"Sponsors should consider: [1] Engaging employee benefits counsel to draft plan language that is consistent with practice for use of forfeitures.... [2] Adopting procedures for the use of forfeitures that outline the intended compliance approach, consistent with the 2023 Proposed Regulations. [3] Reviewing service provider agreements and ensuring that forfeiture provisions are consistent with the adopted procedures. [4] Working with plan recordkeepers on adopting an approach to timely use accumulated forfeitures under the 2023 Proposed Regulations."

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