FLASHPOINT: FBLC FILES COMMENT LETTERS WITH TREASURY

By: FBLC Staff

On March 14, 2025, Ferenczy Benefits Law Center filed two comment letters, authored by Ilene Ferenczy, Alison Cohen, Adrienne Moore, and S. Derrin Watson, with the Treasury in response to recently issued proposed regulations.  The first letter, available here, discusses issues related to the proposed regulations for Mandatory Automatic Enrollment under Code section 414A.  The second letter, available here, relates to proposed regulations on Catch-up Contribution increases for participants age 60-63 (Code section 414(v)(2)) and next year’s requirement that certain highly paid participants make Catch-up Contributions only on a Roth basis (Code section 414(v)(7)).

“I think it is important that FBLC provide insight to the Treasury about issues raised in proposed regulations that negatively impact either plan formation or plan administration,” said Ilene Ferenczy, FBLC managing partner.  “In addition, there are areas of the rules that are not completely clear, and we really need Treasury to give us standards that our clients can meet on a practical basis with confidence that they are taking proper steps to administer their plans correctly.”

“Both Mandatory Automatic Enrollment and Catch-up Contributions are issues that have a direct impact on how much people save for retirement, so having clear guidance and workable rules is critical to both plan management and retirement security,” added partner Alison Cohen.  “We hope that our comments and those of other practitioners will help Treasury to frame a regulatory structure that is practical and reasonable.”

FBLC is an Atlanta-based law firm that practices exclusively in the employee benefits arena, with a particular emphasis on retirement plans.  More information about the firm is available at www.ferenczylaw.com.