"The calendar year end 403(b) plan in question is required to have the mandatory automatic enrollment provision as of 1/1/2025, as per SECURE. That is not in question. The question is how to correct a failure under EPCRS. The plan document did not include an automatic enrollment provision, and participants have not been automatically enrolled. There is no match contribution. A retroactive corrective amendment to add the provision, effective as of 1/1/2025 seems appropriate. And then analysis for a missed opportunity to defer -- specifically a failure to implement an automatic contribution feature. Does it then follow that the plan can rely on the on the reduced QNEC provided in Rev Proc 2021-30 Appendix A part .05(8)? ... This seems like an aggressive interpretation of the correction options but I am open to being swayed that it others think it is perfectly reasonable and not aggressive at all. What say all of you?"

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"Does anyone have a citation for the deadline to make an involuntary cash out of an account less than 7,000, other than that it has to happen after the participant was terminated? Not seeing any deadline requirements, wondering if a plan sponsor can theoretically let an account atrophy until it is eligible for cash out."

"These days, for the most part, new plans must have an auto-enrollment feature. But can the ER stop the auto enroll after a few years? Or must it be in there forever? Does SECURE address that?"

"The plan's eligibility conditions are age 21 and 1 year of service, with a monthly entry cycle. The rule of parity does not apply. Employee A was hired on 4/14/2022, terminated on 9/08/2022, and completed 590 hours. The employee was then rehired on 10/03/2023. If [employee had been] rehired 07/09/2023 what is the case of determining eligibility? In this situation, should eligibility be calculated from the original hire date or from the rehire date? Could someone also explain, with examples, how eligibility is determined for rehired employees who rehired within one year versus after one."