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Retirement Plans Newsletter

November 13, 2024

 

[Official Guidance]

Text of IRS Notice 2024-81: Weighted Average Interest Rates, Yield Curves, and Segment Rates for November 2024 (PDF)

"This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates ... and the 24-month average segment rates ... [as well as] the interest rate on 30-year Treasury securities ... as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate[.]"  MORE >>

Internal Revenue Service [IRS]

[Sponsor]

Advanced Pension Conference - January 29-31 - Register today

The program includes eleven sessions on the latest legislative updates from our ERISA expert panel. Attendees may earn up to 13 CE credits. View agenda and register here.

Sponsored by FIS Retirement Education

[Official Guidance]

Text of IRS Notice 703: Worksheet to Determine Whether Your Social Security Benefits May Be Taxable (PDF)

"We developed this worksheet for you to see if your benefits may be taxable for 2024. Fill in lines A through E."  MORE >>

Internal Revenue Service [IRS]

[Official Guidance]

Draft of Instructions for IRS Form 5307: Application for Determination for Adopters of Modified Nonstandardized Pre-Approved Plans (PDF)

Nov. 12, 2024. "What's New: The form and instructions have been updated to include 403(b) plans. Reminders: The form and instructions have been updated to be completed on Pay.gov as of July 1, 2023. The form and the instructions have undergone major revisions in the format and information."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

Exceptional Usefulness and Quality icon SECURE 2.0 in 2025: Big Plan Design Changes

"We don't yet have a clear definition of who is a 'covered employee' subject to the mandatory auto enroll feature.... The addition of an auto enroll feature will likely result in more small account balances for terminated participants.... Similar to the mandatory auto enroll feature, the LTPT employee provisions may result in increased small balances for terminated participants.... Beginning in 2025, an increased dollar limit [for catch-up contributions] applies for participants who have attained age 60 but not yet age 64.... [T]he provisions effective in 2025 can be operational prior to amending the plan."  MORE >>

PenChecks

[Guidance Overview]

Prepare for Upcoming Changes to Retirement Plans for 2025

"Many of the changes have already been implemented by service providers, but some sponsors will need to plan for changes that will be effective in 2025.... [1] Long term, part-time employees... [2] Enhanced catch-up contributions for certain ages.... [3] Automatic portability of small-sum distributions."  MORE >>

The Wagner Law Group

[Guidance Overview]

IRS Provides Guidance on Long-Term, Part-Time Employee Eligibility for 403(b) Plans

"[Notice 2024-73] addresses the conditions under which part-time employees may be excluded from making elective deferrals and the inclusion of long-term, part-time employees in plan eligibility requirements pursuant to new Employee Retirement Income Security Act (ERISA) section 202(c). It also explains that employers can exclude these employees from certain nondiscrimination testing and employer contributions."  MORE >>

RSM US

[Guidance Overview]

Exceptional Usefulness and Quality icon Final and Proposed RMD Regs Provide Much Needed Guidance

"The Final RMD Regulations are effective for distribution calendar years beginning on or after January 1, 2025. For distribution calendar years before January 1, 2025, a good faith, reasonable interpretation of statutory provisions standard applies. The key provisions from the Final RMD Regulations that clarify or expand on the 2022 Proposed Regulations and the Proposed RMD Regulations are discussed [in this article]."  MORE >>

Trucker Huss

Ninth Circuit Explains What the Q in QDRO Means

[T]he Ninth Circuit's 'substantial compliance' doctrine performed some heavy lifting in this case. The separation agreement lacked significant detail but the district court and the Ninth Circuit enforced it nonetheless because it was clear what the Kowalskis intended and there was only one insurance policy in existence at the time of Mr. Kowalski's death." [Hartford Life & Accident Ins. Co. v. Valois, No. 23-3286 (9th Cir. Nov. 5, 2024; unpub.)]  MORE >>

Kantor & Kantor

Understanding When a Retirement Plan Audit Is Required

"Plans can utilize the 80/120 rule, which allows a plan to file its current year Form 5500 in the same category as the previous year as long as the number of participants with account balances remains between 80 and 120."  MORE >>

Withum Smith+Brown, PC

Preparing for Your First Plan Audit

"You can streamline the audit process by preparing in advance. For example, to expedite the auditors' work, gather and organize [certain] materials ... The Plan Sponsor can further help save time and money by assigning a primary contact person for your audit team.... Also remember to keep open the lines of communication."  MORE >>

