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Posted

Hi

As not being a DC person and dealing with very few DC plans, I have a really stupid question as I could not find anything on it.

Owner only plan, owner (over 50 years old) makes 50k in w-2 and makes full deferral plus catch up.

They are required to have Roth catch up, correct?

The plan also needs to be amended to provide Roth deferrals/catch up as well by 1/1/2026, correct?

Sorry if this was asked before.

Posted

Jakyasar seems to describe a situation in which, at least for 2026, no participant will be constrained to make age-based catch-up contributions as Roth contributions because no participant will have had 2025 Social Security wages more than $150,000.

BenefitsLink mavens, if the plan sponsor is confident no participant will be § 414(v)(7)-constrained to make catch-up deferrals only as Roth contributions, do you think it’s safe for such a plan sponsor to omit a Roth-contribution provision?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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