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Retirement Plans Newsletter

January 9, 2025

6 New Job Opportunities 6 New Job Opportunities

 

[Official Guidance]

Text of IRS Rev. Proc. 2025-4: Procedure for IRS Employee Plans Determination Letters, Rulings and Agreements (PDF)

"This revenue procedure is a general update of Rev. Proc. 2024-4 ... which sets forth general information about the types of advice provided by Employee Plans Rulings and Agreements; general procedures for letter ruling and determination letter requests; specific procedures for determination letter requests; and the user fees associated with advice requested from Employee Plans Rulings and Agreements."  MORE >>

Internal Revenue Service [IRS]

[Official Guidance]

Draft of 2025 IRS Instructions for Certain Information Returns (Forms 1096, 1097, 1098, 1099, 3921, 3922, 5498, and W-2G) (PDF)

Jan. 8, 2025; 32 pages. "Reminders:  [1] E-filing returns ... [2] Information reporting Intake System (IRIS) ... [3] Due date for certain statements sent to recipients."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

SECURE 2.0 Considerations for 2025

"Ages 60-63 (or 'Super') catch-ups ... Auto-portability ... Long-term, part-time (LTPT) rules ... The deadline to amend most plans for SECURE 1.0, the CARES Act, and SECURE 2.0 is December 31, 2026."  MORE >>

Kutak Rock LLP

[Guidance Overview]

PBGC Premiums for 2025 Plan Year Due Earlier Than Usual

"[B]ecause of a provision in the Bipartisan Budget Act of 2015, premiums for plan years beginning in 2025 are generally due a month earlier than usual. For example, the premium filing and payment for a plan with a calendar plan year will be due September 15, 2025, instead of the normal due date of October 15, 2025. This acceleration of premium dues dates applies only for plan years that begin in 2025."  MORE >>

Cheiron

[Guidance Overview]

PBGC Technical Update 25-1 Addresses Accelerated Premium Payment Due Date for 2025 Plan Years

"The Bipartisan Budget Act of 2015 (BBA) accelerated the due date of PBGC premiums from the ordinary date of October 15th to the 15th day of the ninth calendar month that begins on or after the first day of the premium payment year (September 15th for calendar year plans), only for plan years that begin in the 2025 calendar year. The acceleration raises revenue by bringing another year into the ten-year window used for budget-scoring."  MORE >>

Thomson Reuters Practical Law

[Guidance Overview]

IRS Extends Anticipated Effective Date for Certain 2024 Proposed RMD Rules Until 2026

"This relief gives plan/IRA sponsors and recordkeepers some much-needed time to finalize the implementation of these changes. Importantly, prior to such date, the IRS provides a reasonable, good faith interpretation standard to meet these new rules."  MORE >>

Groom Law Group

Verizon Sued Over $5.9 Billion Pension Risk Transfer Deal with Prudential

"[I]nsurance company Prudential, which is managing the pensions, is not named as a defendant in the Verizon lawsuit. Plaintiffs are suing Verizon and State Street Global Advisors, which served as 'the independent fiduciary' in putting the deal together, according to the suit." [Dempsey v. Verizon Comm. Inc., No. 24-10004 (S.D.N.Y. complaint filed Dec. 30, 2024)]  MORE >>

Treasury & Risk; free registration required

Rollover Recommendations: The DOL Fiduciary Rule Stay and What Remains (PDF)

"[T]here may be at least three instances when the current DOL fiduciary rule will apply to a rollover recommendation by an advisor, and in those instances the firm and the advisor may need the relief provided by PTE 2020-02 (that is, the version adopted by the DOL in 2020, which is unaffected by the current litigation and stay)"  MORE >>

Faegre Drinker, via Journal of Pension Benefits

Does Tax Deductibility Increase Retirement Saving? Lessons from a French Natural Experiment

"Using administrative data from a large retirement plan administrator in France, [the authors] examine the voluntary saving choices of approximately 1.4 million workers before and after the implementation of ... a reform that introduced tax-deductible voluntary contributions into employer-sponsored retirement plans.... While such contributions were previously allowed on an after-tax basis, similar to Roth IRAs and 401(k)s in the US, the reform allowed pre-tax contributions that provided an immediate tax deduction for contributors. The reform increased contributions to retirement saving accounts[.]"  MORE >>

