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
Many business owners assume that once tax season passes, the opportunity to reduce last year’s tax bill is gone. That’s often not the case. If you filed a tax extension, you still may have time to establish and fund a retirement plan for the prior year and generate meaningful tax deductions .
As we move further into 2026, one thing is clear: retirement plan administration continues to get more complex and more important to get right. This past quarter, we published several articles addressing common (and costly) misconceptions, emerging compliance challenges, and structural issues we’re seeing across plans of all sizes. Below is a quick summary of what you may have missed, along with a few important reminders for the year ahead.
Due to its seasonal nature, the winery industry operates on a business cycle fundamentally different from most other industries. From harvest and tourism season workforce spikes, to fluctuating tasting room staffing, wineries manage a highly variable employee base throughout the year. In addition, many wineries operate across multiple business lines—production, distribution, and retail, for example—often structured as separate legal entities. Aside from the day-to-day operational complexity these factors imply, they also have important and material implications for a winery’s retirement plan(s), primarily from a federal tax perspective. The complexity inherent in the classification of various employee types introduces unique challenges, which we discuss below.