Barbara Posted October 11, 2023 Posted October 11, 2023 I have a cross-tested profit sharing plan where the client is considering adding a Safe Harbor 401(k) feature for 2024. Will auto enrollment features be required?
CuseFan Posted October 11, 2023 Posted October 11, 2023 that is my understanding Bill Presson 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Peter Gulia Posted October 11, 2023 Posted October 11, 2023 Although Internal Revenue Code § 414A(a)(1) generally (with some exceptions) applies to a § 401(k) arrangement established on or after December 29, 2022, a plan need not provide an automatic-contribution arrangement until the first plan year that begins on or after January 1, 2025. Some plan sponsors might consider it awkward to omit an automatic-contribution arrangement for 2024, recognizing a need to add automatic for 2025. But others might prefer administering the first year of a new § 401(k) arrangement without the extra complexity of automatic. Luke Bailey 1 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
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