"To help customers apply Section 414(v)(7)'s constraint that a higher-wage participant's age-based catch-up deferral must be Roth contributions, recordkeepers are asking an employer to deliver -- in January, following W-2 files -- a computer file that shows, yes-or-no or on-or-off, whether a participant had in the preceding year Social Security wages more than $150,000. Everything I've heard so far suggests this is the mainstream method recordkeepers are doing. Is there any big recordkeeper not doing this?"

"Found a r/k who posts deferral transactions before the check date. Basically, they process the contribution file when it comes in. For example, they processed the 5/9/25 payroll on 5/8/25. I didn't think they could/should do that, but they said it was ok. Do you agree?"

"Is there a particular advantage to signing a new Cash Balance Plan for the current plan year by end of the plan year, typically 12/31. Or is it just as well to wait until prior to the tax filing deadline of the next year and signing retroactively?"

"A 401(k) participant requested a hardship under 1.401(k)-1(d)(3)(ii)(B)(6), relating to the 'repair' of the participant's principal residence, for costs associated with the removal of a tree that posed a danger of falling on the participant's residence (but had not actually fallen yet). From a practical, policy perspective, I understand that it makes sense for the participant to take the tree down before it actually falls on the house. However, I don't think this would qualify as a casualty loss under 165, and therefore wouldn't qualify as a 'repair' eligible for hardship. (See, e.g., Rev. Rul. 76-134.) Do you all agree? Other thoughts? (As an aside, I realize that SECURE 2.0 permits self-certification, but in this case the participant volunteered the information, so the plan sponsor has actual knowledge.)"

"Our firm has a lot of owner only so we tend to have a lot of mega Roth conversions. I can't seem to find a definitive answer on what the limit is when the plan is ONLY doing after tax -> Roth. I've read a lot of places that if you are 50 and over, then the limit is $77,500 for 2025 but the examples always include deferrals/Roth. What about when it's solely after tax? I read an AI response that said if it's only after tax, then the limit is just $70,000 because after tax is not subject to 402(g):

• Elective deferrals = pre-tax 401(k) deferrals + Roth 401(k) deferrals (salary-reduction contributions subject to the 402(g) limit).
• After-tax (non-Roth) contributions = a different bucket under Section 415(c), not subject to 402(g), and not elective deferrals."

"Can someone point me to annual participant notice requirements for 457(b) and 457(f) requirements?"

"A plan came on with us earlier this year, this is our first time doing testing for them. Owner wants a projection of what it'd look like to max out profit sharing with new comp (they've never done profit sharing before). Right now their plan doc has 3 month wait, no hours or age requirement, and monthly entry for all sources, including safe harbor. Owner has two kids, 12 and 14, which get a small paycheck, defer some, and get safe harbor money. This causes some wild numbers in 401(a)(4) testing because of their age; the $330 of safe harbor received by one kid means I'd need to get 5 NHCEs up to ~27 EBAR. Essentially, there's no way to max out the owner without giving wild contributions to everyone else because of those two kids. Our plan is to amend their document for next year to either have an age requirement or exclude HCEs from the safe harbor contribution, along with some allocation conditions and other small provision changes to make this much smoother next year. That said, is there anything at all we can do for this year to make this spread better? I've seen conflicting information about the use of statutory exclusions for 401(a) rate group testing & struggling a bit to wrap my head around if there's any way we can make this work."