Art of the Qualified Plan Audit

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

Non Safe-Harbor Hardship Approvals: Warning: Employer Discretion Could be Ill-Advised A Bleeding Heart The phrase bleeding heart is used to describe one who shows excessive sympathy for another’s misfortune. Every year, we get phone calls from clients who want to help employees out of a financial bind. This emergency is not on the list of … Continued

Background: Definition of Catch-Up Contributions Individuals who are age 50 or over at the end of the calendar year can make annual catch-up contributions to their 401(k), 403(b), and governmental 457(b) plans in the amount of $7,500 in 2023 and 2024. By definition, catch-up contributions must be contributed IN ADDITION to the lesser of:   … Continued

403(b)-Specific IQPA Audit Considerations Let’s start with a little background. Code Section 403(b) came first. In 1958, Congress made available a tax deferred savings device for employees of certain section 501(c)(3) organizations by adding section 403(b) to the Internal Revenue Code. Although deferred compensation plans for municipal employers had already existed for over a decade, … Continued