"A sole prop established a solo 401k plan in 2023, wants to include after-tax employee contributions and do the mega-backdoor Roth with it. [1] do the after-tax contributions have to be deposited by 12/31/2023? [2] Does the Roth conversion have to be done by 12/31/2023 as well in order to be applied towards the 2023 tax year?"

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"Starting to work my way through this. Welcome news that certain class exclusions can apply. But, they cannot be a proxy for for an age or service requirement. Consider the following: plan currently excludes interns. ALL interns work between 500 and 999 hours. My reading is that this exclusion would not be valid, and LTPT rights would need to be granted to interns that otherwise satisfy the LTPT age/service requirements. Agree/disagree? Now, if interns work various numbers of hours - some 500-999, some over 1,000, and interns are an excluded class, then it should be permissible to exclude them from LTPT requirements. Agree/disagree?"

"Plan has a few participants whose religion precludes them from investing in any of the plan's alternatives. There are several hundred active participants. What duty, if any, do the fiduciaries/trustees have to include a fund/funds that would be eligible under a haram/halal investing strategy? It is quite a niche corner of the investing world (at least here in the US), and funds can go from performing to underperforming quite rapidly quarter over quarter. Would the these participants have some sort of religious discrimination claim if these types of investments are not offered? Just on a fact-finding mission for now. I sent the plan sponsor to their attorney, but I'd like to get the community's take on this."

"Plan has different eligibility requirements for deferrals and safe harbor match. If a participant is eligible for deferrals, but not the safe harbor portion, must that participant receive a safe harbor notice? Generally the notice requirement is satisfied if notice is given to each employee eligible to participate, but I can't determine if that means eligible for safe harbor or for the plan in general."

"My understanding is that for a plan started before SECURE 2.0 (and therefore grandfathered in for not being required to have automatic enrollment if over 10 employees), if they add an automatic enrollment provision voluntarily, then LTPTEs are not subject to the automatic enrollment. I don't see anything in the proposed regs that counters this. Am I correct with this?"