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Consider Nonqualified Plans When Implementing New Roth Catch-Up Contribution Rules
Verrill Dana LLP 
[Guidance Overview] Oct. 2, 2025 "401(k) plan sponsors who also maintain a nonqualified deferred compensation plan [should] ... [1] Determine how the Roth catch-up requirement will be implemented.... [2] Review the terms of any nonqualified plans and assess whether the answers to item 1 above will affect the plans.... [3] Implement plan amendments and administrative procedures that ensure compliance by the 401(k) plan under Code Section 414(v)(7) and the nonqualified plans under Code Section 409A." MORE >> |
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