"I have a client that has failed to implement participant deferrals into a state 457(b) plan that the employer participates in. My understanding is that, since there is limited opportunity to submit corrections to the IRS under Section 4.09 of EPCRS, and Reg 1.457-9 provides that governmental entities have until the first day of the plan year that begins more than 180 days after the IRS notifies them of the failure to correct their plan failures, practitioners interpret that to mean that corrections for 457(b) plans can generally follow those prescribed under EPCRS for qualified plans. So in this case we would corrective contributions for the participant's missed opportunity to make a contribution/invest (e.g., 50% of missed deferral) as under EPCRS. Is that understanding correct?"

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"Do the plan sponsors who adopt a PEP also need to carry their own ERISA Bond ?"

"For any of you TPAs who also do in-house recordkeeping, what software do you use to manage client onboarding? I am currently researching project management systems that include a client portal (for the new client to complete and return forms, for the advisor to upload their investment menu, etc.). Any ideas?"

"Any thoughts on if it is permissible to change the definition of disability in a DC plan, or would the definition of disability be considered a protected benefit subject to the anti-cutback rules? Does the answer change if the definition of disability is used as a distribution trigger or to provide for immediate vesting? I am aware that it's not uncommon for DC plans to be amended to change the definition of disability (ex. back in 2018 when the DOL issued the claims procedure regs requiring retirement plans to require adding disability claims procedures if the disability definition included some discretion) but have not been able to iron out whether this type of change is subject to the cutback rules."

"Are Davis Bacon contributions considered employer contributions to a plan and if so, would they count towards the 25% deductible employer contribution limit? I assume they count towards an employee's 415 limit."