"[B]ecause Roth contributions are not needed even for [highly-paid individuals (HPIs)] during the Administrative Transition Period, a plan will be treated as complying with Code section 414(v)(7)(B) even if the plan permits HPIs to make pre-tax catch-up contributions and continues not to offer Roth deferrals to anyone.... If Roth does not need to be implemented until 2026 in relation to catch-up contributions by HPIs, the amendment can be delayed until then, as well.  ... The IRS did clarify its intent at some nebulous future date to release further guidance on the relevant open issues[.]"  MORE >>

"Notice 2023-62 also outlines guidance that the IRS intends to issue (subject to comment) regarding implementation of the Roth catch-up requirement ... [1] Roth catch-up requirement does not apply to participants with non-FICA wages ... [2] 'Deemed' Roth elections permissible for catch-up contributions ... [3] Plans maintained by more than one employer not required to aggregate wages from multiple participating employers when applying the Roth catch-up contribution requirement:"  MORE >>

"[IRS Notice 2023-62] provided a two-year administrative transition period: through December 31, 2025. During this transition period, plans may continue to allow pre-tax catch-up contributions by High-Paid Participants and plans that do not have Roth features may continue to allow catch-up contributions.... The IRS provided a preview of 'expected' future guidance[.]"  MORE >>

"[IRS Notice 2023-62] specifically invites comments and suggestions on whether a plan that offers Roth catch-up contributions in order to comply, but not the ability to make Roth contributions generally, violates the provisions of the Code requiring that all eligible participants must be allowed to make the same election regarding catch-up contributions, or whether restricting catch-up contributions to only those participants whose prior year earnings do not exceed $145,000 is permissible."  MORE >>

"The IRS confirmed that the issue was a programming glitch, which it fixed on Wednesday. However, it emphasized that Form 8955-SSA is filed with the IRS through the FIRE (Filing Information Returns Electronically) system, not the EFAST system. 'The concern is that if a Form 8955-SSA is filed with EFAST, the form is not considered filed with the IRS, and the taxpayer will receive a penalty notice [as a result],' the IRS said. 'EFAST, therefore, can't be used to file a Form 8955-SSA.' "  MORE >>

"While it won't be official until sometime in mid-to-late October, it's looking more and more like the 2024 401(k) contribution limit will receive a $500 boost to $23,000 from the $22,500 limit in 2023 ... Mercer's forecast aligns with Milliman's most recent 2024 IRS limits forecast, which also predicts that the 2024 maximum contribution for 401(k), 403(b), and 457 defined contribution plans will rise by $500 to $23,000, and catch-up contribution limits will remain the same."  MORE >>

"The average price for U.S. houses sold during the second quarter was nearly $500,000 -- that, coupled with the highest mortgage interest rates in over 20 years, could make a 401(k) loan appealing for buyers.... Having a loan means that the assets are out of the market, potentially hurting returns that would benefit from years of compounding. Further, most plans require 401(k) loans to be repaid in full when an employee leaves a company -- and that can trigger taxes and penalties for borrowers who don't have the money to do so."  MORE >>

"This detailed set of Frequently Asked Questions, fully updated for 2023, addresses the workplace-related issues facing employers in the wake of hurricane-related disasters. In addition to legal obligations you need to consider, this Insight also addresses the practical questions that most often arise both while preparing and in the aftermath of storms."  MORE >>

"Looking ahead over the next two years, employers are focused on shaping a more competitive benefit portfolio that meets their employees' diverse needs across a range of areas: Financial wellbeing/short-term finances comes in first. Approximately four in 10 employers globally (39%) and in North America (41%) ... indicate this is the benefit area where they most want to improve their market position ... Additionally, roughly three in 10 respondents globally (31%) and across most regions indicated they were looking to improve their position in retirement plan/long-term finances."  MORE >>