"I have an auditor asking for part-time hours starting in 2021, however this plan started 1/1/2023. Am I right in thinking that hours prior to 1/1/2023 shouldn't be applied?"

"Unfortunately, we're getting closer to the 1/1/26 buzzsaw of required Roth catchups for the Highly Paid Individuals (or High Earners, whatever). I get that it's allowed to not make these participants complete a new deferral election form if they have elected pre-tax deferrals -- the plan sponsor has the authority to cut them off at the base limit and then take any additional deductions as Roth. And for especially large plans, that might be the most practical method. But what about smaller plans? Does it 'feel' better to allow the participant to sign off on something, or is just a note telling someone 'hey, this is what's going to happen' sufficient?"

"I am working with a client with a defined benefit plan for collectively bargained employees. The overwhelming majority of the participants are male. The plan uses the RP-2014 blue collar male table for actuarial equivalence for participants and the RP-2014 blue collar female table for beneficiaries. In 1983, the US Supreme Court decided Arizona Governing Committee v. Norris, which held that the use of sec-based tables violated Title VII of the Civil Rights Act. Has anything developed which has changed this result in the interim? Or can this be justified by using a table for a single gender for all participants, regardless of actual gender?"

"We are a small TPA firm with about 80 plans but are definitely in a growth mode. We service only DC plans. We still have a portion of our plans as trustee-directed balance forward plans, but those are becoming less prevalent.... We do not do any daily val recordkeeping, so there is no need for the functionality of the VRU, trading, etc.... Currently, we use Relius Administration, Relius Web Client and Relius Documents. We don't have any proposal or portal software at this point.... Any insight of people who have converted to one of these other options would really be appreciated. I'd love a dialogue on this stuff and I feel like there are lots of us out here facing the same challenges with Relius."

"Say in 2025 a participant under age 50 defers $23,500, receives a non-SH match of $11,750 (match formula of 50% of all employee deferrals), and receives a PS contribution of $40,000 for a total of $75,250 and a 415 excess allocation of $5,250. Under EPCRS Section 6.06, the reduction would come first from unmatched deferrals (none as 50% of all deferrals are matched) and then from matched deferrals and the corresponding match. In that scenario, is the correction:

1. Refund $3,500 of matched deferrals to the participant, and [2] transfer $1,750 of matching contributions to the plan's unallocated account; or
2. Refund $5,250 of matched deferrals to the participant, and [2] transfer $5,250 of matching contributions to the plan's unallocated account?

In other words, does the 'corresponding match' also count toward the 415 reduction (as in the first scenario)?"

"Employee made elective contributions in 2018 and 2019. He should have been paid in 2021, but was not -- it is too old to correct under the correction procedures (Notice 2008-113). So we definitely have an uncorrectable error. The employer is not interested in ignoring it and hoping it never gets discovered -- they want to fix it now. I know we have to report it as a 409A violation and there will be a 20% excise tax. But do we have to go back and report these as if the contributions were actually paid in 2018 and 2019? Can we even go back that far? To make matters worse, the participant also has older contributions (going all the way back to 2001) -- how do we handle those? Can we just pay out everything now (2025), report it as a 409A payment, and pay the 20%? Do we have to go back and report the contributions as paid in the year the contributions were made?"