FuturePlan ERISA Team

The IRS has issued Notice 2024-3, which contains the 2023 cumulative list of changes in requirements that must be taken into account by drafters of pre-approved defined contribution retirement plan documents for the fourth remedial amendment cycle (Cycle 4).

The IRS has released Notice 2024-2, Miscellaneous Changes Under the SECURE 2.0 Act of 2022. The so-called “Grab Bag” Notice provides guidance to multiple provisions of the SECURE 2.0 Act of 2022.

The IRS has released final regulations that provide de minimis error safe harbor exceptions to penalties for failure to file correct information returns or furnish correct payee statements.

The IRS has issued Revenue Ruling 2024-1, containing the covered compensation tables for the 2024 plan year. These tables are used in calculations for defined benefit pension plans when permitted disparity, sometimes called integration, is used in determining employer-provided benefits.

The Internal Revenue Service (IRS) has issued Notice 2024-04, which contains updated guidance on factors used in certain defined benefit (DB) pension plan minimum funding and present value calculations. 

The IRS has issued Revenue Ruling 2024-02, which contains the applicable federal rates (AFR) for January 2024. These rates are used for such purposes as calculating distributions from retirement savings arrangements that meet the requirements for substantially equal periodic payments (a 10 percent early distribution penalty tax exception), also referred to as "72(t) payments."

The SECURE 2.0 Act has shortened the time necessary to allow part-time workers access to 401(k) plans. 

Two Department of Labor (DOL) regulatory actions have been removed from the Office of Management and Budget’s list for review, signaling they may be released soon.

The Internal Revenue Service (IRS) has released a proposed regulation reflecting statutory changes related to long-term, part-time (LTPT) employees made by the SECURE Act of 2019 (SECURE Act) and the SECURE 2.0 Act of 2022 (SECURE 2.0). This proposed regulation would amend Treasury Regulation (Treas. Reg.) 1.401(k)-5 to reflect the rules for LTPT employees, including specific eligibility and vesting requirements. The proposed regulation also provides guidance regarding employer contributions with respect to LTPT employees and the impact that LTPT employees will have on nondiscrimination, coverage testing, and top-heavy benefits.

The Senate and House committees of jurisdiction have released a draft containing technical corrections and other clarifications to SECURE 2.0.