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Retirement Plans Newsletter

November 17, 2025

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💼  5 New Job Opportunities

 

[Guidance Overview]

Should You Send an Annual Notice to Plan Participants for 2025?

"[A] table provides a list of the content and deadlines for the most common notices that plan sponsors may need to distribute. It includes: [1] Traditional Safe Harbor 401(k) Notice; [2] Qualified Automatic Contribution Arrangements (QACA) Notice for a Safe Harbor 401(k); [3] Eligible Automatic Contribution Arrangement (EACA) Notice; [4] Qualified Default Investment Alternative (QDIA) Notice; [5] Non-Safe-Harbor Automatic Contribution Arrangement Notice; [6] Annual participant fee disclosures."  MORE >>

Alston & Bird

[Sponsor]

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[Guidance Overview]

Retirement Plan Amendments and 2025 Year-End Action Items

"[P]lan sponsors that made discretionary changes to their plans during the 2025 plan year should ensure that such amendments are documented in a formal plan amendment before the end of the year.... The general deadline to amend a qualified plan (that is neither a government plan nor a collectively bargained plan) to reflect changes adopted under several recent federal laws (including the SECURE Act, the CARES Act, and SECURE. 2.0) is December 31, 2026."  MORE >>

Alston & Bird

[Guidance Overview]

Preparing for the Roth Catch-Up Contribution Mandate, Part 3

"This article ... explores correction methods available when catch-up contributions for a participant subject to the Roth catch-up contribution mandate are mistakenly made on a pre-tax basis instead of a Roth basis.... A plan is permitted to correct this type of error by distributing the pre-tax elective deferrals that are not catch-up contributions. The final regulations also provide two additional correction methods that allow pre-tax elective deferrals that exceed an applicable limit to be treated as a Roth contribution. "  MORE >>

WTW

[Guidance Overview]

Mandatory Roth Catch-Up Contributions for 2026

"This new development has the potential to directly impact the operation of practically every 401(k) plan in existence.... [A]ny plan sponsor that fails to prepare for this rule change is likely to end up with compliance problems that could have easily been avoided."  MORE >>

Legacy Retirement Solutions

Building a Culture of Compliance: Beyond the 401(k) Plan Audit

"Yes, audits are required by the [DOL] for plans with 100 or more participants with balances. Yes, there are regulatory boxes to check. But there's a deeper reason behind all of it ... Because at the end of the day, a well-run retirement plan isn't just a compliance win. It's a promise kept to your employees. Let's talk about what it means to build a culture of compliance -- and how your annual 401(k) audit fits into that bigger picture."  MORE >>

Cassell Plan Audits

Fiduciary Considerations Following DOL Approval of Lifetime Income Option as QDIA

"It is important for plan fiduciaries to be mindful that a plan's selection of a QDIA must satisfy the QDIA regulation, so selection of a fund offering that is more unique than the typical target date fund may be challenged for not satisfying the regulation's requirements absent specific or broad-based approval by the DOL."  MORE >>

Holland & Hart LLP

What's the Deal with PLESAs?

"According to the Survey of 755 plans, 1.3% said they have a PLESA, 14% are considering adding one and 84.7% said they are not even considering it.... For plans with 1-49 participants, 79.8% said they are not even considering adding a PLESA (3% already have one), and that number rises 90% for plans with 1,000 to 4,999 and 89.2% for plans with 5,000 or more participants."  MORE >>

Plan Sponsor Council of America [PSCA]

Optimizing Retirement Financial Strategies: Integrating Annuities, Defined Contribution Plans, and Long-Term Care Costs

"[The authors] determine how retirees should manage payouts from defined contribution plans to balance trade-offs between consumption and health care cost shocks, using both retirement plan assets and annuitization. [The] analysis explicitly integrates the role of taxes, required minimum distributions, bequest motives, and the possibility of retiree insolvency.... [P]ayout annuities, especially deferred and variable annuities, can be quite valuable for retirees, even when they face health shocks in later life."  MORE >>

National Bureau of Economic Research [NBER]

[Opinion]

Data Wars: Who Controls Your 401(k) Information?

