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Retirement Plans Newsletter

February 7, 2025

4 New Job Opportunities 4 New Job Opportunities

 

[Guidance Overview]

DOL Muddies the Water with Escheatment Guidance for Retirement Plans

"[Field Assistance Bulletin No. 2025-01] is notable in that it provides some insight into how DOL views the fiduciary decision to voluntarily escheat benefits, but the relief provided by the non-enforcement policy is very limited. Notably, the FAB states that the non-enforcement policy is temporary because DOL 'intends to consider more formal guidance' related to escheatment in the future."  MORE >>

Groom Law Group

[Guidance Overview]

IRS Updates Determination and Opinion Letter Procedures for 2025

"Besides making routine revisions for dates, cross-references and citations to other revenue procedures, Rev. Proc. 2025-4 makes several changes to the procedures for requesting preapproved plan opinion letters ... Rev. Proc. 2025-4 makes no increases to 2024 user fees. However, a reduced fee of $10,000 applies to a letter ruling request for a funding method or actuarial assumption change for a defined benefit pension plan (the fee for most other letter rulings is $12,500)."  MORE >>

Mercer

[Guidance Overview]

Exceptional Usefulness and Quality icon IRS Releases Proposed Mandatory Automatic Enrollment Regulation

"[A] 401(k) or 403(b) plan will satisfy the mandatory automatic enrollment requirement only if the plan provides an EACA that covers all employees in the plan who are eligible to elect to have contributions made on their behalf. This includes long-term, part-time employees.... The regulatory amendments are designed to align with the mandatory automatic enrollment requirements described in Section 101 of SECURE 2.0. They also support SECURE 2.0 provisions that allow employers to forego sending annual EACA notices to unenrolled participants and to combine two or more mandatory notices."  MORE >>

Ascensus

[Guidance Overview]

IRS Releases Catch Up Roth Guidance

"The regulations also include two self-correction programs ... A plan could provide for either correction method but must use the same correction method for all participants with deferrals over the same applicable limit in a plan year. To use these correction methods, a plan must have practices and procedures in place that are designed to result in compliance with the mandatory Roth catch-up provision.... Plans would not be permitted to avoid mistakes by categorically requiring that all catch-up contributions be made as designated Roth contributions."  MORE >>

The Rosenbaum Law Firm, P.C.

[Guidance Overview]

New Proposed Catch-Up Contribution Regs Answer Many Questions

"These changes, if applicable, would introduce more complexity to both payroll and plan administration, and would require additional coordination between the two systems ... If plan administrators would like to take advantage of the two new correction methods for errors involving Mandatory Roth Catch-Up contributions, they must implement procedures that are designed to result in compliance with the Mandatory Roth Catch-Up rules at the time of the deferral, including to provide for deemed Roth Catch-Up elections."  MORE >>

Patterson Belknap Webb & Tyler LLP

[Sponsor]

2025 CCA Enrolled Actuaries Conference | Virtual

Choose from 39 sessions covering topics in single-employer, multiemployer, public plans, small plans and other topics relevant to pension professionals. Earn up to 18.5 EA credits, including 2.0 EA Ethics credits & 1.5 credits toward bias topics.

Sponsored by Conference of Consulting Actuaries [CCA]

Bills to Allow CITs in 403(b) Plans Reintroduced in House, Senate

"[B]ills that would allow 403(b) plans to include collective investment trusts in their investment lineups were introduced in the House and Senate on [February 5]. The Retirement Fairness for Charities and Education Institutions Act of 2025 seeks to amend federal securities laws to enhance 403(b) plans. The House bill (HR 1013) and the Senate bill (S 424) are identical."  MORE >>

PLANSPONSOR; free registration may be required

U.S. Pension Plan Managers Foresee Increased Risks to Both Assets and Liabilities in 2025

"84% of US pension plan managers expect the coming year to bring an elevated risk profile.... In 2024, the bulk of those surveyed already saw risks rising. Half (50%) of those surveyed said their risk profile increased slightly last year and 6% reported their risk increased considerably. Around two fifths (42%) reported their risk profile remained the same and only 2% said their risk decreased."  MORE >>

Ortec Finance

Asset Allocation of Public-Sector DC Plan Participants, 2022 (PDF)

10 pages. "Large-cap domestic equity was the asset class with the largest amount of assets, constituting over 26 percent of the sample on a dollar-weighted basis. This was followed by off-the-shelf target-date funds (17.2 percent) and stable value/fixed accounts (16.2 percent).... Among the 27 asset classes ... 12 classes had 0.5 percent or less of the total asset value each[.]"  MORE >>

PRRL [Public Retirement Research Lab]

