News Archive

With the shutdown ended, the [IRS] has finally issued Notice 2025-67, setting out the limits on benefits and contributions for 2026. Maximum deferrals under a 401(k) or 403(b) plan rose from $23,500 to $24,500, while maximum benefits under a defined benefit plan rose from $280,000 to $290,000. This page includes a chart showing details, and limits from 1996 to 2026.  MORE >>

The IRS has now released all of the 2026 benefit limits, including both the cafeteria and health plan limits as well as all of the qualified retirement plan limits. Earlier this year, IRS also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits. This chart shows all of these limits for 2025 and 2026.  MORE >>

• "Effective January 1, 2026, the limitation on the annual benefit under a defined benefit plan under section 415(b)(1)(A) of the Code is increased from $280,000 to $290,000....
• "The limitation under section 402(g)(1) on the exclusion for elective deferrals described in section 402(g)(3), which includes elective deferrals made to the Thrift Savings Plan, is increased from $23,500 to $24,500.
• "The limitation on deferrals under section 457(e)(15) concerning deferred compensation plans of state and local governments and tax-exempt organizations is increased from $23,500 to $24,500.
• "The limitation under section 414(v)(2)(B)(i) for catch-up contributions to an applicable employer plan other than a plan described in section 401(k)(11) or section 408(p) that generally applies for individuals aged 50 or over is increased from $7,500 to $8,000.
• "The limitation under section 414(v)(2)(E)(i) for catch-up contributions to an applicable employer plan other than a plan described in section 401(k)(11) or section 408(p) that applies for individuals who attain age 60, 61, 62, or 63 in 2026 remains $11,250.
• "The Roth catch-up wage threshold for 2025, which under section 414(v)(7)(A) is used to determine whether an individual's catch-up contributions to an applicable employer plan (other than a plan described in section 408(k) or (p)) for 2026 must be designated as Roth contributions, is increased from $145,000 to $150,000....
• "The threshold used in the definition of “highly compensated employee” under section 414(q)(1)(B) remains $160,000.
• "The threshold under section 416(i)(1)(A)(i) concerning the definition of “key employee” for top-heavy plan purposes is increased from $230,000 to $235,000.
• "The annual compensation limitation under sections 401(a)(17), 404(l), 408(k)(3)(C), and 408(k)(6)(D)(ii) is increased from $350,000 to $360,000. "

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10 pages. " The report identifies over 70 key milestones that shaped the emergence of today's U.S. PRT market....[PRT] refers to the process by which defined benefit plan sponsors reduce financial risk and administrative burden by transferring pension obligations. This process is typically facilitated through annuity purchases tied to plan terminations or retiree lift-outs, or through lump sum distributions offered to participants."  MORE >>

"[T]here appears to be a contingent of folks who believe, irrespective of asset activity during the year, that end of year assets should always be zero for funding and deduction purposes in the initial year. The other -- and in [the authors'] opinion the clearly proper -- answer is that assets reflect the fair market value of the plan assets, reduced by deposits made, such deposits adjusted with interest."  MORE >>

"[T]here have now been multiple court rulings on motions to dismiss [pension risk transfer] lawsuits with varying results. This article will discuss those rulings and analyze the issues faced by plan participants whose pensions have been transferred by their employers to annuity providers that utilize non-traditional capital structures."  MORE >>

PBGC table showing the present values applicable to benefits with annuity starting dates in 2026. A two-column spreadsheet version of the table is also available for convenient copying.   MORE >>

"During October, the PFI funded ratio improved for the seventh straight month, rising from 106.5% on September 30 to 107.1% as of October 31. Market gains of 1.27% drove this result.... During the month, the market value of plan assets rose to $1.328 trillion while the projected benefit obligation rose to $1.240 trillion."  MORE >>

17 pages. "[T]he PBGC's disavowal of federal protection for retirees after pension risk transfers was never authorized by Congress and conflicts with both the statute and the PBGC's own 1981 position. The authors trace the legal history, legislative intent, and policy implications demonstrating that the law already requires PBGC guarantees to continue even after pension benefits are annuitized. Their analysis calls on regulators and courts to restore this 'forgotten promise' to strengthen the integrity of the U.S. pension system."  MORE >>

"Every dismissal so far rests on one or more reversible errors. The most common: [1] Courts assume PRT annuities are safe -- contrary to market evidence ... [2] Courts misapply ERISA's burden of proof ... [3] Courts ignore prohibited transactions (the strongest claim) ... [4] Courts wrongly treat PBGC loss as irrelevant ... [5] Courts ignore offshore private-credit exposures inside insurer portfolios ... Judges have been asleep at the wheel. Appeals are not just warranted -- they are essential."  MORE >>

