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Retirement Plans Newsletter

January 31, 2024

3 New Job Opportunities 3 New Job Opportunities


[Official Guidance]

Text of Instructions for IRS Form 8915-F: Qualified Disaster Retirement Plan Distributions and Repayments (PDF)

52 pages, Jan. 30, 2024. "As a result of section 331 of the SECURE 2.0 Act of 2022 ... you are now eligible for the benefits of Form 8915-F if you were adversely affected by a qualified 2021 or later disaster and you received a distribution described in Qualified Disaster Distribution Requirements or Qualified Distribution Requirements[.]"  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

IRS Provides Guidance on Roth Matching or Nonelective Contributions

"The Employer Roth Contribution will be includible in income of the employee in the year in which it is allocated to the employee's account.... [Notice 2024-02] provides any designated Employer Roth Contributions are generally not considered wages subject to income tax, FICA or FUTA withholding ... Therefore, affected employees will likely have to voluntarily adjust withholding or pay estimated tax payments[.]"  MORE >>

Trucker Huss

[Guidance Overview]

IRS Issues Guidance on Required Inclusion of Long-Term, Part-Time Employees in 401(k) Plans, Including Application to Governmental Plans

"The proposed IRS regulations provide clarification on who long-term, part-time employees are and how to determine their eligibility and vesting rights. Long-term, part-time employees may be excluded from nondiscrimination and coverage testing, and top-heavy vesting and contributions. The IRS summary indicates that the long-term, part-time employee rules also apply to ERISA-exempt governmental and church plans, but the IRS is requesting comments on that issue."  MORE >>

Hanson Bridgett LLP

[Guidance Overview]

Deadlines for 401(k) Adoption, Including SECURE 2.0 Changes

"What is the deadline for adopting a new safe harbor 401(k) plan? ... What is the deadline for adopting a new traditional 401(k) plan? ... What is the deadline for converting a traditional 401(k) into a safe harbor plan? ... How soon can I replace a SIMPLE IRA with a 401(k) plan? ... What are the major 401(k) adoption deadlines for 2024 and 2025 [listed in a chart]?"  MORE >>

Employee Fiduciary

More Than Half of Plan Sponsors View In-Plan Retirement Income as 'Too Complex'

"Nearly one in three sponsors reported concerns that associated fees will mean higher costs for their companies, while 30% said they are worried about the additional administrative work that offering income options would require.... At the same time, 72% of employees expressed concern that their retirement income sources may not be simple and easy to manage."  MORE >>

PLANSPONSOR; free registration may be required

DC Target Date Performance 2021-2023, in Four Charts

"For those looking to convert an asset pile into income, ... high interest rates are good news....[T]he sweet spot (for an investor whose ultimate goal is to produce income) is any case in which the 'income gains' from higher interest rates are greater than 'asset losses.' ... Inflation is an acute risk with respect to bonds and annuities -- less so with respect to equities."  MORE >>

October Three Consulting

New Proposal Would Repeal Income Tax on Social Security Benefits, Eliminate Wage Cap

"[HR 7084 would repeal] the federal taxation of benefits while phasing out the current wage cap on taxable earnings.... The bill would keep the trust funds solvent until 2054.... The program's long-range deficit drops meaningfully.... Employees with multiple employers would pay taxes via a special formula.... Trust fund operations would be meaningfully bolstered."  MORE >>


Bill Introduced to Recoup Pension Bailout Sent for Deceased Participants, Require Verification for Future Payments

"The [proposed] legislation would require the PBGC to verify past and future pension bailout applications by cross-checking plan participation lists against the [Social Security Administration's (SSA) Full Death Master File (Full DMF)], ensuring taxpayer dollars are not paying pension bailouts to multiemployer pension plans for deceased individuals. It would further require the PBGC to recoup from multiemployer plans any ghost pensions the plans received as windfalls from taxpayer dollars."  MORE >>

Committee on Education and the Workforce, U.S. House of Representatives


Longevity Is Disrupting Traditional Retirement

"[Y]oung people should start thinking about their potential longevity in a fundamentally different way than their grandparents' or even their parents' generations. This in turn means that they need to rethink their concept of work, saving, investing and retirement.... [If] people expect to live to be 120 on average, the concept of a single, linear 40-year career stops making much sense."  MORE >>


Employee Benefits Jobs

View job as Retirement Plan Administrator for Burke & Schindler CPA

Retirement Plan Administrator

Burke & Schindler CPA

Cincinnati OH / Hybrid

View job as Retirement Plan Administrator for Burke & Schindler CPA

View job as Employee Benefits Account Manager for U.S. Retirement & Benefits Partners

Employee Benefits Account Manager

U.S. Retirement & Benefits Partners

New Braunfels TX

View job as Employee Benefits Account Manager for U.S. Retirement & Benefits Partners

View job as Actuary/Director - Retirement Plan Consulting for Eisner Advisory Group LLC

Actuary/Director - Retirement Plan Consulting

Eisner Advisory Group LLC

Remote / Minneapolis MN / FL / IL / LA / NJ / PA / TX / Hybrid

View job as Actuary/Director - Retirement Plan Consulting for Eisner Advisory Group LLC

Selected New Discussions

Changing from Pay-Period Safe Harbor Match to Annual Match

"So 2024 has already begun and a plan has a pay-period safe harbor match. A client advisor is asking if they can amend the plan to an annual match to eliminate the requirement to pay the match quarterly. (This is not our client and apparently the plan sponsor has been paying the full match after the end of the year.) I told the advisor, I believe this is a prohibited amendment at this point for 2024 and that they need to begin paying no later than the end of the following qtr. I expect everyone will say it's a prohibited amendment for 2024 now even though an annual/true up match could effectively increase the match for some."

BenefitsLink Message Boards

Invalid Beneficiary Designation?

"We administer a small 401(k) plan A participant died and the plan sponsor sent us a copy of the participant's most recent Designation of Beneficiary Form. It was signed a few years ago. The Designation of Beneficiary form provided room to name up to two Primary Beneficiaries and up to two Secondary Beneficiaries. The form also indicates that the participant may attach an additional form should they want to name additional beneficiaries and as long as it the form is signed and dated by the participant it will be valid. Now the Designation of Beneficiary Form is clear that the total of all primary beneficiaries share of benefits must total 100% and the total of all secondary beneficiaries must total 100%. This participant was not married and named a friend as primary beneficiary entitled to 50% of the benefits and no other primary beneficiaries entitled to the remaining 50% share (i.e. the total does not equal 100%). Same with the secondary beneficiaries as their share of benefits does not equal 100%. Question: would this be considered an Invalid Beneficiary Designation? And if so, I believe we would follow the standard hierarchy allocation of assets as described in the plan document."

BenefitsLink Message Boards

Press Releases

Federal Court Orders Coal Producer Retirement Plan Trustees to Pay $637K in Restitution for Unremitted Contributions, Unlawfully Diverted Funds

Employee Benefits Security Administration [EBSA], U.S. Department of Labor

Kantor and Kantor, LLP Launches Their Podcast, 'Talking Insurance with Kantor and Kantor'

Kantor & Kantor LLP

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

The Evolution of QDIAs

March 14, 2024 WEBINAR


Last Issue's Most Popular Items

DOL Lawsuit Alleges TPA Stole $5.5M in Retirement Plan Assets from 17 Clients

PLANSPONSOR; free registration may be required

Meta Effect of Being Non-ERISA


American Benefits Council Comment Letter to IRS on Proposed Regs for Long-Term, Part-Time Employee Under Section 401(k)

American Benefits Council

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

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