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Free Publications
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Correcting Overpayments in Defined Contribution Plans After SECURE 2.0
Ferenczy Benefits Law Center 
[Guidance Overview] Mar. 17, 2026 "[The IRS] has specific language and procedures to correct plan errors ... [R]efunds distributed to HCEs [in error] are considered 'overpayments,' that is, amounts paid to participants that should not have been.... In general, the IRS's correction rules require the Plan to request that participants repay the overpayment.... However, the SECURE 2.0 Act made fixing this problem easier if the overpayment is an 'inadvertent benefit overpayment' or 'IBO'." MORE >> |
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