"I didn't see a date -- has anyone heard anything from recordkeeping platforms? I'm just assuming we use the new ones (modified if we feel like it) as reasonably possible."

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"I've been reading through the final SECURE 2.0 Roth catch-up regs and trying to picture what this actually looks like in real life starting in 2026. On paper it's simple: prior-year wages over the threshold: catch-ups must be Roth. In practice, it feels like this touches a lot of systems that don't talk cleanly: payroll -- prior-year wage history -- contribution coding -- plan admin -- audits -- corrections. Curious how people think this will go. Where do we expect the biggest problems? [1] payroll pulling the wrong wage data; [2] employers mis-certifying eligibility; [3] misclassified catch-ups getting deposited; [4] cleanup/corrections later; [5] audit documentation; [6] something else? And realistically -- who ends up dealing with the mess when it happens?"

"A participant who is above 59 1/2 years of age is seeking a distribution of excess deferrals (they paid $20,500 above the 402(g) limit) and attributable income ($2,452) to a ROTH 401k. The client made the contributions in 2022 to two separate employer plans, so neither plans were able to detect the over-contribution. Both contributions were ROTH. The client is still employed by both employers and both allow in-service withdrawals. The participant caught the error and reported to both administrators and employers.

"How would you code the 1099-R? [1] Would you process this as a 'normal' distribution (Code 7). The IRS instructions for forms 1099-R from 2025 states that 'Use Code 7: (a) for a normal distribution from a plan, including a traditional IRA, section 401(k), or section 403(b) plan, if the employee/taxpayer is at least age 59 1/2...' or [2] would you use code 8 -- Excess contributions plus earnings/excess deferrals (and/or earnings) taxable in 2025. (this information is Instructions for Forms 1099-R and 5498 (2025). It states 'Use Code 8 for a corrective IRA distribution under section 408(d)(4), unless Code P applies. Also, use this code for corrective distributions of excess deferrals, excess contributions, and excess aggregate contributions, unless Code P applies. See Corrective Distributions, earlier, and IRA Revocation or Account Closure, earlier, for more information.' or is there some other coding of the 1099-R?"

"An involuntarily terminated participant is demanding her former employer make up lost earnings on more than six years of 'late deposits' of employee deferrals because they were not made within 7 business days of being withheld from her pay. The former employee is also demanding that all similarly situated participants be 'made whole,' as well. IRS says, 'You must deposit employees' salary reduction contributions to their SIMPLE IRAs within 30 days after the end of the month in which the amounts would otherwise have been payable to the employees in cash, according to IRS rules.... The [DOL] rule for deposit of the salary reduction contributions may be stricter. They do have a 7-business day safe harbor rule.'

"The SIMPLE IRA Plan Sponsor Guide from the Capital Group similarly states, 'For SIMPLE IRA plans, employee contributions must be remitted as soon as they can be reasonably segregated from company assets, but in no event later than 30 days after the last day of the month the contributions were withheld. For plans with fewer than 100 participants, employee contributions deposited no later than the 7th business day following withholding by the employer will be considered timely.'

"All deferrals were deposited within 30 days after the end of the month in which they were withheld, though at least arguably, the amounts might readily have been contributed within 7 business days. Is the employer at risk of liability for lost earnings on amounts not deposited within 7 business days (or such longer permissible time by which it would have been practicable to do so)? This former employee appears determined to hold the employer 'accountable' and has threatened to have the [DOL] investigate. Might the employer also be liable for excise taxes or other penalties if it is determined that it could reasonably have deposited amounts earlier than it did?"