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Retirement Plans Newsletter

March 19, 2025

💼  2 New Job Opportunities

 

[Official Guidance]

Text of IRS Publication 560: Retirement Plans for Small Business (SEP, SIMPLE, and Qualified Plans), for Use in Preparing 2024 Returns (PDF)

48 pages. "What's New: [1] Compensation ... [and] catch-up contribution limits for 2024 and 2025 ... [2] Plans established after the end of tax year.... [3] Increased small employer pension plan startup cost credit.... [4] Employer contributions credit.... [5] Small employer military spouse participation credit.... [6] Designated Roth nonelective contributions and designated Roth matching contributions.... [7] Matching contributions on account of qualified student loan payments.... [8] Starter 401(k) deferral-only arrangement.... [9] Additional nonelective contributions under a SIMPLE IRA plan.... [10] Midyear replacement of SIMPLE IRA plan with safe harbor 401(k) plan.... [11] Roth IRAs under a SEP arrangement and Roth SIMPLE IRAs under a SIMPLE IRA plan.... [12] Pension-Linked Emergency Savings Accounts. "  MORE >>

Internal Revenue Service [IRS]

[Sponsor]

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[Guidance Overview]

DOL Touts New Self-Corrections, More Flexibility in VFCP Update

"With the latest VFCP updates, DOL hopes to encourage greater program participation by making the correction process more 'efficient and less costly.' To that end, the updates include new 'self-correction component' (SCC) options for the delinquent transmittal of participant contributions and loan repayments -- by far the most frequently corrected transactions under VFCP -- and for certain participant loan failures self-corrected under EPCRS."  MORE >>

Mercer

[Guidance Overview]

403(b) Plan Employer Eligibility Failures

"It is not uncommon to find governmental agencies that do not operate a public school system, do not have an IRS determination letter and are not within any other classification of an eligible employer, having operated a Section 403(b) Plan for many years. They have been under the misconception that because they are exempt from federal income taxation as a 'local government,' they are an eligible employer. However, the IRS considers a 403(b) plan maintained by an ineligible employer to have experienced a potentially disqualifying event, which it classifies as an 'Employer Eligibility Failure,' starting from the plan's inception."  MORE >>

Best Best & Krieger

JPMorgan Sued for Including ‘Underperforming’ Stable Value Fund in 401(k) Menu

"[Plaintiff] claimed that JPMorgan Chase Bank failed to objectively and adequately review the plan's investment offerings, initially and on an ongoing basis, with due care to ensure each investment option was prudent in terms of performance. As of the end of 2023, the plan had more than $44 billion in assets under management and 295,407 participants. [The] complaint argues that, as a jumbo plan, the plan had substantial bargaining power regarding the fees and expenses charged against participants' investments." [Gonzalez v. JPMorgan Chase Bank N.A., No. 25-1889 (D.N.J. complaint filed Mar. 14, 2025)]  MORE >>

PLANSPONSOR; free registration may be required

The Truth About Pension Data Cleanup: Dispelling Common Myths

"[D]ata cleanup projects don't just mitigate risks; they can be financially rewarding.... The financial implications of ignoring data maintenance can be significant ... Artificial intelligence (such as Optimal Character Recognition, which translates text into characters) and innovative data solutions are game changers, ... Compliance issues arising from faulty data can demand significant time, vendor and legal fees[.]"  MORE >>

Willis Towers Watson

Retirement Plans in M&A Transactions: Look Before You Acquire

"A buyer should learn, as early in the deal as possible, how much the retirement benefit is expected to cost each year, and whether there are any large or small compliance failures lurking in the plan's documentation or operations.... [A] seemingly minor failure left unchecked can jeopardize the plan's tax benefits for years ... [If] caught in time, the buyer can negotiate for the seller to help mitigate the failure and/or plan for the expense of correction after closing.... [This article provides] a due diligence checklist relevant to most 401(k) and 403(b) plans."  MORE >>

KLB Benefits Law Group

Advisor Attitudes Toward 3(16) Fiduciary Outsourcing (PDF)

10 pages. "Nearly 70% [of advisors surveyed] cite administrative burdens and fiduciary risk as chief concerns among clients in managing their retirement plans.... Advisors cite lack of sponsor knowledge of fiduciary responsibilities and retirement plan regulations as the greatest obstacles to retirement plan success.... More than 80% of advisors view 3(16) fiduciary outsourcing as a retirement plan best practice.... Less than half of clients outsource 3(16) fiduciary responsibilities today, representing an opportunity to offer a value-added service."  MORE >>

Pentegra

A Review of Existing Measures of Retirement Well-Being

"While financial readiness measures suggest many could fall short in retirement, most retirees say they are satisfied with their lives. To explore this disconnect, the analysis reviews existing measures of objective and subjective well-being across many datasets. The results show that the objective measures -- such as health and income -- are generally poor predictors of reported satisfaction."  MORE >>

Center for Retirement Research [CRR] at Boston College

Record Number of 401(k) Participants Increased Deferral Rate in 2024

"According to Vanguard's How America Saves 2025, 45% of plan participants increased their deferral rate -- either voluntarily or through an automatic annual increase.... In 2024, 16% of participants raised their payroll deferral percentage ... [while] 29% experienced an increase due to automatic annual escalation.... [T]he average participant account balance rose by 10% from year-end 2023, reaching a record high. By the end of 2024, the average account balance stood at $148,153, while the median balance increased by 8% to $38,176."  MORE >>

Savant

CRS Report: Traditional, Roth, and Rollover IRA Ownership in 2022 (PDF)