Marie Briere, James M. Poterba and Ariane Szafarz, via SSRN

Executive Compensation and Nonqualified Plans

[Guidance Overview]

2025 Deadlines Approach to Furnish Incentive Stock Option and Employee Stock Purchase Plan Information Statements and Returns

"Section 6039 of the Internal Revenue Code requires a corporation to furnish a written statement to any employee or former employee who either [1] exercised an incentive stock option ... or [2] in 2024 first transferred legal title to shares acquired under the corporation's employee stock purchase plan ... The corporation must furnish these statements on Forms 3921 and 3922 to affected participants no later than January 31, 2025."  MORE >>

DLA Piper

Employee Benefits Jobs

View job as Retirement Plan Client Onboarding Specialist for TriStar Pension Consulting

Retirement Plan Client Onboarding Specialist

TriStar Pension Consulting

Remote

View job as Retirement Plan Client Onboarding Specialist for TriStar Pension Consulting
View job as Director of 3(16) Fiduciary Services for Definiti

Director of 3(16) Fiduciary Services

Definiti

Remote

View job as Director of 3(16) Fiduciary Services for Definiti
View job as Retirement/TPA Industry Expert for Stax.ai, Inc.

Retirement/TPA Industry Expert

Stax.ai, Inc.

Scottsdale AZ

View job as Retirement/TPA Industry Expert for Stax.ai, Inc.
View job as Actuary for Nova 401(k) Associates

Actuary

Nova 401(k) Associates

Remote

View job as Actuary for Nova 401(k) Associates
View job as Retirement Plan Analyst - Defined Contribution Plans for M2B Retirement Consulting, LLC

Retirement Plan Analyst - Defined Contribution Plans

M2B Retirement Consulting, LLC

Remote / PA

View job as Retirement Plan Analyst - Defined Contribution Plans for M2B Retirement Consulting, LLC
View job as Compliance Manager for FiduciaryXChange

Compliance Manager

FiduciaryXChange

Remote

Selected New Discussions

Loan Repayments Set Up as Deferrals

"Pooled 401k plan in a brokerage account. Participant L (who does not defer) takes out a loan.... and the office manager who doesn't know any better codes it as pre-tax deferrals. It's a 9/30/24 PYE and the loan was taken in August 2024, so we just discovered it 4+ months in. To the plan, this is a non-issue, right? L owed $200 per paycheck, and that is what was deposited. The only 'allocation' is when we do the recordkeeping, so if we say those are loan repayments, then they are credited as loan repayments. Or do those not count as loan repayments, but rather deferrals.... that weren't asked for? And what about L's W-2? It correctly shows pre-tax deferrals, because that is what happened. Any advice appreciated."

BenefitsLink Message Boards

Allocating ADP Refund to Roth vs Pre-Tax

"My plan has failed the ADP test, resulting in a refund. The HCE receiving the refund has both pre-tax (deferral) and Roth contributions. Is the refund amount discretionary for the employee to choose between pre-tax deferral and Roth contributions, or is there a specific sequential order for deducting it (e.g., first from pre-tax deferrals and then from Roth)? Are there any IRS rules governing the sequential order for processing such refunds?"

BenefitsLink Message Boards

Press Releases

Jay A. Dorsch Appointed to the 2025 ERISA Advisory Council by U.S. DOL

Cozen O'Connor

Independent Retirement Announces Exciting Leadership Transition

Independent Retirement [Inde]

Kelsey Mayo Joins American Retirement Association as Regulatory Affairs Chief

American Retirement Association [ARA]

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

A Primer on PEPs: Separating Myth from Reality

RECORDED

WTW

Demystifying 457(b) and 457(f) Plans for Tax-Exempt Organizations

January 22, 2025 WEBINAR

Multnomah Group

SECURE 2.0 Hits and Misses: An Overview of Recent Developments, Critical Next Steps and Planning Opportunities

January 29, 2025 WEBINAR

Western Pension & Benefits Council

Last Issue's Most Popular Items

The Social Security Fairness Act

403bwise

2025 Compliance Calendar for Defined Contribution Retirement Plans (PDF)

USI Consulting Group

PBGC Premiums for the 2025 Plan Year Are Due One Month Earlier Than Usual

Milliman

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

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