"Let's assume an individually designed governmental DB plan received a determination letter at some time in the dim and distant past. I believe post 2017, such a plan could no longer apply for a D-letter, absent a plan termination, merger, or some other unusual situation that I can't recall. Has that changed?"

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"Pre-SECURE, QACA default rate had to escalate to at least 6% of pay. After SECURE, starting in 2025, auto-enroll plans must escalate to at least 10% of pay. So must a new QACA plan for 2025 escalate to 10% of pay, or is 6% sufficient?"

"So anyone who is 61, 61, 62 or 63 as of 12/31/2025 can do the super catch-up for a total deferral of $34,750. Is it that simple? Anyone know why SECURE limited it to that odd age group?"

"2025's limits on some kinds of early-out distributions bear what to some might seem an incongruity: $1,000 for an emergency personal expense; $5,000 for a birth or adoption; $10,300 when one is a victim of domestic abuse; $22,000 if one had a loss from a federally declared qualified disaster. BenefitsLink neighbors, any observations?"

"I understand that the monthly threshold hours that an employee must work is fewer that 130 for purposes of an ALE avoiding the shared responsibility penalty for not offering that employee coverage. But what is the monthly threshold for full-time status to determine whether an employer is an ALE? 120 or 130? IRS Publication 5208 states that the threshold is 130 hours ... But, when asked this specific question in the 2014 JCEB Q/As, an IRS representative stated that the threshold was 120 ... Note that my reading of the statute indicates that it does not say 120 hours per month; it says 30 hours per week. I recognize that Publication 5208 is more authoritative than an IRS representative speaking for himself, but can anyone point to anything that specifically states the rule? Perhaps the IRS's thinking changed?"

"if a participant took a couple distributions and would like to increase the benefit formula to reach 415 limit in 2024: [1] Should we project the distribution amounts from the distribution dates to 12/31/2024 or simply use the actual distribution amounts? [2] Do you normally calculate the 415 lump sum (excluding the exiting distributions) first then back in the accrued benefit/ cash balance credit to reach max 415 lump sum? or do you convert the exiting distributions into accrued benefit then subtract it from the 415 limit? do you handle this differently between DB and CB plans? [3] Are there any guidance or regs that can answer these questions?"