"Does anyone know when the Cost of Living Adjustments will be officially announced? I have seen many projections but nothing from the IRS. Thank you."

"Suppose you take the approach that the 5,000 cash out limit will increase to 7,000 for 2024, unless the employer informs you otherwise. Is there any dispensation on the timing of including this in the safe harbor notice? Or, realistically, issue an updated one once it is truly 'known' as to whether or not, and exactly when, it is effective?"

"Can a plan have a younger RMD age than the age required by law? The RMD is age is the latest age at which a participant must begin taking distributions, but is there a reason a 401(k) plan couldn't use a younger age than required? Put another way, can a 401(k) plan require a participant that turns age 72 during 2023 to begin RMDs by 4/1/2024?"

"Administer a small defined benefit pension plan that is sponsored by a corporation. The first plan year was from 10/1/2022 -- 9/30/2023. The first plan year valuation was done on end of year basis. Their CPA changed the corporation year to December 31, 2023 from September 30, 2023. It makes sense to keep the September 30 plan year. However, we would need to change to a beginning of year. Is there automatic approval when switching from end of year to beginning of year?"

"So I have a plan sponsor come back to tell me that their plan excludes interns (which it does) and she is asking if the interns they have would be considered Long Term Part Time Employees. So this is a good question. These interns are W-2 employees. I would think that we cannot exclude interns, unless they work less than 500 hours per year in the look back years? I have no clue who they are or what hours they have worked, she only said 'we do exclude interns and our interns stay on forever....' Would interns fall under the 'long term part time employee' category, or can they still be excluded?"

"Can an ESOP contain a provision allowing the plan sponsor to elect in its sole discretion to diversify a portion of participants' accounts (as long as the diversification is nondiscriminatory and applies equally to HCEs and NHCEs) and buy back the shares? I have been unable to find any legal authority on this either way. Maybe I'm overthinking it? I'm aware of the authority on rebalancing participant accounts, but don't believe that would apply here, and most information on buy backs speaks to buying shares from terminated participant accounts only."

"Background 403(b)(9) non-electing church plan The employer did not send in May and June (2023) employee deferral contributions timely. The deferrals were deposited to the plan in mid-August 2023. Question I was looking through RP-2021-30, .05(9) that states: Safe harbor correction methods for Employee Elective Deferral Failures in Section 401(k) plans or Section 403(b) Plans. (a) Safe harbor correction method for Employee Elective Deferral Failures that do not exceed three months. Under this safe harbor correction method, an Employee Elective Deferral Failure (as defined in section .05(10)) can be corrected without a QNEC for missed elective deferrals.... [if the stated conditions are satisfied] Are late deferrals that were deducted but not sent timely to the plan included in .05(10)? I did not notice them explicitly mentioned so I thought I would tap into the wisdom abound on this site! : D It will be a sizeable correction if there is a need to adjust for earnings, so I want to be sure there is not a safe harbor 'out' before the process is started. TIA"

"I'm taking over a client and they are looking to terminate their existing, traditional Defined Benefit Plan to instead utilize a Cash Balance Plan moving forward. I know the limits are lifetime limits, etc. The question is, are they allowed to terminate one and open the new CB Plan within the same year?"