Art of the Qualified Plan Audit

…a Lot to Catch Up About Effective January 1, 2025, plan sponsors can opt to add a plan provision to allow participants who are between the ages of 60 and 63 at the end of 2025 (and subsequent years) to contribute an additional catch-up contribution…a super catch-up. For 401(k) and 403(b) plans, the super catch-up … Continued

The DOL Update at the AICPA Conference At the AICPA National Conference, the DOL Update was presented by Marcus Aron, the Chief of the Division of Accounting Services at the Office of the Chief Accountant (OCA) of the Employee Benefit Security Administration (EBSA), with an impromptu guest appearance from Scott Albert, who heads up the … Continued

When is the First RMD due (the Required Beginning Date-RBD)? The first RMD must be taken by April 1 of year following the later of the year the participant turns 73 or the year of retirement (if allowed by the plan). Employees must be separated from service to be considered retired, such that employees who … Continued

On October 2, 2024, the IRS released Notice 2024-73, which gave us long awaited guidance on the interplay between the historically permitted exclusions from participation available to 403(b) plans and the LTPT rules scheduled to become effective on 1/1/2025 for 403(b) plans covered by ERISA. This guidance corroborates many of our predictions in our original … Continued

New comparability plans are qualified defined contribution plans that allow an employer to allocate different profit-sharing contribution percentages to different groups of employees at the employer’s discretion. These plans are subject to complicated discrimination tests that take into account the equivalent benefit at retirement of the current contribution allocated to each participant. Specifically, new comparability … Continued

October 15th: The Gift that Keeps on Giving… As if we didn’t have enough to celebrate on October 15th, the final deadline to attach our financial statement audits to calendar year Form 5500 filings, the IRS issued Notice 2024-77 to provide welcome guidance on inadvertent overpayments. Oops! I Did It Again, I Paid You Too … Continued

Updated October 29, 2024 Every Independent Qualified Public Accountant (IQPA)’s retirement plan audit is different. There are countless iterations of service providers, plan formulas, payroll companies, investment philosophies, and internal control setups that must be considered when designing an audit plan. There are many audit considerations that are specific 403(b) plans that plan auditors must … Continued

How Does the 403(b) Special 15-Year Catch-Up Contribution Work? Where have you worked, for how long, and how much have you contributed to the 403(b) plan? These are all questions that make up the puzzle pieces necessary to compute each participant’s available 403(b) catch-up. Participants in a 403(b) plan can make an additional contribution once … Continued

The Basics of the True-Up Match Employers that give substantial bonuses tend to give their employees the opportunity to contribute the maximum 401(k) or 403(b) deferral amount out of their bonus pay. To ensure that employees who take advantage of this flexibility get the maximum match, the employers have to make sure that their plan … Continued

No Good Deed Goes Unpunished The protagonist of our previous blog, Non Safe-Harbor Hardship Approvals: Warning: Employer Discretion Could be Ill-Advised, was Mr. Bleeding Heart, an employer who wants to help employees in a financial bind at all costs, which led him to authorize several hardship distributions that were not permitted by the plan document’s … Continued