If the Deadline for Self-Correcting Retirement Plan Errors Is Indefinite, Why Do I Have to Hurry?

Section 305 of SECURE 2.0 added rules for self-correcting a new category of retirement plan errors under the Employee Plans Compliance Resolution System (“ECPRS”).   Specifically, Section 305 allows an “eligible inadvertent failure” to be self-corrected at any time, even if the error is considered a “significant” operational error under EPCRS. Section 305 provides that the …

Both Employers and Participants Benefit from New IRS Guidance on Correcting Inadvertent Benefit Overpayments

Retirement plan administration mistakes require difficult conversations with participants, especially when the mistake involves an overpayment.  Changes in the law, specifically, SECURE 2.0 and IRS Notice 2024-77, give plan fiduciaries additional flexibility when addressing overpayments. Overpayment of Matching Contributions Consider the case of a 401(k) plan with an employer matching contribution on the first 6% …