Art of the Qualified Plan Audit

In Summary Counting All Roth Dollars: All Roth contributions a High Earner makes count toward the mandate, regardless of when they are made. This means a participant who contributes a portion of their regular 402(g) limit on a Roth basis might already satisfy the catch-up requirement before their total contributions exceed the 402(g) limit. Plan … Continued

In Summary Roth’s Vision: Senator Roth’s legacy continues through tax-free retirement innovation, as his creation of the Roth IRA in 1997 transformed retirement savings and inspired later Roth-style accounts like Roth 401(k), 403(b), and 457(b). Mandatory Roths Era: Rothification marks a shift toward mandatory after-tax contributions, beginning in 2026 when High Earners must make catch-up … Continued

In Summary Introducing the Super Catch-Up: Effective January 1, 2025, plan sponsors can optionally allow participants aged 60 to 63 to contribute a “super catch-up,” which is 150% of the regular catch-up limit. For 2025, this allows an additional $11,250, bringing the total maximum deferral for this age group to $34,750. Correct Classification: A contribution … Continued

In Summary Deficient Filings vs. Delinquent Filings: During the AICPA conference, the DOL’s Marcus Aron clarified that the department strongly prefers a “deficient” filing (filed on time but incomplete, such as missing an audit) over a “delinquent” filing (not filed at all). A deficient filing can be amended later to include the audit report and … Continued

In Summary Understanding the First RMD and Subsequent Deadlines: Your first Required Minimum Distribution (RMD) is due by April 1 of the year after you turn 73 or, if your plan allows, the year you retire (whichever is later). However, 5% owners must begin by 73 regardless of employment. All subsequent RMDs are due by … Continued

In Summary IRS Notice 2024-73 Clarifies New Part-Time Rules: There are new IRS guidance effective January 1, 2025, which reconciles existing 403(b) plan exclusions with the Long-Term Part-Time (LTPT) rules. Specifically, employees working less than 20 hours per week can be excluded until they meet the LTPT criteria (age 21 with two consecutive years of … Continued

In Summary New Comparability Plans, a Flexible Tool for Business Owners: These are qualified profit-sharing plans that allow employers to divide employees into different groups, or “classes,” to provide different contribution percentages to each. This design is specifically intended to maximize the contributions going to older, higher-paid owners and key employees while providing a more modest, … Continued

In Summary New IRS Guidance for IBO Flexibility: IRS Notice 2024-77 provides flexibility for inadvertent benefit overpayments (IBOs) from retirement plans. It confirms that employers are permitted, but not required, to seek recoupment of funds paid to a participant by mistake. Choosing Not to Recoup Preserves Rollover Status: If a plan sponsor forgives the overpayment, the … Continued

In Summary 403(b) Plan Eligibility: Only specific 501(c)(3) organizations and public education institutions are permitted to sponsor a 403(b) plan. An auditor must verify this tax-exempt status using tools like the IRS’s TEOS and must also obtain and review the executed plan document, adoption agreement, and all amendments to ensure the plan satisfies IRS requirements in … 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