4th Quarter Compliance Reminders
August 28, 2024
As we approach the end of 2024, there are plenty of important deadlines to be mindful of. Staying on top of these deadlines contributes to the ongoing compliance of your plan and provides a seamless experience for your employees.
New SECURE Act 2.0 | Long-term part-time employees
Starting in the 2025 plan year, the SECURE Act 2.0 lets part-time employees who've worked at least 500 hours for two consecutive years join the company's 401(k) plan. Here's a quick guide for employers:
- January 1, 2025: Part-time employees who work 500 hours/year for 2 consecutive years are eligible to participate in the company’s 401(k) plan.
- Check your records: Look at your employee data to see who'll be eligible.
- Talk to them: Once you know who's eligible, tell them about their new 401(k) options.
Doing this early helps get your part-time employees smoothly onboard with their new benefits.
Q4 Compliance Highlights*
October 15
- If on extension, filing deadline for the Form 5500
- If on extension, filing deadline for individual and/or corporate tax returns and final contribution deadline for deductibility
- Adopting a retroactive amendment to correct minimum coverage or nondiscrimination requirements (IRC Sections 410(b) & 401(a)(4))
December 1
- Sending annual 401(k) and safe harbor match notice*
- Sending annual Qualified Default Investment Alternative (QDIA) notice*
- Sending annual automatic contribution arrangement notice (ACA)*
- It's important to send these notices at least 30 days (and not more than 90 days) before the beginning of each plan year.
December 15
- If on extension, deadline for distributing SAR to participants*
December 31
- Processing corrective distributions for failed ADP/ACP test to avoid the 10% excise tax
- Correcting a failed ADP/ACP test with qualified nonelective contributions (QNECs)
- Converting existing 401(k) plan to safe harbor non-elective design for current plan year
- Amendment to remove or convert to safe harbor status for next plan year
- Amending plan for discretionary changes implemented during plan year (certain exceptions apply)
- RMDs due under IRC Section 401(a)(9) to avoid penalties
As we wrap up the second quarter of 2026, one trend continues to stand out: retirement plans are becoming increasingly specialized. Whether driven by changing regulations, unique workforce structures, or evolving business goals, employers are finding that a one-size-fits-all approach simply doesn't work. This quarter, we explored the unique retirement plan challenges facing several industries—including medical and dental practices, construction companies, architecture and design firms, wineries, and California employers navigating CalSavers requirements. We also continued our series on the hidden risks of low-quality retirement plan services, highlighting how operational complexity, fragmented accountability, and misaligned incentives can create costs that extend far beyond administrative fees. For employers still evaluating their retirement plan options, we also discussed opportunities that many business owners overlook, including the ability to establish retirement plans after filing a tax extension and potentially generate meaningful tax savings. Below is a recap of the articles we published this quarter. We hope they provide practical insights to help you reduce risk, improve plan performance, and make more informed retirement plan decisions.
When considering retirement plans, employers in the private sector are often focused on designing a compliant plan that meets the needs of their owners and employees. While that process for private sector entities can certainly be complex, nonprofit organizations face an entirely different set of considerations, related to funding, staffing, governance, and organizational structure, to name just a few. From seasonal employees and grant-funded positions, to creative executive retention strategies and legacy retirement programs, to smaller budgets serving a mission, there is so much behind the scenes that can affect a nonprofit organization’s ideal retirement plan. At Primark Benefits, we've worked with nonprofit organizations of all sizes throughout our history, from large institutions with hundreds of participants to small community organizations with fewer than 20 employees. In addition, many members of our management team serve on nonprofit boards across the country for organizations and causes near and dear to their hearts. All that combined experience has validated what makes a retirement plan most successful: understanding the organization itself.
The Mega Backdoor Roth strategy has become one of the most talked-about retirement planning techniques in recent years. Financial publications regularly highlight its potential to help participants contribute far more than the standard deferral limits allow. However, while the strategy can be extremely valuable, an important limitation is often overlooked: due to nondiscrimination testing requirements, some employer-sponsored retirement plans may prevent certain participants from taking full advantage of it. Before assuming a Mega Backdoor Roth will work in your plan, it is important to understand how the strategy operates—and where it can run into trouble.