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Should a Plan Have an Investment Policy Statement?

To be clear; a retirement plan is not required to have an Investment Policy Statement (IPS). But the more important question is should a plan have an IPS? To use a silly analogy, a person need not have a parachute to jump out of an…

Fixing What Others Fear

No surprises. That is the objective plan sponsors should strive for when it comes to managing a retirement plan. With all the moving parts associated with retirement plan administration, it’s easy to miss things. The reality is that mistakes can and do happen, and when…

After Tax Contribution Considerations

Pentegra administers many 401(k) plans that include standard after-tax contributions—the non-designated Roth 401(k) type. And one thing we have learned is that after-tax contributions can create problems for the sponsor if the plan is not carefully designed and properly administrated. In a 401(k) plan, standard…

Plan Penalties, Costs and 3(16)

The Department of Labor (DOL), Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) have extensive reporting and disclosure requirements for qualified retirement plan officials. These reporting and disclosure requirements serve the important function of educating and supporting participants in their retirement planning journey,…

Automatic Enrollment/Escalation—Is My Plan Grandfathered?

We knew it was coming—some type of auto enrollment and auto escalation mandate for 401(k) and 403(b) plans. Congress has long been a proponent of such automatic arrangements as they have proven they boost plan participation. The first “negative election” plans go back 25 years…

New RMD Rules to Live By

Just when we had figured out the required minimum distributions (RMDs) rules for retirement plan participants—Congress changed them—again! Under the SECURE Act 2.0 of 2022 (SECURE 2.0) there are no less than six changes to RMDs in all. The most talked about adjustment to the…

SIMPLE IRA-to-401(k) Mid-Year Switch Gets Easier in 2024

A frequently asked question by small business owners who sponsor savings incentive match plans for employees (SIMPLE) IRA plans is, “Can I terminate my SIMPLE IRA plan and start a 401(k) plan mid-year?” It’s a straightforward question that, currently, has a problematic answer due to…

Partial Plan Termination and the Applicable Period Case Study

An advisor in Ohio asked: “My client suffered an accident and cannot keep employees on at his business. He was wondering if he could lay off employees over time to avoid triggering full vesting for a partial plan termination?” Here’s What We Know The IRS…

When Does a 401(k) Deferral Become a Catch-Up Contribution?

A recent call with an advisor involved a question on 401(k) catch-up contributions. The advisor asked: “When does a 401(k) deferral become a catch-up contribution?” An employee salary deferral becomes a catch-up contribution when it exceeds the lowest of the following three limits (See Treasury…