"An effective de-risking approach often involves collaboration among actuaries, annuity consultants and investment professionals to evaluate a plan sponsor's unique circumstances and goals.... Compared to siloed consulting models, an integrated methodology can lead to more efficient execution and better outcomes."  MORE >>

"The aggregate funded ratio for U.S. corporate pension plans is estimated to have increased by 1.4 percentage points in October, ending the month at 104.0% ... The aggregate funded ratio is estimated to have increased by 6.2% and 1.9% year-to-date and over the trailing twelve months, respectively."  MORE >>

"[F]ederal policies have real, measurable impacts on state and local budgets and public pensions. Plan sponsors should not look to contributions and benefits as the place to cut costs ... [P]ension funds receiving their full actuarially determined contribution ... reported funded ratios 20 percentage points higher than those that did not. Over time, this translates into substantial taxpayer savings and greater financial stability."  MORE >>

"Excess mortality for Americans aged 65 or older dropped from more than 20% at the peak of the COVID-19 pandemic to only 1.3% in the past year -- according to a new analysis from the Society of Actuaries Research Institute.... Spikes in mortality persisted through early 2022, driving up the overall average excess mortality for the year, the analysis said. However, since that time, U.S. population mortality rates have returned to levels more consistent with 2019, and have exhibited the seasonal pattern usually seen in the U.S."  MORE >>

"As a result of the indexing rules under federal law, the guarantee limits for single-employer plans that terminate in 2026 will be 4.82% higher than the limits that applied for 2025."  MORE >>

"Both the single-employer and multiemployer plan rates have increased. [A chart] shows the rates in effect for plan years beginning in 2024, 2025, and 2026."  MORE >>

"If the Supreme Court sides with the Second Circuit, ... withdrawal liability estimates requested by and provided to employers prior to their withdrawal will be more reliable estimates of the actual withdrawal liability.... If, however, the court sides with the D.C. Circuit ... withdrawal liability estimates will be arguably unreliable for purposes of estimating the actual withdrawal liability, making it more difficult to plan for withdrawal liability in the same manner as an employer does any other corporate liability." [M&K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund, No. 22-7157 (D.C. Cir Feb. 9, 2024; cert. pet. granted Jun. 30, 2025 No. 23-1209)]  MORE >>

"Stress testing and scenario analysis are essential tools for trustees and investment committees seeking to understand how pension plans will perform under adverse market conditions. These methodologies help quantify vulnerabilities, guide strategic decisions, and ensure that plans remain solvent and resilient, even during economic shocks.... As pension plans mature, the divergence between active participants and retirees becomes more pronounced -- not just demographically, but financially.... This structural imbalance demands a differentiated investment approach."  MORE >>

"Plans with higher Pension Protection Act funded percentages tend to be in the green zone, but that isn't always the case.... The median burn rate for C&D plans is more than twice that of red-zone plans. For SFA recipient plans, the median inactive-to-active ratio is much higher than for other plans, including C&D plans."  MORE >>

"23 states each had over $20 billion in unfunded pension liabilities at the end of the 2024 fiscal year ... Two states had more than $200 billion in public pension debt: California ($265 billion in unfunded pension liabilities) and Illinois ($201 billion). Two other states reported more than $90 billion in unfunded pension liabilities: Texas ($92.2 billion) and New Jersey ($92 billion)."  MORE >>

"A group of cases, all having been dismissed by district courts, are on appeal in the U.S. Courts of Appeal for the Sixth and Eleventh Circuits ... What remains at stake is whether sponsors may rely on legacy mortality tables and interest assumptions embedded in plan documents or whether, as plaintiffs contend, ERISA compels the use of reasonable and contemporary assumptions for the two forms of benefit have equal present value when payments begin."  MORE >>

PBGC has determined the premium rates applicable for plan years beginning in 2026 in accordance with the indexing rules provided in section 4006 of ERISA.  MORE >>

"The court held that the private equity fund was under 'common control' with the portfolio companies because it owned a 95% interest in them, and that the fund was a 'trade or business' under the standard set forth in Sun Capital I as a result of it actively managing the portfolio companies. The court declined, however, to hold the private equity fund's general partner or management company liable, concluding that under the standard set forth in Sun Capital II, they did not comprise a partnership-in-fact with the private equity fund or the withdrawing employers such that they could be deemed part of their controlled group." [Longroad Asset Management LLC v. Boilermaker-Blacksmith National Pension Trust, No. 23-0738 (W.D. Mo. Aug. 19, 2025)]  MORE >>

"Excess mortality rates have continued to decline since the peak of the pandemic, and emerging data through June 2025 suggests that there is still a small amount of excess mortality for the 65+ population."  MORE >>

"During September, the estimated cost to transfer retiree pension risk to an insurer in a competitive bidding process increased from 100.0% to 100.5% of a plan's accounting liabilities (accumulated benefit obligation, or ABO)."  MORE >>