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Retirement Plans Newsletter
September 15, 2025
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💼 3 New Job Opportunities
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[Guidance Overview]
Final Roth Catch-Up Regs Issued by IRS
"[The final regs] [1] Permit[] an employer that is part of a controlled group or affiliated service group to aggregate
compensation across multiple entities for purposes of determining whether a participant is required to make catch-up contributions on a Roth basis. [2] Clarify[] that a plan offering the age 60-63 catch-up may utilize other permitted practices, including limiting total deferrals to 75% of compensation, without violating the universal availability requirement.... [3] Permit a plan administrator to utilize the correction method until
the last day of the plan year following the close of the plan year for which the excess contribution was made; and [4] Clarify the treatment of in-plan Roth rollover corrections for purposes of plan qualification requirements." MORE >>
American Retirement Association [ARA]
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[Sponsor]
Anticipating Change: Turning Proposed Legislation Into Strategic Insight
Legislation is evolving fast. Discover how upcoming compliance changes can become opportunities for trust and growth—and reach out to see how we can help. Read the full insight.
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[Guidance Overview]
Withholding and Reporting Obligations for Re-Issued Distribution Checks
"Revenue Ruling 2025-15 is consistent with past IRS rulings that have concluded that withholding and reporting obligations
apply at the time a distribution check is distributed to the distributee. This is true even if the check is received but not cashed by the distributee (Revenue Ruling 2019-19) or includes an excess payment that the distributee may be obligated to repay later (Revenue Ruling 2002-84).... [A] number of questions remain regarding plan administrators' obligations when plan participants go
missing or fail to receive the check." MORE >>
Ice Miller LLP
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Arbitration in ERISA Litigation: Supreme Court Declines Review as Circuit Split Persists
"The Supreme Court has twice declined to review ERISA arbitration cases, offering no signal that it plans to resolve the growing appellate divide.... [T]he appellate circuits remain divided on broad applicability of the doctrine. Notably, the Supreme Court has not yet been asked
to weigh in on a decision upholding individual arbitration provisions ... [T]hat opportunity may arise if the Ninth or Eleventh Circuits affirm a recent Central District of California ruling that found individual arbitration requirements enforceable under ERISA Section 502(a)(2)." [Yagy v. Tetra Tech, Inc., No. 24-1394 (C.D. Calif. May 17, 2024)] MORE >>
Polsinelli PC
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Are Plan Sponsors Ready for Roth Catch-Ups?
"The implementation of this provision is extremely complex ... There are many nuances and intricacies that play out depending on the organization's current structure and systems in place ... 44 percent of respondents ... stated they are struggling with
payroll logistics and only five percent are ready to go. Forty percent are still working on it but feel confident they will be ready by January 1st." MORE >>
Plan Sponsor Council of America [PSCA]
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The Rise of Managed Accounts: Are They Right for Your Plan?
"One potential fatal flaw of target-date funds is the one-size-fits-all approach that fails to consider relevant investment criteria like the participant's risk tolerance or investment experience. With managed accounts, portfolios may be tailored to account for these
variables among participants, as well as whether accounts are sufficiently large enough to prudently accommodate wider diversification and alternative assets." MORE >>
PlanPILOT
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Fidelity Reports Almost All Plan Sponsors Lean on Advisers
"More than nine out of ten (92%) plan sponsors work with advisers for consultation and management -- up two percentage points from last year ... While 74% of those who felt participants are saving enough for retirement reported high satisfaction with their advisers, 58%
of those who felt participants are not saving adequately still reported high satisfaction." MORE >>
PLANSPONSOR; registration may be required
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Don't Disinherit Your Grandchildren: Beneficiary Form Risks
"The boilerplate forms provided by financial institutions generally do not handle multigenerational planning well and rarely accommodate the special considerations that arise in second marriages, special-needs situations, minor beneficiaries or those with serious drug or alcohol
problems." MORE >>
Kiplinger
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The Impact of Working at an Employee-Owned Firm and Working from Home on Job Satisfaction
"[J]ob satisfaction is higher for employees in ESOPs than for observationally similar workers in non-ESOP firms and for [work from home (WFH)] workers than for their non-WFH peers.... ESOPs raise satisfaction by increasing worker participation on collective workplace or firm
decisions while WFH raise satisfaction by increasing worker flexibility in their individual work activity.... ESOPs had more extensive WFH than non-ESOP firms during the COVID-19 pandemic." MORE >>
National Bureau of Economic Research [NBER]; purchase required for full paper
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[Opinion]
Public Pensions Need Independent Inspectors General
"Mark Lee Greenblatt who served as Interior Department inspector general, 2019-25 ... opines, 'There's no downside to having independent inspectors general for public pensions.' ... It's no mystery why not a single public pension in America -- not a
single one -- has followed Warren Buffett's sagely advice to invest index funds. Not a single public pension in America -- not a single one -- has outperformed, or even met, the index rate of return. Indeed, it seems there's no downside to looting public pensions. " MORE >>
Edward Siedle
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Benefits in General |
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[Guidance Overview]
Upcoming Key Compliance Deadlines and Reminders for Fourth Quarter 2025
"This period includes several important dates related to health and welfare plans, and timely action and accurate documentation are vital to maintaining compliance and avoiding potential penalties.... [This] fourth quarter guide is categorized by federal and state deadlines in
chronological order, with additional notice requirements due at open enrollment." MORE >>
Lockton
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AI in HR: It's Not About Technology
"AI tech itself isn't the end goal -- better outcomes are. And AI is only one tool ... High-tech has to meet up with high-touch.... Personalization must be redefined to meet people 'in the moment.' ... Remove friction from the benefits
experience." MORE >>
Alight Solutions
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Women Who Earn More Are Less Satisfied With Their Benefits (PDF)
"Creating programs for benefits education and financial literacy based on employee segments such as gender, life stage and income can help companies attract and retain female workers. Employers should consider leveraging AI to develop targeted resources. Doing so would lighten
the burden on HR and save businesses from having to significantly alter their benefits packages." MORE >>
The Standard
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Employee Benefits Jobs
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Selected New Discussions |
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Too Soon to Do Another Fresh Start?
"A cash balance plan had a fresh start effective 01/01/2023 when it had the Cycle 3 restatement. The owner (a physician) wants to know if s/he could do another fresh start to increase the benefit formula in order to increase the tax-deductible limit. Can this be done right away
or should s/he wait/? if s/he needs to wait, how long?"
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The Standard
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Last Issue's Most Popular Items |
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Text of IRS Final Regs: Catch Up Contributions
Internal Revenue Service [IRS]
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Trump Savings Accounts: The Hidden Tax-Reporting Challenge
Morningstar
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Plan Errors Are Inevitable: Is Your Correction Playbook Ready?
Bricker Graydon
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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.
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