"If data is like oil, then anyone should be able to drill for it, no matter who owns the land. And the driller should not charge even if they incur the costs of refining, storing and shipping.... [T]he reckoning over data is coming between record keepers that want to cross-sell, which may be most, if not all, of them, according to McKinsey, either alone or in partnership with advisors, and advisory firms that have similar ambitions[.]"  MORE >>

Fred Barstein in WealthManagement.com

[Opinion]

Private Equity in 401(k) Target Date Funds Is a Prohibited Transaction

"This report expands and fully develops the legal, economic, regulatory, and fiduciary basis demonstrating that any allocation to Private Equity (PE) or Private Credit (PC) within a 401(k) Target Date Fund (TDF) -- including allocations as small as 1-10% -- renders the entire TDF a prohibited transaction under ERISA Sections 406(a) and 406(b)."  MORE >>

The Commonsense 401(k) Project

[Opinion]

Things to Worry About, Part 26: Pooled Employer Plans and DOL RFI

"[It] would not be a burden if the DOL required that PEPs offer a lineup that satisfied the 404(c) condition of a broad range of investments that would permit participants to construct portfolios that reasonably reflected their risk and return profiles.... Most commentators responded that the DOL should not establish a 'range of total fees'. There are several difficulties with that."  MORE >>

FredReish.com

Benefits in General

[Official Guidance]

IRS Disaster Relief Notice MO-2025-03, for Taxpayers Impacted by Severe Storms, Straight-Line Winds, Tornadoes, and Flooding in Missouri

"[I]ndividuals and businesses in parts of Missouri affected by severe storms, straight-line winds, tornadoes, and flooding that began on March 30, 2025 ... now have until March 30, 2026, to file various federal individual and business tax returns and make tax payments.... [I]ndividuals and households that reside or have a business in Bollinger, Butler, Cape Girardeau, Carter, Cooper, Douglas, Dunklin, Howell, Iron, Madison, Maries, Mississippi, New Madrid, Oregon, Ozark, Pemiscot, Reynolds, Ripley, Scott, Shannon, Ste. Genevieve, Stoddard, Texas, Vernon, Washington, Wayne, and Webster Counties qualify for tax relief."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

2026 Quick Benefit Facts (PDF)

2-page chart includes 2026 limits for qualified retirement plans, IRAs, PBGC, Social Security, and health and fringe benefit plans, along with corresponding limits for 2025 and 2024.  MORE >>

Mercer

AI Collaboration: A Better Path for Benefit Plans Now

"Benefit plans operate in a world where every rule matters, every exception counts and every decision touches someone’s livelihood. ... [F]ull automation isn’t achievable today with the tools currently on the market. And even if it were, it might not be the right move. The smarter, and safer path forward is to use AI as a collaborator, not a replacement."  MORE >>

Segal

Executive Compensation and Nonqualified Plans

[Guidance Overview]

NQDC Participants Affected By 2026 Contribution Limits For Qualified Retirement Plans

"Newly important for planning at year-end 2025 is the impact of the 'One Big Beautiful Bill' Act (OBBBA) ... [which] significantly raised the cap on the state and local tax (SALT) deduction but also phases out the deduction for yearly adjusted gross income (AGI) exceeding $500,000. An income deferral into an NQDC plan could reduce your phaseout in whole or in part."  MORE >>

myNQDC.com

Employee Benefits Jobs

💼

Senior Retirement Analyst

Dunbar, Bender & Zapf, Inc.

Remote / Pittsburgh PA

View job as Senior Retirement Analyst for Dunbar, Bender & Zapf, Inc.

💼

Relationship Manager

Compass

Remote / Stratham NH / Hybrid

View job as Relationship Manager for Compass

💼

Mergers & Acquisition Specialist

Compass

Remote / Stratham NH / Hybrid

View job as Mergers & Acquisition Specialist for Compass

💼

Plan Administrator

My Benefits, LLC

Remote / AL / FL / GA / NC / SC

View job as Plan Administrator for My Benefits, LLC

💼

Retirement Plan Administrator

Leading Retirement Solutions

Remote

View job as Retirement Plan Administrator for Leading Retirement Solutions

Selected New Discussions

Plan Takeover/Merger: Best Practices for Beneficiary Info

"I apologize if this type of question has been answered previously, i could not locate it. Is it best practice to carryforward Beneficiary data from a prior plan during a Plan Merger or Plan Takeover client, or to require all participants to re-enter their Beneficiaries in their new account?"

BenefitsLink® Message Boards

PBGC Letter Received

"A PBGC-covered plan received the following email from the PBGC:

This letter is to inform you that the [PBGC] was notified that a Reportable Event has happened. According to the information we have received, 'A' Corporation (the 'Plan Sponsor') has failed to make the required minimum contributions.'

[1] Who are they referring to when they say they were notified? Who could have notified them? [2] The minimum required contributions that they are referring to are the possible MRC that would be shown on the 5500 (that were not filed for a few years) or are they referring to the PBGC annual premiums that have not been paid?"

BenefitsLink® Message Boards

Last Issue's Most Popular Items

An Explanation of Some 2026 IRS Retirement Plan Limits

American Retirement Association [ARA]

District Court Decision Reveals True Value of ERISA 3(38) Services

WealthManagement.com

Shutdown's Over: IRS Wastes No Time Reminding You You're Still Not Saving Enough, Because Priorities

Seyfarth

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

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