Mandatory Roth Catch-up for SE comp, W-2 combo

[ejohnke]

I just want to make sure I am understanding the rule correctly.

Facts:

• Plan doesn't currently allow Roth deferrals
• Owners have SE Income
• 2 owners are 50+ and will defer up to their catch-up limit
• Employees have W-2 wages
• No employees are 50+
• No employees have FICA wages greater than $150,000

They are possibly moving from brokerage accounts to a Platform in 2026, and will likely add Roth deferrals at that time. They would prefer to no allow Roth until they are at a platform because they will have even more accounts to move. 

This Plan is not required to add Roth deferrals NOR remove Catch-up contributions right now because they don't have anyone that the Mandatory Roth Catch-up applies to, correct?

[Belgarath]

Agree.

See Peter's point below. I assumed not 50 by EOY, and you know what assuming can do...

 

[Peter Gulia]

A caution for others who might do one or both sorts for who might be § 414(v)(7)-affected:

An employee who’s 49 at the beginning of a year might turn 50 by the end of the year.