Art of the Qualified Plan Audit

Posted by Maria T. Hurd, CPA, RPA As we discussed in our blog “Delaware’s Senator Roth and his Roth Account Legacy,” about 93% of 401(k), 403(b), and 457(b) plans offer a Roth deferral option, up from 62% a decade ago. The Roth 401(k) option became available at the beginning of 2006, while the traditional 401(k) … Continued

First Steps Toward Rothification: the Roth Catch-up Requirement for High Earners As we explained in our previous blog, Delaware’s Senator Roth and his Roth Account Legacy, Rothification refers to a policy shift requiring the use of Roth after-tax contributions or accounts. The Setting Every Community Up for Retirement Enhancement Act (SECURE) 2.0 may very well … Continued

Being from Delaware, I remember Senator Roth, the lone U.S. Representative from Delaware, and his two giant St. Bernards walking down Market Street, greeting all his constituents. Who knew that this affable man would leave behind a legacy that will benefit millions of people for generations to come? At the age of 76, he created … Continued

…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

Updated February 28, 2025 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, … 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