"A 403(b) plan received two rollover checks from a 401(k) on behalf of a participant age 74. Check #1: Pre-tax deferrals ($4,915) Check #2: Non-Qualified Roth basis ($10,447) with earnings ($590) [First Roth contribution = 2024] The 403(b) was informed that the participant's 2025 RMD for the 401(k) was not distributed to him prior to the rollover. The participant is not eligible to make regular contributions to the 403(b). The 403(b) has not cashed the checks yet because it does not want to deposit ineligible amounts. It is wondering if it can return the checks to the 401(k). What is the cleanest way to correct this?"

"With the passing of these laws, clients have many new options to consider and implement. Does anyone know of the required employee communications regarding these? For example if a client wanted to implement the domestic abuse distributions would this need to be communicated to all staff?"

"Can someone please confirm that employer contributions to a nonqualified plan are subject to FICA taxes at the time they vest? We recently found out our payroll isn't applying FICA taxes to our employer contributions to our NQDC Plan (in our plan employer contributions are always 100% vested). They claim this is correct, so I'm second guessing myself. My understanding is FICA taxes must be paid under the 'special timing rule' when contributions to a NQDC Plan vest, even employer contributions. If they aren't applying FICA upon contribution (or, if later, vesting) we'll have to apply FICA to the employer contribution part of the distribution later, correct?"