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Automatic Enrollment/Escalation—Is My Plan Grandfathered?

We knew it was coming—some type of auto enrollment and auto escalation mandate for 401(k) and 403(b) plans. Congress has long been a proponent of such automatic arrangements as they have proven they boost plan participation. The first “negative election” plans go back 25 years…

Partial Plan Termination and the Applicable Period Case Study

An advisor in Ohio asked: “My client suffered an accident and cannot keep employees on at his business. He was wondering if he could lay off employees over time to avoid triggering full vesting for a partial plan termination?” Here’s What We Know The IRS…

When Does a 401(k) Deferral Become a Catch-Up Contribution?

A recent call with an advisor involved a question on 401(k) catch-up contributions. The advisor asked: “When does a 401(k) deferral become a catch-up contribution?” An employee salary deferral becomes a catch-up contribution when it exceeds the lowest of the following three limits (See Treasury…

Who’s the Plan Administrator?

In a merger and acquisition (M&A) situation, where the acquiring organization does not assume the seller’s retirement plan, what is something that the selling company often overlooks with respect to its retirement plan? M&A scenarios are notorious for treating retirement plans as an after-thought. Because…

There’s More to Love About Qualified Charitable Distributions in 2023

Our consultants regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings plans. Recently we received a call from a financial advisor who asked: “Can you summarize the rules and

Best Practices for After-Tax Contributions and IRS Form W-2

Pentegra recently received a question from a financial advisor who asked: “My client has made non-Roth, after-tax contributions to his 401(k) plan for 2023. Will those amounts be reported on his Form W-2 and, if so, where?” The answer to the first part of the…

IRS SECURE 2.0 “Grab Bag” Guidance – Roth Employer Contributions

On December 20, 2023, the IRS released Notice 2024-02, “Grab Bag” guidance on certain provisions of SECURE 2.0 in the form of Frequently Asked Questions (FAQs). Let’s begin with the guidance released around employer Roth contributions. Optional treatment of employer contributions or nonelective contributions as…

IRS SECURE 2.0 “Grab Bag” Guidance – Cash Balance Plans

This is the second article on the recent IRS “Grab Bag” guidance on provisions of SECURE 2.0 (Notice 2024-02). Let’s dive into the guidance on SECURE 2.0’s cash balance provision. To start with the bottom line: The Grab Bag guidance will generally allow plans that…

IRS SECURE 2.0 “Grab Bag” Guidance – Other Issues

This is the last of the articles on recent IRS “Grab Bag” guidance on certain provisions of SECURE 2.0 (Notice 2024-02). In this article, we’ll cover certain other guidance included in the “Grab Bag” relevant to qualified retirement plans: SECURE 2.0’s new automatic enrollment requirement;…