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Automatic Enrollment Communication

What is Changing?

Starting in 2025, most 401(k) and 403(b) plans created after December 29, 2022, will be required to include automatic enrollment as a plan feature. There are limited exceptions to this requirement, including church and governmental plans, plans sponsored by entities that have been in business for fewer than three years; and plans sponsored by employers that “normally employ” no more than 10 employees.
 

What is Required?

Covered plans must implement the automatic enrollment arrangement by the beginning of their 2025 plan year. The arrangement must meet the following requirements:

• Employees are automatically enrolled to contribute between 3% and 10% of their pay.

• The participant contributions will then increase by 1% each year to at least 10% and not more than 15%.

• Employees must have the option to opt out of the plan completely or change their contribution rate.

• The plan must offer employees who are automatically enrolled a period of 90 days to stop contributions and take the automatic contributions out of the plan.

What Options Do I Have?

◦Let us know if you are currently exempt from the mandate.

◦Add an Eligible Automatic Contribution Arrangement to your plan and keep everything else about your current plan design the same.

◦Modify your existing plan design to be a Qualified Automatic Contribution Arrangement safe harbor plan.

Eligible Automatic Contribution Arrangement
(EACA) Only

• Employees may withdraw deferrals in 90 day period

• 3-10% minimum starting auto-deferral, escalation of 1% per year to 10-15%

• Option to opt out

• Notice given when initially eligible and annually thereafter

• Employer contribution is permitted; no required design; may be combined with non-QACA safe harbor

• If combined with non-QACA safe harbor design; safe harbor contributions must be 100% vested

Qualified Automatic Contribution Arrangement
(QACA) Safe Harbor

• Employees may withdraw deferrals in 90 day period

• 3-10% minimum starting auto-deferral, escalation of 1% per year to 10-15%

• Option to opt out

• Notice given when initially eligible and annually thereafter

• Employer contribution may be either 3% nonelective contribution or a match of at least 100% of first 1% deferred plus 50% of next 5% deferred (3.5% match total)

• May impose 2-year vesting schedule on these safe harbor contributions

Attached is the Automatic Enrollment Form.


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ERISA Workplace Retirement Plan Limits

The federal government annually publishes updated qualified retirement plan limits, which impact the contributions, benefit accruals, and compliance of ERISA covered qualified retirement plans. The below tables summarize the most significant changes in recent history.


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