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Retirement Plans Newsletter

December 9, 2025

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[Official Guidance]

IRS Employee Plans News: Digital Form 15315, Annual Certification for Multiemployer Defined Benefit Plans

"The IRS Employee Plans recently digitalized Form 15315 to allow you to electronically report the actuarial certification of a multiemployer defined benefit plan's funding status. The Mobile Friendly Forms webpage has a glitch that won't allow you to enter a date beyond Dec. 31, 2025, or plan numbers beginning with 0; for example, 002. Note: The IRS is now accepting Form 15315 certifications by mail, fax or email."  MORE >>

Internal Revenue Service [IRS]

[Guidance Overview]

2025 Required Amendments List Includes SECURE Acts' RMD Changes

"[T]his year's list includes changes to the rules for required minimum distributions (RMDs) made by the [SECURE Act] of 2019 (SECURE 1.0) and certain RMD changes made by the SECURE 2.0 Act of 2022. These provisions now have a plan amendment deadline that is one year later than the deadline that applies to most other SECURE 1.0 and 2.0 provisions."  MORE >>

Mercer

Fourth Circuit Confirms Discretion in QDRO Cost Allocation and Declines ERISA Penalties

"[T]he Fourth Circuit affirmed the district court's judgment finding that the ERISA plan administrator properly interpreted a qualified domestic relations order (QDRO) and correctly calculated the participant's monthly annuity. The court also upheld the denial of statutory penalties for the delayed production of plan documents." [Gasper v. EIDP, Inc., No. 24-1959 (4th Cir. Dec. 8, 2025)]  MORE >>

Roberts Disability Law

401(k) Forfeiture Case Against Northrup Grumman Dismissed

"The plaintiffs contended that the plan documents stated that forfeiture funds should be used to restore participants' accounts or pay down plan expenses before being used to reduce company contributions.... [The judge] wrote that the plan document did not require the company to use forfeiture funds in any specific order. Instead, the employer had discretion to allocate the funds among the three listed purposes as it saw fit." [Garner v. Northrop Grumman Corp., No. 25-0439 (E.D. Va. Dec. 4, 2025)]  MORE >>

PLANADVISER

Fiduciary Rule Update: Fifth Circuit, at DOL's Request, Dismisses Appeal of Stay, and What's Next

"The Fifth Circuit's dismissal of DOL's appeal does not ... make all the problems created by DOL's decades long attempt to change the 1975 rule go away. There remains a set of issues under Prohibited Transaction Exemption 2020-02 Improving Investment Advice for Workers & Retirees, issued in 2020 and subject to litigation in at least two separate district courts."  MORE >>

October Three Consulting

[Sponsor]

Turning Plan Document Review into Actionable Insights - Now Including DB Plans

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), 457(b) and DB plans!

Sponsored by PlanDataAI LLC

Fiduciary Gamechanger: What the Cornell 403(b) Decision Means for You

"More lawsuits will survive motions to dismiss. They'll get past the gate. That means discovery. That means costs. That means plan sponsors and fiduciaries need to be sharper than ever.... [1] Audit all your service-provider contracts.... [2] Ask your advisor: 'When was the last competitive bid?' ... [3] Review your committee and fiduciary process.... [4] Update your disclosures and communications.... [5] Don't ignore the cost. Litigation is expensive.... [6] Consider monitoring litigation risk as part of your fiduciary oversight."  MORE >>

The Rosenbaum Law Firm P.C. via JD Supra

Can an Employer Match Catch-Up Contributions?

"[A] section of your plan document or adoption agreement [should] specifically addresses whether or not catch-up contributions are matched ... [D]epending on your plan design, whether or not you match catch-up contributions may be a moot point, as employees in many plans are able to max out their matching contributions without making catch-up contributions to the plan."  MORE >>

PLANSPONSOR; registration may be required

Workers Turn to Employers for Paycheck-Linked Financial Support

"83% of employees are confident in the financial advice they receive from their employer, and 76% would like their companies to simplify paycheck and benefits choices. This includes 88% of respondents who want to navigate payroll tools as simple as their favorite apps, and 95% who want guidance that integrates debt, savings, benefits, insurance, and retirement planning."  MORE >>

401(k) Specialist

Retirement Plan Design: Bilbo Baggins Finds Safe Harbor in the Shire

"Bilbo lives a quiet, comfortable life in the Shire. He owns a farm and employs several workers ... One day, wanting to show his appreciation for his beloved employees, Bilbo sets up the Bilbo Baggins’s Benefits 401(k) plan (BBB 401(k)). He includes an employer match ... Before Bilbo can dive into the nuts and bolts of plan administration, however, the wizard Gandalf shows up to his house with a rowdy band of dwarves. Before Bilbo knows it, he is whisked away on an epic adventure. Bilbo, a homebody to the core, worries about what will happen to him, his employees, and the BBB 401(k)."  MORE >>

Ferenczy Benefits Law Center

Advisor Authority Study: Gen X Started Saving Late, Is Concerned Savings Won't Last (PDF)

