"The IRS considers it to be an operational failure if forfeitures remain unused beyond the 12-month deadline.... [T]he proposed regs provide transitional relief for old forfeiture balances. For any forfeitures incurred during any plan year that begins before January 1, 2024, the IRS will treat those forfeitures as having been incurred in the first plan year that begins on or after January 1, 2024."  MORE >>

"The two model notices have significant differences from the prior model that go beyond incorporating the changes made by section 343 of the SECURE 2.0 Act. For example, the introductory language has been significantly revised. Plan administrators may want to consider whether they should adopt the new model notices right away or whether any notice that was about to be sent would be a reasonable alternative taking into account the latest guidance."  MORE >>

"Congress revised the statutory framework for AFNs through SECURE 2.0, prompting new compliance challenges for plan sponsors. [FAB 2025-02] is intended to clarify the act's compliance expectations for AFNs beginning this year."  MORE >>

42 pages. "To help employers and plan sponsors understand the legislation's implications, this guide provides a high-level summary of SECURE 2.0 provisions grouped topically, including separate treatment of provisions specific to DC and DB plans. The six tables in this guide describe statutory changes and their effective dates, identify whether the changes are mandatory or optional for employers, and provide observations, including implementation challenges."  MORE >>

"Safe harbor 401(k) plans have special rules that apply when amending the plan, and certain provisions cannot be modified in the middle of a plan year.... Generally speaking, a plan amendment that is more generous to all eligible employees is permitted to be made mid-year without affecting the safe harbor 401(k) status of the plan."  MORE >>

"[T]he district court acknowledged that American Airline's plans paid low rates for investment management fees, and focused instead on the relationship between American Airlines and BlackRock, and BlackRock's ESG policies for proxy voting.... [T]he Court found American Airlines acted prudently in selecting and maintaining BlackRock as its investment manager, but also found that it (counterintuitively) acted disloyally by allowing its own corporate interests to affect its fiduciary role in monitoring BlackRock." [Spence v. Am. Airlines, Inc., No. 23-0552 (N.D. Tex. Jan. 10, 2025)]  MORE >>

"[This article provides] a sample checklist of documentation needed for a 401(k) or 403(b) plan audit.... [M]any of the items will be provided by the plan's third-party administrator or recordkeeper ... As a first step, you should authorize view-only access to the plan's webstation for your auditor. Direct access to the webstation will streamline the process, allowing your auditor the ability to directly download or request the necessary reports from your recordkeeper,[.]"  MORE >>

17 pages. "Next steps in increasing the availability of in-plan lifetime income solutions: ... [1] Encourage industry consensus and consistent labeling of in-plan lifetime income solutions as a distinct asset class for clearer comparisons.... [2] [D]evelop a more expansive and detailed safe harbor that considers varied and innovative designs and specifies how plan sponsors can satisfy their fiduciary obligations when adding lifetime income solutions.... [3] Provide straightforward, accessible materials that clearly explain in-plan lifetime income products to plan sponsors and plan participants."  MORE >>

"The funded status of the 100 largest U.S. corporate defined benefit pension plans fell by $7 billion during March ... As of March 31, the PFI funded ratio dropped to 104.1%, from 104.6% at the end of February. March's decline concludes a down first quarter of 2025 that saw a net $8 billion drop in funded status."  MORE >>

"[U]nexpected medical expenses and long-term healthcare costs are two of the most common threats to a solid financial plan.... Consider an HDHP over a PPO to stash additional savings ... Max out your HSA ... It's okay to touch an emergency fund for healthcare costs ... Get to know your benefits package and be aware of wellness programs."  MORE >>

"When negotiating a compensation arrangement, nonprofit organizations that are tax‑exempt under Section 501(c)(3), (4), or (29) should be aware of the potential for triggering an excess benefit transaction that may be subject to excise taxes under Section 4958 of the Internal Revenue Code, known as 'intermediate sanctions.'"  MORE >>