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Retirement Plans Newsletter

September 16, 2025

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[Official Guidance]

Text of IRS Notice 2025-47: Weighted Average Interest Rates, Yield Curves, and Segment Rates for September 2025 (PDF)

"This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates ... and the 24-month average segment rates ... [as well as] the interest rate on 30-year Treasury securities ... as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate[.]"  MORE >>

Internal Revenue Service [IRS]

[Sponsor]

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[Guidance Overview]

Final Catch-Up Rules: What Now? (Spoiler Alert: There Is No Extension)

"The much-welcomed final regulations answer a number of open questions ... [1] Designated Roth contributions counted for purposes of Roth catch-up requirement ... [2] Determination of FICA wages -- aggregation of related employers ... [3] Super catch-ups ... [4] Applicability date of rules."  MORE >>

Seyfarth

[Guidance Overview]

Final Regs Issued for Mandatory Roth Catch-Ups for Higher-FICA Wage Participants

"In response to questions about what happens if an individual, who has a Deemed Roth Catch-up Election in place, ceases to be an Affected Participant, the Final Regulations note that such a 'Deemed Election' must cease to apply within a 'reasonable period of time' thereafter. Catch-up contributions that were 'deemed' as Roth contributions before the end of the 'reasonable period of time' do not need to be recharacterized as pre-tax catch-up contributions."  MORE >>

Smith, Gambrell & Russell, LLP

[Guidance Overview]

Final Catch-Up Contribution Regulations under SECURE 2.0 Act

"The final regulations maintain the rule that MRC status is determined solely based on the employer and not on a controlled group basis.... The final regulations retain the exception to the universal availability requirement so that catch-up contributions of Puerto Rico participants can be limited by the Puerto Rico tax code."  MORE >>

Kilpatrick Townsend

[Guidance Overview]

Executive Orders, Private Funds, and Fiduciary Standards, Part 4

"This article focuses on the DOL's guidance in a 2020 Information Letter ... on the inclusion of private equity in 401(k) plans. The discussion in that Information Letter ... is foundational for any guidance that will be issued by the DOL in response to [Executive Order 14330]."  MORE >>

FredReish.com

[Sponsor]

Turning Plan Document Review into Actionable Insights

PlanPort revolutionizes how advisors, recordkeepers, and TPAs use retirement plan documents across their business operations –- delivering efficiency, accuracy, review, and automation like never before. Now supporting 403(b) and 457(b) plans!

Sponsored by PlanDataAI LLC

What Happens After the 401(k) Audit?

"[1] Attach the audit to your Form 5500 ... [2] Review the audit results with your plan committee ... [3] Address internal control recommendations ... [4] Document any corrections made during the audit ... [5] Use the findings to prepare for next year."  MORE >>

Cassell Plan Audits

Survey Finds Retirement Plan Sponsors Are Bracing for Volatility and Looking to Active Management

"More than half of US retirement plan sponsors -- 53% -- expect that the next 12 months will be more volatile than 2022 and early 2023, a period that saw the return of inflation. Forty-one percent anticipate the next year could be even more volatile than the Global Financial Crisis. The top macroeconomic concerns for respondents were tariffs and protectionist trade policies (83%), an economic downturn (60%) and higher inflation (57%).... 51% of the plans now rank portfolio resilience as their top investment priority."  MORE >>

National Conference on Public Employee Retirement Systems [NCPERS]

Cutting the Cost of Delayed Retirement with an Employee-First Strategy

"[It] costs an average of $103,000 each year in added compensation and benefits when an employee works past age 65. For employers with a sizeable population over that age, the impact can reach millions annually.... [Plan sponsors] can purposefully design plans to help improve retirement readiness -- reducing the financial strain of delayed retirement and supporting employees in retiring on their own terms."  MORE >>

Principal Financial Group

Non-Governmental 457(b) Plans Provide Increased Deferral Opportunities for Key Employees of Nonprofit Organizations

"Nongovernmental Code section 457(b) plans are a simple way for nonprofits to offer key employees a way to defer compensation in excess of the limits under their organizations' section 403(b) or 401(k) plan. For larger nonprofits, a section 457(b) plan is frequently offered in conjunction with an individually tailored, separate Code section 457(f) plan to attract and retain key employees."  MORE >>

EisnerAmper

[Opinion]

ERISA 404(A) vs. NAIC Rule 275: Ticking Fiduciary Litigation/Liability Time Bomb for Plan Sponsors

"[T]he Achilles' heel that ERISA plaintiff attorneys should focus on is the obvious inconsistency of the standards between ERISA 404(a) and NAIC rule 275 and the potential fiduciary liability that exists, liability which is going to completely blindside many plan sponsors ... Investment fiduciaries who receive a recommendation to include an annuity, any type of annuity, should always require the annuity salesperson to provide a written, properly prepared breakeven analysis on the annuity being recommended."  MORE >>

The Prudent Investment Adviser Rules

Benefits in General

DOL Has Stepped Into Morgan Stanley's Legal Battle

"For wealth advisors and RIAs, the implications of this ongoing dispute extend beyond the legal maneuvers. Deferred compensation remains a powerful retention tool across the wirehouse and brokerage landscape ... If courts or regulators were to determine that such programs fall under ERISA, it could significantly alter how firms structure advisor pay, adding compliance burdens and limiting forfeiture provisions that firms rely on to retain talent." [DOL Advisory Opinion 2025-03AO'Neill v. Morgan Stanley, No. 24-00358 (FINRA Aug. 8, 2025)]  MORE >>

WealthAdvisor

Employee Benefits Jobs

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Retirement Plan Administrator

Retirement Solutions Specialists

Remote / Jacksonville FL

View job as Retirement Plan Administrator for Retirement Solutions Specialists

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Manager of Administration

The Pension Source

Remote / Stuart FL / Abilene TX / Nashville TN / Hybrid

View job as Manager of Administration for The Pension Source

Press Releases

Congruent Solutions and LeafHouse Announce Strategic Partnership to Automate Fund Performance & Factsheets integration

Congruent

SEC Announces Four New Members of Investor Advisory Committee

Securities and Exchange Commission [SEC]

Last Issue's Most Popular Items

Text of IRS Final Regs: Catch Up Contributions

Internal Revenue Service [IRS]

Final Roth Catch-Up Regs Issued by IRS

American Retirement Association [ARA]

Are Plan Sponsors Ready for Roth Catch-Ups?

Plan Sponsor Council of America [PSCA]

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

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