Maybe You Shouldn’t Delay Taking Your Social Security Benefits After All

"Adding annuities and Social Security to your portfolio withdrawals will lead to higher spending while increasing the efficiency of guardrail strategies. Delaying Social Security gives you a bonus on the amount the Social Security Administration owes to you.... A bridge strategy builds an income cushion so you can postpone taking your full Social Security. If you're able to, it's better to postpone retirement as a bridge strategy to delay Social Security."  MORE >>

Morningstar

Benefits in General

Top Return-to-Office Strategies Employees Truly Value

"[P]eople who rated their RTO experience as 'extremely positive' pointed to clear policies and expectations from their employers. Flexibility also played a vital part, with 87% of employees saying flexible work schedules were important to help them excel at their current role.... 83% of employees who had an extremely positive RTO experience reported improved work quality."  MORE >>

HealthEquity

Executive Compensation and Nonqualified Plans

[Guidance Overview]

Proposed Regs Explain the Expansion of 'Covered Employees' Under Code Section 162(m)

"In assembling compensation data for potential covered employees, companies should take a broad view of their employee population to correctly identify the next five highest compensated employees under the Proposed Regulations (i.e., companies should consider individuals that are employed through foreign entities, PEOs or other third parties). Companies should also be prepared to conduct the analysis on an annual basis to redetermine the group of five additional employees."  MORE >>

Eversheds Sutherland

Employee Benefits Jobs

View job as Manager, Retirement Plan Onboarding and Legal for Cetera Retirement Plan Specialists

Manager, Retirement Plan Onboarding and Legal

Cetera Retirement Plan Specialists

Saint Cloud MN / CA / IA / TX / Hybrid

View job as Manager, Retirement Plan Onboarding and Legal for Cetera Retirement Plan Specialists
View job as Combo Plan Administrator for Karel-Gordon & Associates

Combo Plan Administrator

Karel-Gordon & Associates

Remote

View job as Combo Plan Administrator for Karel-Gordon & Associates
View job as Retirement Plan Consultant for The Finway Group

Retirement Plan Consultant

The Finway Group

Remote / West Des Moines IA

View job as Retirement Plan Consultant for The Finway Group
View job as Retirement Specialist for Alerus

Retirement Specialist

Alerus

Remote / AZ / CO / MI / MN / ND / WI

View job as Retirement Specialist for Alerus

Selected New Discussions

Resources for Independent Valuations

"We have a client with a 401(k). The client does not want to hire an investment consultant. Instead, they are looking for a resource for where to get a report of metrics for the investments in the Plan so they can do this work themselves. Does anyone know of a good resource for this? I understand the benefits of an investment consultant and they have been communicated to the client, but this is their decision."

BenefitsLink Message Boards

Individual Brokerage 401(k)

"Our firm is managing the investments and the administration for a client where each participant has individual brokerage accounts. We process def, match, and ps into each of their individual brokerage accounts. For those who have clients that aren't at traditional record keepers, is it recommended to have individual accounts for each money source?"

BenefitsLink Message Boards

One Entity Purchases Two Others, Now Wants to Merge 3 Plans

"We're being asked to takeover and merge 3 separate plans. Entity A purchased entities B&C during 2023. Entity A participates in a PEO 401k Plan. Entities B & C each maintain their own safe harbor 401k, with different safe harbor formulas. Entity A's plan is also SH. We are told it was a stock purchase (B&C are LLCs) and nothing has been done with these plans until now to bring them together. They have been maintained and each have separate TPAs. Since they are all owned by the same owner now we intend to merge the plans effective 1/1/26 sponsored by Entity A and with entities B&C as participating sponsors.... Any reason this can't be done? We're waiting until 2026 because of the issues that would be involved with a mid-year change to safe harbor plans."

BenefitsLink Message Boards

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

Nderstanding the Risks and Conflicts in the 'Retailification' of Retirement Plans

February 20, 2025 WEBINAR

Multnomah Group

Thriving (Not Just Surviving) During a Plan Audit: Collaborating to Build Trust, Enhance Communication, and Save Time!

April 1, 2025 WEBINAR

ASPPA [American Society of Pension Professionals & Actuaries]

Deferred Compensation Strategies to Attract, Retain and Incentivize Key Employees

April 8, 2025 WEBINAR

Lorman Education Services

Last Issue's Most Popular Items

IRS Chart: Cost-of-Living Adjustments for Retirement Items (PDF)

Internal Revenue Service [IRS]

DOL Adopts Self-Correction for Common Retirement Plan Fiduciary Breaches

Squire Patton Boggs

2025 Outlook for Pension Legislation, Rules and Litigation

Segal

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

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