Pam Shoup

WCC - thank you for the clarification. Of course, the people that make these rules don't have to communicate all the nuances to plan sponsors/participants!

Jayasar, you are correct. 1. Highly Paid Individuals for 2026 are those that earned more than $150,000 (indexed) in 2025, based on FICA wages (Box 3 of W-2). It is a lookback provision. 2. Those without W-2 wages (i.e. sole props, partners) are currently exempt from having to make catch-up as Roth. 3. Roth provisions must be in place before the first Roth contribution. The timing of the Roth catchup contribution is irrelevant. The first Roth dollar deposited can be counted as Roth catchup. The participant does not need to exceed the 402(g) limit for the contribution to be counted as catch-up. 4. One note of caution if you have HPIs that solely earn W-2 and are not HCEs: if the plan does not permit Roth and the HCEs get to make catchups (pre tax) because they don't earn W-2, but the HPIs are prevented from catchups, then you have a benefits, rights and feature issue. In your example, since owner makes $50k in W-3 income, they are not subject to the Roth Catchup requirement.

I agree with David that you should ask for it. But in my experience, we rarely receive it from other providers. I recommend that you require all participants to re-enter their beneficiary data and remind them several times a year to update their beneficiaries. In the case we do receive beneficiary information from a provider, we keep the data on file. In the rare instance that someone passes away without a beneficiary, we look to the old file to see if anything is listed there.

I would add that reporting the correct participant counts is important. I have had some takeover plans where the counts on the 5500 were just under 120 to avoid the audit requirements when our review shows that the number of participants at EOY should definitely have been higher than what was reported.

Let me add one more thing, does the plan's 404a-5 notice disclose to the participants that the forfeitures will be used to pay plan expenses?

You should be able to do this via a Merger and Transfer Agreement whereby you merge and transfer the assets from the PEP to the stand alone plan. The PEP will report on its 5500 the transfer out, listing the name of the stand alone plan, the EIN and the Plan Number. You will need to review for anti-cutback issues, etc. Your plan document provider should have a model M&T available. The current PEP may also have a model you may be able to use. The stand alone plan will list the transfer in from the PEP on its 5500. The same would apply if you are going from PEP to PEP. A M&T will need to be prepared. I am not sure why this would be a mid year plan issue and why the PEP/RK would not permit the transfer out from a plan document or recordkeeping perspective, unless there was some agreement that it could only be done at PYE.

With the new Roth Catchup Rules for Highly Paid Individuals starting next year, I am trying to make sure that I understand the Rules for recharacterization. I understand that one of the methods for recharacterization is In Plan Roth Rollovers (if completed timely and the plan permits). My question is this: If a participant is under age 59.5, would this be done as an In Plan Roth Transfer and the 5-year recapture rule apply?

We agree with the answers above. We use ERISApedia as that meets our needs for most day to day research. For the super technical questions, we subscribe to the ERISApedia service where we can ask X number of technical questions per year and get a very detailed response. We have been looking at the AI and are thinking about it. We also like their (free) continuing education webinars, especially for our QKA/QPA and ERPA personnel as they are on a little higher level than classes we can take elsewhere. This saves us a lot of money in paying for CE credits for our credentialed personnel. We have also not had any issues with their classes meeting the ERPA requirements.

We use LifeStatus 360 for small jobs. You get results almost immediately and they reasonably priced. They also perform death index searches and obituary searches.

I agree with Ernie G and Peter Gulia. The Plan Administrator role is much more than just signing the Form 5500. The Plan Administrator is legally responsible and liable for the operation of the plan and is a fiduciary to the plan. If there were to be an IRS or DOL audit or review, the PA is the one who would be the hot seat, so to speak. Anyone who is taking on this role should be aware of their fiduciary responsibilities. Most service providers in our industry do not take on a fiduciary role with the plan and instead perform ministerial functions at the direction of the fiduciary. There are service providers who will take on the PA role and that will be clearly defined in any service agreement and most likely in the plan document. As far as other things that need to be done to change the Plan Administrator, I would look at your Plan Document and previous 5500s to determine if the company is named or an individual is named. You may need a change to the document and/or SPD. If an individual is named in the Plan Document and/or on previous 5500 forms, you may also need to file Form 8822-B with the IRS. As always, checking board minutes, etc. is always advisable. There should be something official that says who is authorized to act on behalf of the plan. These can become really important in the event of a fiduciary breach and any fidelity bond/fiduciary liability insurance the plan may have.

In the new FIS Retirement Platform (FRP), there will be no Crystal Reports. They are switching to ThoughtSpot. FIS is also anticipating that we will be writing APIs to get data out of the system into usable reports. If you are a Chief Technology Officer or someone who will be in the decision making chair for future software needs, you may want to check out www.rtug.org. This is a Recordkeeping Technology User's Group. This is a high level group of people well versed in IT and is not meant for the common Relius user. This group is currently exploring all options available.

Datair, FT Williams and ASC do not have a recordkeeping platform, so they won't be of any help for your recordkeeping needs. We used to do the plan testing in Datair and the recordkeeping in Relius. However, that got cost prohibitive and we ended up moving everything to Relius. No matter what we do as recordkeepers, it is going to get a lot more expensive to stay in this industry as an independent recordkeeper in the next few years.

The two major competitors that I know of are SS&C and Congruent for recordkeeping software. I would be interested to know if anyone knows of any other competitors.

I don't know if FIS knows the answer to that question. I recently attended a conference with the architects of FRP and they weren't even sure when the DC compliance piece was going to be added to FRP. The first generation of the software will have the recordkeeping only piece.

I recommend that you look at RVUG.org. This is a group that primarily uses Relius for recordkeeping. I would at least sign up as a free user. You will receive invitations to seminars about using Relius that are either free or low cost (something like $25 for the webinar). If you do a paid membership, you can access more information and ask questions, etc. To answer your question directly, every firm that I have spoken to uses Relius tools differently, with some using them extensively and some firms building tools outside of Relius to do a lot of tracking, etc. Please keep in mind that Relius will be sunsetting in the next few years and will be replaced by the FIS Retirement Platform (FRP). This takes the current FIS Omni software and adds some of the features in Relius to Omni. The decision makers at your company should be looking into the new platform and making some decisions about if you will migrate to that software or use a competitor and when you would be making the switch. It is not too early for them to start their decision-making process about the new software.