"Plan sponsors should review their plan documents to: [1] implement a 'deemed Roth election' that automatically treats high-earner catch-ups as Roth, [1] specify whether wages from multiple employers in a controlled group or from a common paymaster will be aggregated when determining high-earner status, [3] describe any super catch-up opportunity for individuals aged 60 to 63 and [4] describe any in-plan rollover feature that it may consider as a method of correction."  MORE >>

"As employers and their service providers move into the final stages of implementing the Roth catch-up requirement, [certain] provisions of the final regulations deserve special attention, as they may require changes to the plan document.... The regulations also demonstrate how critical it will be for employers, their legal counsel, and their service providers to coordinate their efforts in order to ensure that the plan document accurately reflects the plan's administration of the Roth catch-up requirement."  MORE >>

"[1] When is the Roth catch-up requirement effective? ... [2] How do employers determine which employees are subject to the Roth catch-up rule? ... [3] What options do [employers] have for implementation? ... [4] What is the impact if a higher earner makes regular deferrals on a Roth basis? ... [5] How are participants with wages from multiple employers treated?"  MORE >>

"[T]he DOL has generally discouraged alternative assets in DC Plans, requiring advisers and sponsors to navigate heightened fiduciary obligations.  The Order marks the beginning of what could be a significant shift in private market and retirement plan investments by enabling plan sponsors to make alternative investments available under ERISA-covered plans."  MORE >>

"In most cases, other vehicles offer superior tax benefits, higher contribution limits and greater portfolio customization. Advisers shouldn't be afraid to make these comparisons. But they need to be very careful if the alternatives they recommend to a Trump Account would earn them fees or other compensation. Doing so in a haphazard way could put them in the SEC's fiduciary crosshairs."  MORE >>

"As of July 2025, [the authors] estimate that there are 31.9 million left-behind or forgotten 401(k) accounts holding approximately $2.1 trillion in assets, up almost 30% from mid-2023. The number of forgotten 401(k)s has almost doubled over the last decade driven by ongoing job switching and layoffs ... Layoffs in the Federal Government have led to growth in the number of left-behind Thrift Savings Plan (TSP) accounts, with almost 3 million TSP accounts now projected to be left behind by the end of 2025."  MORE >>

"72% of private industry workers had access to retirement benefits in March 2025 ... Fifty-nine percent of workers in plans with less than 100 employees could access retirement tools and features ... The findings suggest a push among retirement plan benefits, as more workers press plan sponsors for the features and as employers oblige to attract and retain employees."  MORE >>

"TPAs will have to decide whether to buy, build, or outsource their AI technology.... [T]he speed at which AI enhancements are coming to market may sway the calculus for many TPAs.... Traditional TPAs that underinvested in technology because there wasn't an overriding demand now realize they must embrace automation tools, platforms and systems or be left behind."  MORE >>

"[The] language calling for plan sponsors to become actively involving in making allocation decisions is a definite red flag ... While the Opinion seems to indicate that a plan participant can subsequently revise the percentage chosen by a plan sponsor, the complexity of the product itself and the likelihood of confusion of a plan participant raises numerous fiduciary litigation red flags as to potential litigation."  MORE >>

73 pages. "The Department's primary activities during a lapse in appropriations generally will include work for agencies funded by resources other than the annual appropriations ... EBSA would cease all operations not detailed [on page 10] unless funded via previous years appropriations. Among the specific activities that would cease are our regulatory and research activities, audits, compliance assistance, and IT support not dedicated to excepted activities."  MORE >>

"Section 10301 of the Inflation Reduction Act ... provided supplemental appropriations available through September 30, 2031, for all IRS appropriations accounts. With this funding the IRS will not experience a lapse in appropriations on October 1, 2025, and normal IRS operations will continue.... The IRS Lapse in Appropriations Contingency Plan describes actions and activities for the first five [5] business days following a lapse in appropriations."  MORE >>