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Retirement Plans Newsletter

January 8, 2024

4 New Job Opportunities 4 New Job Opportunities


[Official Guidance]

Text of PBGC Comprehensive Premium Filing Instructions for 2024 Plan Years (PDF)

68 pages. "What's New: The filing requirements for 2024 are almost identical to the filing requirements for 2023.... [K]ey changes to note for 2024 ... [1] Single-employer plans other than CSEC plans: The Flat-rate Premium is $101 per-participant, up from $96; The cap on the Variable-rate Premium is $686 per person, up from $652.... [2] Multiemployer Plans: The Flat-rate Premium is $37 per-participant, up from $35.... [3] The Premium Customer Service email address has changed from to Emails sent to the old address will be forwarded to the new mailbox."  MORE >>

Pension Benefit Guaranty Corporation [PBGC]


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[Official Guidance]

Draft Instructions for 2023 IRS Form 8606: Nondeductible IRAs (PDF)

16 pages; Jan. 5, 2024. "What's New: [1] SEP IRAs and SIMPLE IRAs ... [2] References to 2023 Form 8915-F ... [3] Certain corrective distributions not subject to 10% early distribution tax.... [4] Coronavirus-related distributions ... [5] Modified AGI limit for Roth IRA contributions increased.... [6] Due date for contributions."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

Everything You Need to Know About The Vermont Saves Program

"The VT Saves plan will be phased in starting mid-year 2025. Covered employers must auto-enroll their employees into the program. The phase-in dates are as follows: ... 25 or more employees: July 1, 2025; 15 to 24 employees: January 1, 2026; 5 to 14 employees: July 1, 2026. The initial employee contribution rate is 5% of salary; it appears the program will also feature an automatic annual savings increase of 1% of salary up to a maximum of 8%."  MORE >>


[Guidance Overview]

Mandatory Auto-Enrollment Is Coming for Some Plans: What to Know

"Notice 2024-02 doesn't purport to be comprehensive guidance, and existing regulations on auto-enrollment permit more flexibility than SECURE 2.0.... Additional guidance should come sooner rather than later ... Even though the SECURE 2.0 amendment deadlines have been extended by Notice 2024-02, the compliance deadline remains the same, and operational compliance and communications require planning."  MORE >>

Cohen & Buckmann, P.C.

Plan Design: Is the New SECURE 2.0 Cash Out Limit Mandatory or Not?

"[Q]ualified retirement plans are not required to have cash-out provisions at all.... Each plan has the option to set its own cash-out threshold within the prescribed limit (anywhere from $0 to $7,000 for 2024 and later years). The threshold must be written into the plan document."  MORE >>

Retirement Learning Center, LLC

DOL Releases Audit Quality Study for Employee Benefit Plans

"EBSA's review found that 70 percent of the audits fully complied with professional auditing standards or had only minor deficiencies ... However, 30 percent of the audits (3 out of 10) contained major deficiencies with respect to one or more relevant generally accepted auditing standards requirements. This puts $927 billion and 11.7 million plan participants and beneficiaries at risk, an increase of $274 billion compared with prior EBSA studies."  MORE >>

Meaden & Moore

Participant and Plan Sponsor Advocate Says Major Changes Needed at PBGC

"[P]lan sponsors have complained about longstanding issues such as: [1] case review delays; [2] the absence of oversight and management; [3] communication lapses; [4] departmental coordination issues; and [5] an overall lack of transparency about PBGC processes and procedures. The report notes that ... plan sponsors applying for a distress termination under the business continuation test encounter 'a lengthy and inefficient review process' that can take months or years."  MORE >>

American Retirement Association [ARA]

What's Next for Public Pensions and ESG?

"While the concept of socially responsible investing has been around for more than 70 years, the term has made its way to mainstream media over the past year as a political talking point -- and public pensions are increasingly being caught in the crossfire.... These pro- and anti-ESG policies have resulted in several key lawsuits -- the results of which will likely have last implications for public pensions across the country."  MORE >>

National Conference on Public Employee Retirement Systems [NCPERS]

3m to Freeze U.S. Pension Plans at the End of 2028

"The company said pension-eligible nonunion employees will accrue benefits until Dec. 31, 2028 ... 3M had closed its primary U.S. pension plan to new hires effective Jan. 1, 2009. The change will affect employees at both 3M and Solventum, the healthcare company that is expected to spin off from 3M in the first half of 2024."  MORE >>

Pensions & Investments

It's That Time of Year: Retired Households Should Perform Their Actuarial Valuations

