Art of the Qualified Plan Audit

As to Deferral Deposits, Define Timely: As Soon as You Can; ASAP; Chop, Chop; Pronto; What Are You Waiting For?!?! Tell Me What You Want, What You Really, Really Want The timeliness of deferral deposits — a topic that has been beaten to death with a stick and is still the source of discussion at … 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

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

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

  The Internal Revenue Service has announced adjustments on the limitations affecting retirement plans. In particular, participants can now elect to defer up to $23,500 to 401(k), 403(b), and 457(b) Plans in 2025 compared to $23,000 in 2024. Below is a chart that outlines updated employee benefit plan limits: PLAN LIMITS RETIREMENT & SOCIAL SECURITY … Continued

Background The SECURE 2.0 Act’s LTPT rule took effect on January 1, 2023, which means that as of January 1, 2025, any employee who has worked at least 500 hours (but no more than 999 hours) annually for two consecutive years (and has reached age 21 by the end of that two-year period) must be … Continued

Introduction Managing a 401(k) plan involves careful oversight and adherence to regulations set forth by the Department of Labor (DOL). One critical aspect is ensuring timely deposits of employee deferrals into their retirement accounts. However, despite best intentions, mistakes can happen, leading to late deposits. The consequences of such errors can be significant. In this … Continued

Timing Differences Can Make a Difference The number of participants as of the beginning of the year determines whether the plan’s financial statements must be audited. Starting in 2023, eligible participants who do not have an account balance on the first day of the plan year are no longer included in the participant count used … Continued

The Office of the Chief Accountant (OCA) in the Employee Benefit Security Administration (EBSA) of the Department of Labor (DOL) has released a 2023 Audit Quality Study covering the quality of audits being performed by independent qualified public accountants (IQPAs).  This is the fourth study to be performed with prior studies being performed in 2015, … Continued