"Has your recordkeeper, third-party administrator, or plan document appropriately documented and captured the provision selections around the LTPT employees if you exclude part-timers from participating? ... Have all the notices been correctly updated to include this rule (or updated if you changed eligibility) and did those notices go to participants in the required timeframe for the January 1, 2025 enrollment?"  MORE >>

"[S]ome retirement plan service providers and vendors have advised plan sponsors that Super Catch-Up Contributions can be made by participants who are age 63 at any time during the participant's taxable year. This would effectively allow participants who attain age 64 sometime during the taxable year to make Super Catch-Up Contributions. The statute and regulations are clear that participants can only make Super Catch-Up Contributions for the years in which they first attain ages 60 through 63."  MORE >>

"EBSA reserves the right to conduct an investigation to confirm the accuracy of the factual statements made in the self-correction notice, and to ensure that corrective actions were actually taken. The plan administrator must retain proof of payment of the principal amounts and lost earnings and copies of [1] the filed SCC notice, [2] the Acknowledgement, [3] the representative's authorization form, and [4] the signed penalty of perjury statement. The reporting of Late Participant Contributions on the plan's Form 5500 or Form 5500-SF is still required[.]"  MORE >>

"The compliance burden associated with a solo 401(k) is relatively light but is not to be minimized.... Here are three somewhat thorny compliance challenges a solo 401(k) may face. [1] A non-excludable employee is hired.... [2] Contributions exceed IRS limits.... [3] The prohibited transaction rules apply."  MORE >>

"Plan sponsors of dual-qualified plans and plans qualified solely in Puerto Rico should update their administrative processes and systems to reflect the 2025 limits. These sponsors should also review their administrative procedures to ensure limits are being monitored."  MORE >>

"The court's decision highlights the importance of thoughtfully drafted plan provisions that detail the permitted or mandated uses of forfeitures. The court's decision also serves as an important reminder that employers and plan fiduciaries should continue to proactively review their plan language to ensure that the use of forfeitures is consistent with plan terms and applicable laws." [Hutchins v. HP Inc., No. 23-5875 (N.D. Calif. Feb. 5, 2025)]  MORE >>

"The next generation of automatic features in 401(k) plans will include default savings rates that will give workers switching jobs the option to choose between the new employer’s default savings rate or the one they had at their previous employer, if higher. That was one of the innovations that Mark Iwry, a nonresident senior fellow at the Brookings Institution, predicts the industry will have within 24 months.... Even if SECURE 3.0 does not move forward, Iwry is confident that the auto-provision will materialize."  MORE >>

"More emphasis on participant 'financial wellness' and education ... Greater focus on retirement income solutions ... More enrollment and contribution-increase automation ... Expanded 'catch-up' contribution limits and Roth focus ... Utilizing professional assistance."  MORE >>

"Defined benefit plans are required to provide participants with an Annual Funding Notice, or 'AFN.' DOL regulations require that the AFN include the allocation of Plan investments, but do not dictate specific asset categories that must be listed for purposes of this disclosure. The AFN is usually prepared by the plan's actuary, then reviewed by the plan administrator. This Benefits Bullets is intended to assist the plan administrator's review. It provides background on the asset allocation disclosure requirement and presents several ways that defined benefit plans can meet it."  MORE >>