ORBA

SEC Poised to Undergo Major Changes Under Republican Leadership

"In light of Donald Trump's recent presidential election victory, various regulatory and enforcement priorities at the [SEC] are likely to change. These include swing pricing, disclosure rules, crypto enforcement, and private offerings. The SEC under Chairman Gary Gensler may yet have time finalize a rule or two during the lame-duck period prior to Trump's inauguration."  MORE >>

American Retirement Association [ARA]

Retirement Plan Providers Improve Website Experiences and Financial Planning Tools, Participants Still Want Better Usability

"User satisfaction with retirement plan providers is generally high ... with 87% of respondents saying they were either 'somewhat satisfied' or 'extremely satisfied' with their provider. But many respondents cited usability improvements when asked what they would change about their plan provider's website. Respondents focused on page layout, menu design, and login flow as areas ripe for improvement."  MORE >>

Corporate Insight [CI]

[Opinion]

Retirement Plans Must Consider the Possibility That President Trump's Second Term Will See America Embracing Bitcoin

"Many individuals remain skeptical of Bitcoin ... However, a prudent investor would assign some probability to the United States creating a strategic bitcoin reserve and consider taking a position.... Once it was understood that the mathematical and computer science principles that are the foundation of the Bitcoin protocol functioned properly, Bitcoin has always been as close to a sure bet that exists in the long-run."  MORE >>

Ryan P. Moulder

Benefits in General

[Guidance Overview]

Benefit Plan Deadlines Extended for Individuals Affected by Recent Natural Disasters

"Pursuant to the Joint Notice, benefit plans subject to ERISA or the Internal Revenue Code are required to disregard a defined 'Relief Period' when determining certain plan deadlines applicable to participants, beneficiaries, COBRA qualified beneficiaries and claimants affected by the disasters. [This article answers] questions related to the scope of the relief, and offer recommendations for plan sponsors and administrators regarding implementation of the deadline extensions."  MORE >>

Proskauer

[Guidance Overview]

IRS Announces 2025 Retirement and Benefit Plan Limits, SSA Announces COLA Adjustment

"On November 1, 2024, the [IRS] announced cost-of-living adjustments (COLAs) to the dollar limits on benefits and contributions in retirement plans for 2025. These adjustments are in addition to previously announced increases in limits to other employee benefit plans. In addition, the Social Security Administration (SSA) recently announced the COLA to the Social Security wage base for 2025."  MORE >>

DLA Piper

Executive Compensation and Nonqualified Plans

Nonqualified Plan Outlook: 2025 IRS Contribution Limits on Qualified Plans

"Year-end is when many participants in NQDC plans ... choose how much of next year's pay to put away for the future. Generally, you defer income via nonqualified plans only when you know you will max out your yearly contributions to qualified plans, such as your 401(k). Crucially for this decision, the IRS just released the 2025 contribution limits for qualified retirement plans."  MORE >>

myStockOptions.com

Selected New Discussions

Maximum Comp for Match

"Does it say anywhere that the comp limit is the FIRST $345,000 earned? (for 2024) My doc says 'Compensation in excess of $200,000 [as indexed] shall be disregarded for all purposes other than for purposes of Elective deferral.' Does that mean someone who earns $700,000 a year, but doesn't start deferring until the second half of the year will get no match? Doesn't make sense. But plan sponsor and advisor want something in writing."

BenefitsLink Message Boards

Press Releases

Morris, Manning & Martin Expands Employee Benefits & Executive Compensation Practice in D.C. With Addition of Jeff Witt

Morris, Manning & Martin, LLP

Olivia Mitchell to Receive CIO’s 2024 Lifetime Achievement Award

CIO [Chief Investment Officer]

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

What’s the Difference Between Performance Stock Units (PSU) and Restricted Stock Units (RSU)?

RECORDED

Savant Wealth Management

Last Issue's Most Popular Items

Do You Need to Send an Annual Notice to Plan Participants?

Alston & Bird

What's All the Fuss About Forfeitures?

Newfront

IRS Interim Guidance Under SECURE 2.0 on 'Inadvertent Benefit Overpayments'

Jackson Lewis P.C.

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

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