BENEFITS DIGEST

NAPA details the IRA side of the October 22 correction guidance. The new IRA program opens May 1, 2027 with corrections limited at launch to four categories. Three cover service-provider errors, a missed required minimum distribution, the wrong type of account opened, and a distribution or transfer that mishandles an inherited IRA for a nonspouse beneficiary. The fourth covers a 60-day rollover that missed its window where denying a waiver would offend equity or good conscience, including events beyond the individual’s reasonable control. Applications are filed through Pay.gov with a $3,500 fee for single filings before 2028. Rollover-deadline waivers transition out of individual IRS ruling requests, with both routes open during 2027, while the free automatic-waiver and self-certification routes stay available. Self-correction isn’t part of the IRA program at launch, and comments on both revenue procedures are due January 20, 2027.

Sponsors correcting certain automatic-enrollment mistakes get more time to restore missed employer matches under the [updated retirement plan correction procedure](https://www.irs.gov/pub/irs-drop/rp-26-34.pdf). The period deemed reasonable for those corrective matches increases from 6 months to 12 months after the month correct deferrals begin. The October 22 update also incorporates SECURE 2.0’s broader self-correction rules and its treatment of inadvertent overpayments, with exceptions and safeguards that still need to be checked for each error. Separately, the [new IRA correction procedure](https://www.irs.gov/pub/irs-drop/rp-26-33.pdf) opens May 1, 2027 for four specified types of failure, including certain missed required minimum distributions and rollover errors. That program requires an IRS application, generally with a $3,500 fee. Comments on both procedures are due January 20, 2027.

Andy Ives catalogs the required-minimum-distribution errors that keep recurring, including trying to roll over an RMD, aggregating IRA and 401(k) requirements as if they were interchangeable, and assuming an earlier excess withdrawal reduces the next year’s requirement. He also walks through the limits of the still-working exception and the trap in delaying a first age-73 distribution to the following April 1, which puts two taxable distributions into one year. The missed-distribution penalty is 25%, with correction relief available in some cases.

Candace Finn untangles which SECURE and SECURE 2.0 amendments are actually due December 31, 2026, drawing on the IRS’s recent clarification. For required changes, the IRS’s annual amendment list helps determine when the paperwork is due, and a provision does not land on that list until the underlying guidance is settled. The Roth catch-up requirement, for example, is expected on the 2027 list, which would push its amendment deadline out to the end of 2029, and future lists are expected to cover automatic enrollment, long-term part-time employees and remaining required minimum distribution changes. More time to amend the document does not mean more time to comply with the underlying requirement, which applies on its own schedule. Discretionary provisions are the ones still on the 2026 clock. Under Notice 2024-2, optional SECURE 2.0 features a plan already operates, such as Roth employer contributions, generally must be documented by December 31, 2026. Finn’s practical warning is to resist checking every optional box in the amendment package, because a provision the recordkeeper and payroll system cannot administer is a plan document saying one thing while operations say another.

The SECURE Acts raised the statutory required minimum distribution ages to 72 and then 73, but Code section 401(a)(9) sets the latest permissible commencement date, not the plan’s own. A defined benefit plan whose document independently defines its required beginning date as April 1 following age 70 1/2 may keep starting benefits at 70 1/2, a result the preamble to Treasury’s 2024 final RMD regulations confirms directly. The answer lives in the plan document rather than the statute, so check whether yours states its own age or merely incorporates the Code by reference. The amendment clock runs either way; required SECURE amendments, including the technical RMD updates, are generally due by December 31 of this year.

December 31, 2026 is the deadline for most calendar-year retirement plans to document, in a formal amendment, the CARES, SECURE and SECURE 2.0 changes they’ve been operating under, from Roth catch-ups for high earners and long-term part-time eligibility through super catch-ups, higher RMD ages and the optional early-withdrawal provisions. Informal IRS guidance from September 16 suggests some SECURE 2.0 amendment deadlines may slip, but the firm still recommends documenting everything implemented as part of this year-end. The discretionary review is where the litigation lessons show up. The firm suggests forfeiture language that makes the allocation choice a plan-design decision rather than a fiduciary one, claims procedures with limitations and venue provisions, a look at arbitration language, and beneficiary procedures that answer what happens after a divorce or when a beneficiary dies before being paid.

December 31 is the deadline for 2026 required minimum distributions, and this plain-English refresher has two details worth stealing for participant communications. First, the 1959 drafting glitch. SECURE 2.0 assigns people born that year to both age 73 and age 75, and until proposed regulations finalize the fix, the safe answer is 73. Second, the first-year trap. Waiting until April 1 to take a first RMD means two taxable RMDs land in the same year. On inherited accounts, beneficiaries under the 10-year rule generally owe annual withdrawals in years one through nine only when the original owner died on or after his required beginning date, and the IRS’s penalty waiver for those missed annual withdrawals ended after 2024. The missed-RMD excise tax is 25 percent, dropping to 10 with prompt correction.

The deadline depends on what the amendment does. Most plans adopting optional features under SECURE and SECURE 2.0 must update their documents by December 31, 2026. Required changes follow a different schedule tied to IRS guidance and the agency's annual Required Amendments lists, and later deadlines apply to certain union-negotiated plans, governmental plans, and public school 403(b) plans. These are deadlines for updating plan documents, not permission to delay following rules already in effect. One wrinkle from the IRS's September clarification helps sponsors: if the IRS later issues guidance about an optional feature a plan has already adopted, the further amendment implementing that guidance gets its own, later deadline. The IRS expects to issue final regulations on automatic enrollment, long-term part-time workers, and required minimum distributions, and the Roth catch-up requirement is expected to join the 2027 list, pushing that amendment deadline to December 31, 2029.

The question plan sponsors have been asking, answered from the source. Discretionary SECURE and SECURE 2.0 amendments, the features a plan chose to adopt, must be adopted by December 31, 2026, the Notice 2024-2 deadline, now about three and a half months away. Required amendments run on a different clock: generally the end of the second calendar year after the provision lands on the IRS's annual Required Amendments List. Collectively bargained plans, governmental plans and public-school 403(b) plans get later dates. The article also previews what will land on future Required Amendments Lists, including final rules on automatic enrollment, long-term part-time employees and required minimum distributions, each carrying its own two-year amendment window. The task between now and year-end is sorting every adopted feature into the right column.

As the December 31, 2026 deadline approaches for adopting SECURE and SECURE 2.0 amendments, Milliman examines a key decision for defined benefit plan sponsors: whether to retain a required start date for benefit distributions that is earlier than the new later statutory required beginning date for RMDs, which has been raised to age 72, 73, and 75 depending on the participant's birth year.

She passed away last year. I have four sisters, one of whom withdrew her portion last year.

On Friday, July 3, Treasury posted its 2026 regulatory agenda, which includes the following retirement and executive compensation items: Final regulations Required minimum distributions (“RMDs”) as

The US Treasury also posted a rule list that provides SECURE 2.0 guidance including required minimum distributions.