"A household actuarial valuation involves calculating and comparing present values of household assets and household spending liabilities for the purpose of determining the household's Funded Status. To do this, [the authors] suggest you follow the easy 5-step valuation process outlined [in this post, using the] Actuarial Financial Planner (AFP) models."  MORE >>

Ken Steiner, FSA Retired

Benefits in General

[Official Guidance]

IRS Confirms E-Filing of Form 5558 Through EFAST2 Postponed Until Jan. 1, 2025

"Due to IRS administrative issues involving the EFAST2 system, the IRS is postponing electronic filing of Form 5558 through EFAST2 until Jan. 1, 2025. Plan sponsors and administrators should continue to use a paper Form 5558 to request a one-time extension of time to file a Form 5500 series or Form 8955-SSA (up to 2½ months after the normal due date for Form 5500s or Form 8955-SSA)."  MORE >>

Internal Revenue Service [IRS]

Employee Benefits Jobs

View job as Client Manager for Marcum Wealth

Client Manager

Marcum Wealth


View job as Client Manager for Marcum Wealth

View job as Third-Party Employee Benefits Administrator for Schneider Downs

Third-Party Employee Benefits Administrator

Schneider Downs

Pittsburgh PA / Hybrid

View job as Third-Party Employee Benefits Administrator for Schneider Downs

View job as Recordkeeping Manager for July Business Services

Recordkeeping Manager

July Business Services


View job as Recordkeeping Manager for July Business Services

View job as Regional Sales Director - Midwest for July Business Services

Regional Sales Director - Midwest

July Business Services

Remote / IL / IN / MN / MO / WI

View job as Regional Sales Director - Midwest for July Business Services

Selected New Discussions

Abandoned Plan

"When a plan sponsor decides to terminate their 401k retirement plan as per regulation it need to be closed within 12 months from the termination dates however we have seen plan sponsor becoming unresponsive which ultimately leads to Abandoned plan. From a record keeper perceptive what will be challenges to maintain an abandoned plan? also on the regulatory part if any?"

BenefitsLink Message Boards

Top-Heavy/Key-Employee Question

"I'm checking the admin software on this which says the person is not key for 2023. 99% of our plans are small with owners/officers being the same and always >5%. But now the top-heavy issue comes into question for a client with a non-owner officer.

Question: For PYE 12/31/2023 the top-heavy determination date is 12/31/2022 and the plan is top heavy as of that date. The employee in question is not an owner or officer in 2022 but became an officer 1/1/2023 (no ownership) and has $250,000 in comp for 2023. I believe this person is non-key for 2023 and needs a top heavy contribution for 2023. This is what our software indicates.

Likewise if someone buys into a company in 2023 at over 5% (is not an officer) they would not be key for the year of their buy-in since the determination date of their status is the last day of the prior year. They would be non-key for 2023 and key for 2024. (They would be HCE for 2023 however.) Comments?"

BenefitsLink Message Boards

LTPT Questions That Thread the Needle

"Trying to write some formulas... Plan Year End = 12/31. Participant is hired on 12/31/2023. Their first 12 months is finished 12/30/2024,which is year 1. Their 2nd year (assuming switch to plan year) is calendar 2024. Agreed? And if their hire is 1/1/2024, and their 12 months is finished 12/31/2024, because that coincides with the plan year exactly, clearly we would not count the same exact 12 months, right? I could see someone (especially a formula if one is not careful) mistakenly crediting the same 12 months twice because it counts both the first 12 months AND the first full plan year)."

BenefitsLink Message Boards

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

Six Gaps in the U.S. Retirement System (And How to Close Them!)

January 9, 2024 WEBINAR


Executive Compensation Academy: New Compensatory Thoughts & Practices from ISS

January 11, 2024 WEBINAR

Hunton Andrews Kurth

Marketing Your Fiduciary Excellence

January 11, 2024 WEBINAR


New Guidance on SECURE 2.0

January 17, 2024 WEBINAR

Convergent Retirement Plan Solutions, LLC

Fiduciary Rule 4.0: Are You Ready?

January 30, 2024 WEBINAR

American Bar Association Joint Committee on Employee Benefits [JCEB]

ERISA: Beyond the Basics

May 7, 2024 WEBINAR

American Bar Association Joint Committee on Employee Benefits [JCEB]

Last Issue's Most Popular Items

IRS Provides Guidance on SECURE 2.0 Act Changes and Further Extends Plan Amendment Deadline for Applicable Legislation (PDF)

Thomson Reuters / EBIA

IRS Issues 2023 Cumulative List for Defined Contribution Pre-Approved Plans (PDF)

Thomson Reuters / EBIA

The Plan Sponsor's Guide to PEPs

Pensions & Investments, in partnership with AON

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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.

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