15 pages. "In 2022, about one-third (30.1%) of U.S. households had savings in IRAs.... [1] Traditional and Roth IRAs ... [2] Inflows to Traditional and Roth IRAs ... [3] Assets in IRAs ... [4] Household ownership of Individual Retirement Accounts in 2022." [R48456 Mar. 18, 2025]  MORE >>

Congressional Research Service [CRS]

Social Security Strengthens Identity Proofing Requirements and Expedites Direct Deposit Changes to One Day

"Over the next two weeks, SSA will carefully transition to stronger identity proofing procedures for both benefit claims and direct deposit changes. Individuals seeking these services who cannot use their personal 'my Social Security' account, which requires online identity proofing, will then need to visit a local Social Security office to prove their identity in person. At the same time, the agency will expedite processing all direct deposit change requests -- both in person and online -- to one business day. Prior to this change, online direct deposit changes were held for 30 days."  MORE >>

U.S. Social Security Administration [SSA]

DOL Introduces Lost and Found Database

"The Lost and Found Database is only as good as the information provided by the plan administrators of the employer-sponsored plans, often many years ago. Users may find that the database does not have all their employers listed, or may not show that benefits are due from an employer plan if the benefits were paid out long ago. Also, the employer and plan contact information may be out of date."  MORE >>

Pension Rights Center [PRC]

[Opinion]

With New Labor Secretary, Opportunity for Decision on Retirement Security Rule Litigation Provided by Two Federal Judges

"With time still remaining on the 60-day period that the Fifth Circuit granted the DOL to decide on whether the DOL would appeal the stays granted by two Texas district courts. some decision will need to be made in order to protect the future of the Retirement Security Rule.... [T]he DOL has to look at the bigger picture, the potential for having the courts, specifically SCOTUS, decide the case. The fact that two well-respected federal judge have submitted excellent, well-reasoned opinions supporting the DOL’s process in creating and submitting the Rule cannot be overlooked in projecting the potential outcome before SCOTUS."  MORE >>

The Prudent Investment Adviser Rules

[Opinion]

Litigation Reform, Part 2: Investment Management Fees

"If it is the case that mitigation (via revenue sharing or other rebates) of the 'sticker price' for services can only be taken up after the motion to dismiss and discovery stages, then sponsors and the industry can restructure fee arrangements to avoid possible litigation.... If fiduciaries are to examine all third-party payments with respect to the plan received by any service provider, some policymaker -- e.g., a regulator or Congress -- should say so, in so many words."  MORE >>

October Three Consulting

Benefits in General

[Official Guidance]

Text of IRS Publication 505: Tax Withholding and Estimated Tax, for Use in 2025 (PDF)

45 pages. "What's new for 2025: [1] Retirement savings contribution credit in- come limits increased. In order to claim this credit for 2025, your MAGI must not be more than $39,500 ($79,000 if married filing jointly; $59,250 if head of household).... [2] The maximum adoption credit or exclusion for employer-provided adoption benefits has increased to $17,280. In order to claim either the credit or exclusion, your MAGI must be less than $299,190."  MORE >>

Internal Revenue Service [IRS]

Employee Benefits Jobs

💼

Relationship Manager

ERISA Services Inc.

Remote / Knoxville TN

View job as Relationship Manager for ERISA Services Inc.

💼

Human Resources Analyst II

Sacramento Regional Transit District

CA

View job as Human Resources Analyst II for Sacramento Regional Transit District

Selected New Discussions

Form 5500-EZ - Correction Program

"We have a new 1 person plan who failed to file a Form 5500 despite crossing the $250k threshold that requires it. I was looking at the DFVCP program, but one-person plans don't qualify for it. Is there a correction program for plans that file Form 5500-EZ? Trying to figure out how to get them back in compliance."

BenefitsLink Message Boards

Amend DC Plan to Restrict Eligible Participants

"A customer has had a defined contribution plan for a while, participation is open to all employees if they work the threshold 1000 hours. Now, the customer wants to cut back on who can participate based on their job types. The customer understands it can't change the rules for present employees. But for John Doe who is hired next year in a job classification that will be cut, I'm not sure how the plan can be revised to maintain the present participants and prospectively cut job classes. I've drafted a web of the 1,000 Hour Rule and its implications if not followed; I've looked at non-discrimination rules; I've looked at the general plan amendment rules. I'm stumped. What other rules should I read to figure out this goal? So far it looks like the plan cannot be amended to prohibit future participants based on their job classification, but I have to imagine there is some mechanism that allows it."

BenefitsLink Message Boards

Press Releases

Schechter Benefits Law Group LLP (formerly Butterfield Schechter LLP) Announces Partners' Recognition in 2025 Super Lawyers List

Schechter Benefits Law Group LLP

PCS Selects iJoin to Expand Advisor Access to AMA and Income Solutions

PCS Retirement

John Hancock Retirement Introduces FutureChoice™ to Offer a New Suite of Advisor-Centric Solutions

John Hancock Retirement

October Three Expands O3 PRIME to Address Shortcomings of Corporate Retirement Plans

October Three, LLC

Webcasts and Conferences
(Retirement Plans / Executive Compensation)

New Administration, New Landscape: What’s Ahead for Employers

April 9, 2025 in NY

Davis+Gilbert LLP

Last Issue's Most Popular Items

Text of EBSA Appendix A to PTE 2002-51: Model Notice to Interested Persons for Self-Correction of Delinquent Participant Contributions or Loan Repayments Under VFCP

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

Monitoring the Activities of a Plan Fiduciary Committee: Recommendations to a Board of Directors

Verrill Dana LLP

New Bill Would Require Spousal Consent for 401(k) Distributions

Plan Sponsor Council of America [PSCA]

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

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