutdown was December 22 2018 - January 25, 2019 -- maybe somebody knows what happened then?
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EBSA opens voluntary "Retirement Savings Lost and Found" database for submissions - First submissions should be made as soon as possible before December 29, 2024, and updated at least annually thereafter. Links to the Official RFI and Fact Sheet included in a just-issued BenefitsLink Newsletter Bulletin. (Those links will be updated when the RFI is published in the Federal Register.)
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adjustable loan interest rate
Lois Baker replied to jeff mandell's topic in Retirement Plans in General
Duplicate post -- see ` -
Change in Sponsor's Business Arrangement
Lois Baker replied to J Simmons's topic in Cross-Tested Plans
Duplicate post -- see this thread. -
2025 Retirement Plan Limits released by IRS
Lois Baker posted a topic in Retirement Plans in General
IRS Notice 2024-80 401(k) deferral limit increases to $23,500 415 limit for DC plans increases to $70,000 HCE threshold increases to $160,000; Key employee at $230,000 401(a)(17) limit increases to $350,000 -
Sounds like you're looking for some actual "hands on" experience/recommendations; for generic "how to" issues, here are a couple of articles that may (or may not) be of help: Breaking Up Is Hard to Do: Exiting a Retirement Plan MEP or PEP Getting Out of a MEP/PEO/PEP Is Not as Easy as You Might Think
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Secure Act 2 amendments: must stay in plan?
Lois Baker replied to BG5150's topic in Retirement Plans in General
I'll admit, I haven't kept up with all of the fine print in the IRS regs ... but would it be permissible for the amendment to name a specific disaster? or limit distributions to a specific time frame? That way it's self-limiting from the outset -- and if the employer later decides to be more generous (e.g., add another disaster, or remove that limitation entirely), there's no cutback issue. Not sure any of that would be possible in a prototype plan, though ... -
Helene - BenefitsLink is ok, others are not
Lois Baker replied to Lois Baker's topic in Humor, Inspiration, Miscellaneous
Thank you so much -- this area needs all the help we can get. More info is coming out, and it just looks worse and worse; the toll both in lives and in economic loss is going to be staggering. Samaritan's Purse is on the ground -- distributing food and water, setting up field hospitals, etc. Operation Airdrop has been in the air for two days -- helicopter is the only way to get to many locations The Y'all Squad -- they're buying and installing portable StarLink units; communication (even among first responders) is the biggest struggle right now. -
Many of you know that BenefitsLink is headquartered in the mountains of North Carolina. Thankfully, we're safe and sound, albeit without cell service and primary internet (thank goodness for StarLink!). Many around us are not. We know that Florida and Georgia experienced significant damage. The mountains of North Carolina and Tennessee took a devastating hit. Over 2' of rain fell in a large swath of the NC mountains; the runoff put rivers at historic flood levels. Power, cell and internet service are all down over a large area, roads are collapsed or otherwise impassable, and many homes and small towns are completely isolated -- or washed away. Two of the four interstate routes in/out of Asheville -- the two that cross the mountains to the west -- have washed out; a third route (to the east) is blocked in several places. The damage is almost unbelievable -- and the affected area is almost the size of Massachusetts. This area is not equipped or prepared for this level of catastrophic destruction. Mountain people are self-reliant survivors, both individually and collectively, but this will be quite a stretch. It will be a long, difficult road forward. Please keep all in this area in your thoughts and prayers. And if any of our BenefitsLink neighbors have been affected, please reach out on this thread - we'll do what we can to help. Lois and Dave
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Voluntary Benefits - what constitutes consideration?
Lois Baker replied to tsrl01's topic in Miscellaneous Kinds of Benefits
Duplicate -- see -
Estimated inflation adjustments for 2025 limits?
Lois Baker replied to Peter Gulia's topic in 401(k) Plans
Here are Mercer's projections. -
Estimated inflation adjustments for 2025 limits?
Lois Baker replied to Peter Gulia's topic in 401(k) Plans
Milliman has been publishing estimates throughout this year; most recent update was issued August 15. -
RMD Final and Proposed Regs
Lois Baker replied to Paul I's topic in Distributions and Loans, Other than QDROs
Links to both final and proposed regs available here. -
Distribution from plan to employer first then participant???
Lois Baker replied to kmhaab's topic in 401(k) Plans
"Direct rollover" caught my eye -- doesn't that mean the employee wanted the funds to go straight from the plan to an IRA account? Did the letter include information about the employee's recipient IRA? or did the employee at least ask for a rollover account to be established at Fidelity? If any of that language was included, how did Fidelity issue payment to the employer in the first place? -
Duplicate -- see