"Six in ten non-retired Gen X investors say they didn't feel their retirement was an urgent priority, rather a distant milestone, until age 50 or older.... After realizing retirement was nearing, 40% of Gen X investors cut discretionary spending, 34% increased their contributions to retirement accounts, 23% sought out professional financial advice, and 19% shifted their investment strategy to reduce risk.... A quarter of Gen X investors say they are concerned their savings won't last more than 14 years, and more than one in ten say their savings are already dwindling."  MORE >>

Nationwide Retirement Institute® and The Harris Poll

The New 'Safe' Retirement Spending Rate: It's Not 4%

"Morningstar's latest 'safe' spending analysis finds people starting retirement in 2026 can spend 3.9% of the portfolio annually. If they embrace flexible spending strategies, the safe rate is as high as 6%. Experts say the latter approach is likely more appealing and appropriate for most retirees."  MORE >>

ThinkAdvisor

Quarterly U.S. Retail Annuity Sales Top $120 Billion for the First Time

"Total U.S. annuity sales increased 5% to $121.2 billion in the third quarter of 2025, marking the eighth consecutive quarter of $100+ billion in sales and setting a new sales record. Year to date (YTD), annuity sales totaled $347.0 billion, up 4% year-over-year, according to LIMRA's U.S. Individual Annuity Sales Survey, which represents 92% of the total U.S. annuity market."  MORE >>

LIMRA

Benefits in General

[Guidance Overview]

Trump Accounts Get First Round of Guidance

"[Notice 2025-68] provides Q&As addressing the various Trump account requirements, along with a number of important clarifications regarding: [1] how the accounts are established, [2] available contribution sources (including the pilot program and employer programs), [3] distribution and investment restrictions, [4] reporting requirements, [and] [5] the (in)applicability of ERISA for employer programs."  MORE >>

Groom Law Group

Advisors Weigh 'Trump Accounts' with Existing UTMA, 529 Account Options

"Beyond accepting the free $1,000 deposit from the government, advisors generally see more upside from existing UTMA (Uniform Transfers to Minors Act) accounts and 529 plans designed to fund education. Both options have higher contributions limits than Trump Accounts and come with different tax structures."  MORE >>

InvestmentNews; subscription may be required

Understanding IRMAA: How to Manage Rising Medicare Costs in 2026

"Medicare beneficiaries with Part B and/or Part D prescription drug coverage may face additional monthly surcharges known as the Income-Related Monthly Adjustment Amount (IRMAA). These surcharges ... are based on modified adjusted gross income (MAGI) from two years prior ... If you're navigating Medicare costs or planning for retirement, this overview can help you understand the impact of IRMAA and the steps you can take to effectively manage your premiums."  MORE >>

Savant

Employee Benefits Jobs

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Senior Plan Administrator

Merkley Retirement Consultants

Remote

View job as Senior Plan Administrator for Merkley Retirement Consultants

Selected New Discussions

Inherited IRAs

"Situation: H had an IRA. H died. W survived. She did not rename the IRA into her name as owner. She did not take any MRDs, even for those years she had reached and passed her RBD. Then, W dies. Her executor has the funds in the IRA moved to an 'estate account' and then, 1/5th each transferred to five new 'inherited IRAs', one each for the five children. How do we resolve the failure by W to take MRDs? Were the funds taxable when transferred from the IRA to the estate account (since estates per se cannot be IRA owners)?"

BenefitsLink® Message Boards

Late ADP Failure Correction

"We are working with a client where we did not process all of the refunds for the failed ADP test by March 15, 2025. The refunds have been done for all but 2 participants out of a total of 50 required to receive refunds. The 2 participants no longer work for the client and the investment company requires the participant signature on the refund form. They will not sign the form. Do we the client deposit a QNEC for the refund amount of those 2 participants?"

BenefitsLink® Message Boards

Press Releases

IRI Announces 2025 Federal Champion of Retirement Security Award Recipients

Insured Retirement Institute [IRI]

IMA Financial Group Appoints Industry Veteran Josie Martinez as Boston Market Leader

IMA Financial Group

Independent Actuarial Review Validates Goodpath Claims Analysis, Showing 32 Percent Reduction in Employer Medical Costs

Goodpath

Vestwell to Acquire Accrue 401k, Becoming the New Home for Nearly 30,000 Guideline Retirement Plans

Vestwell

Webinars, Podcasts and Conferences
(Retirement Plans / Executive Compensation)

Trump Accounts – The Big, Beautiful Announcement

ON-DEMAND WEBINAR

Groom Law Group

ERISA Moments, Episode 32: The 2024 Election and What it Means for Retirement Policy

ON-DEMAND WEBINAR

Faegre Drinker

SECURE 2.0: Updates, Amendments, and Next Steps

January 28, 2026 WEBINAR

TRA [The Retirement Advantage]

Plan Sponsor Institute (PSI) Roundtable

March 25, 2026 in CA

Defined Contribution Institutional Investment Association [DCIIA]

Last Issue's Most Popular Items

PBGC Provides New Filing Options in the PBGC e-Filing Portal

Pension Benefit Guaranty Corporation [PBGC]

Instructions for 2025 IRS Form 5329: Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts (PDF)

Internal Revenue Service [IRS]

Year-End Amendments for 457(b) Plans

Verrill Dana LLP

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

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