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Retirement Plans Newsletter
March 20, 2026
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💼 3 New Job Opportunities
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[Guidance Overview]
IRS Postpones Effective Date of Certain RMD Regs
"[P]lan sponsors may wish to use the additional time provided by the delay to coordinate with recordkeepers on system readiness to implement any required or desired changes to address the Delayed RMD Regulatory Provisions. Plan sponsors should also document interim administrative
positions to support reliance on the good-faith compliance standard[.]" MORE >>
Morgan Lewis
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[Guidance Overview]
PBGC Relaunches Opinion Letter Program
"The Program is open to employers, plan sponsors, unions, and supporting practitioners (like lawyers and actuaries).... Submissions to the Program are made electronically.... The Program also includes a searchable database that will serve as a public repository of opinion letters issued by the Office of the General Counsel from 1974 to date." MORE >>
Snell & Wilmer
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[Guidance Overview]
SEC Issues Landmark Digital Asset Guidance
"For businesses operating in or adjacent to the digital asset space, this guidance fundamentally changes the regulatory landscape. The 'regulation by enforcement' era appears to be over, replaced with clear taxonomies and defined pathways for compliance.... The heart of
the SEC's interpretation is a five-category classification system for crypto assets." MORE >>
Fox Rothschild LLP
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Don't Just Sign Your New Adoption Agreement or Amendment
"Recordkeepers tend to do a good job preserving the design of customers' retirement plans during restatement and other update processes. But mistakes do occur, and the significant number of changes being made as part of the CARES/SECURE restatement process may increase the
risk of unintended changes to the written terms of the plan.... [P]lan document updates provide an excellent opportunity to reaffirm that the employer's administrative practices are aligned with the written terms of the plan document." MORE >>
Verrill Dana LLP
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Retirement Plan Options for Public Employers
"This article provides a high-level overview of the most common retirement plan structures used by governmental employers, including defined benefit pension plans, 457(b) deferred compensation plans, 401(a) defined contribution plans, and hybrid approaches that combine elements
of these structures." MORE >>
FosterSwift
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Fidelity Study Finds 'Retirement Age' No Longer Integral to Late-Career Plans
"72% of responding pre-retirees expected to retire on their own terms, up 5 percentage points from last year.... Respondents from younger generations were particularly open to alternative paths ... Overall, 34% of pre-retirees expected to reduce their hours before
retiring, 30% expected to take on fewer responsibilities, and 18% expected to move into freelance or contract work. " MORE >>
PLANADVISER
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Benefits in General |
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How Private Equity Is Reshaping the Benefits and Retirement Landscape
"Over the past decade, private equity has significantly accelerated consolidation across the retirement and benefits industries.... For plan sponsors, the key takeaway is not to avoid PE-backed firms -- but to ensure that evaluation processes remain objective, transparent,
and well documented." MORE >>
Culpepper RFP
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Employee Benefits Jobs
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Selected New Discussions |
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Designating Excess Deferrals in Multiple Plans (402(g) Limit)
"An individual worked for 2 unrelated employers in 2025 and deferred into separate 401k plans. They deferred $15,000 into Plan A and $15,000 into Plan B. They are not catch-up eligible and they need a 402g refund of $6,500. Based on what I am seeing in the regs, the individual
ultimately determines which plan holds the excess. If you go by the last-in, first-out method -- Plan B would issue the refund. But, Plan B has a very generous match and the individual would have to forfeit some of his match if the refund comes from Plan B. Can the individual choose Plan A as holding the excess? Or, can they designate a portion of the excess from Plan A and a portion from Plan B? For example, can they request $3,000 to
be refunded from Plan A and $3,500 refunded from Plan B?"
BenefitsLink® Message Boards
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Last Issue's Most Popular Items |
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DOL Restores ERISA 5-Part Test After Fiduciary Rule Is Vacated
401(k) Specialist
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The New York Secure Choice Registration Deadlines Are Fast Approaching
Jackson Lewis P.C.
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New York State Mandatory Auto-IRA Program
Patterson Belknap Webb & Tyler LLP
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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.
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