Compliance Corner: Q3 2026
Upcoming Deadlines
Our calendar year plans should have completed annual 2025 plan administration and electronically filed Form 5500 (or are preparing to do so this month). If you have received correspondence from H&S regarding any outstanding action items you should respond immediately to make sure all required filings are made on time. If you are considering changes to your plan for the 2027 plan year it is not too late, but the deadline is rapidly approaching for plans that wish to adopt or modify a safe harbor design prior to the start of the 2027 plan year. If you have questions about potential changes to your plan please reach out to your H&S Plan Consultant.
Upcoming compliance deadlines for calendar year plans:
October 15th - Contribution deadline for deductibility in 2025 tax year for C-Corps and sole proprietorships (or LLCs taxed as such). Extended deadline for filing the 2025 Form 5500 on extension.
December 1st - Deadline to provide annual safe harbor/QDIA/automatic enrollment notices for 2027 plan year. Notice to participants for an existing plan is generally required at least 30 days prior to the start of the following plan year.
December 31st – Deadline for corrective distributions to participants with 10% excise tax paid by the employer. Deadline for most existing plans to adopt the SECURE 2.0 Interim Amendment.
SECURE 2.0 Interim Amendments
Over the next several weeks, Hunnex & Shoemaker will send out the required Interim Amendment to Plan Sponsors. The Interim Amendment reflects changes to the plan document mandated by the IRS as a result of the SECURE 2.0 Act of 2022. Most plans must adopt this amendment by December 31, 2026. The Interim Amendment formally adopts into the plan the provisions your plan has already been operating under or will operate under for future years. The Interim Amendment will include our recommended default elections for each optional provision. If the defaults suit your plan, no signature or action is needed other than distributing a Summary of Material Modification. In all cases, the Interim Amendment should reflect the actual operations of the Plan.
Please review the Interim Amendment materials carefully when they arrive and contact your H&S Plan Consultant with any questions about which elections are right for your plan. If you would like to choose elections other than the defaults please let us know by the deadline in your Interim Amendment package.
Overview of SECURE 2.0 Changes
SECURE 2.0 is a broad retirement reform law that made several required changes to qualified plans, including:
• The age at which required minimum distributions must begin increased to 73 (rising to 75 in 2033), and pre-death required distributions from Roth accounts held within a plan were eliminated;
• Long-term, part-time employees who work at least 500 hours in two consecutive years must have the opportunity to make elective deferrals;
• Beginning in 2026, participants whose prior-year FICA wages exceed an indexed threshold ($150,000 for 2026) must make any catch-up contributions on a Roth basis; and
• Most new 401(k) and 403(b) plans established after December 29, 2022, must also include automatic enrollment.
In addition to certain required changes, SECURE 2.0 also includes a number of new elections that a Plan Sponsor can make, if supported by your recordkeeping provider, including:
• Ability for Participants age 60 through 63 can make higher catch-up contributions;
• Option for Participants to designate employer contributions as Roth;
• Participants may receive matching contributions based on certain qualifying student loan payments;
• Plans can offer new penalty-free distributions for emergency personal expenses (up to $1,000 per year), victims of domestic abuse, terminal illness, and federally declared disasters;
• Plans may allow participants to self-certify hardship withdrawals; and
• Limit for automatic cash-out of small balances may increase from $5,000 to $7,000.
SECURE 2.0 includes over ninety changes so a complete description is beyond the scope of this Compliance Corner. The Interim Amendment package will include a list of default elections. For plans that have already communicated an intent to adopt an optional provision the Interim Amendment package for those plans will include those elections and require a signature from the Plan Sponsor.
Partner Spotlight
In a new addition to Compliance Corner, we have dedicated some space prior to the start of the next plan year to introduce two service providers that we regularly work with that offer services designed to ease the administrative burden of plan operations. Many of our Plan Sponsors are familiar with these providers for payroll reporting and plan notice requirements but if not, we encourage our Plan Sponsors to take a look at the services described below.
Dynamis
Hunnex & Shoemaker was one of the earliest adopters of Dynamis, a payroll data automation platform built specifically for the retirement plan industry. Dynamis provides Payroll Data Automation Services that create a secure, authorized connection between an employer’s payroll system and Hunnex & Shoemaker. Once connected, Dynamis provides ongoing access to the payroll data needed for census collection, compliance testing, participant eligibility tracking, compensation analysis, and other retirement plan administration functions.
For Employers, that means less time downloading reports, formatting spreadsheets, responding to data requests, and tracking down information at census time. For our Team, it means earlier access to more complete, accurate data and fewer hours spent on the manual work of collecting and preparing it.
“We love working with Hunnex & Shoemaker because they’re constantly looking for innovative ways to advance their business. That commitment to improving the experience for both clients and employees is what makes H&S such a great partner.” - Karim Lessard, Dynamis CEO
Dynamis’ motto is “Ensuring TPAs do more of what matters.” Retirement plans are complex. They require experienced professionals who understand the regulations, recognize when something doesn’t look right, anticipate potential issues, and help employers navigate the decisions that come with managing a plan. By automating more of the administrative work behind the scenes, our team can devote more time to proactive client support, thoughtful guidance, and the personal relationships that have always been central to how Dynamis and Hunnex & Shoemaker both serve their clients.
Technology gives us better tools. The value comes from what our people are able to do with them—and our partnership with Dynamis helps the Hunnex & Shoemaker team spend more time doing what matters most: serving our clients.
Ready to spend less time on payroll data? See if your payroll provider connects with Dynamis Integrated Payroll Providers, then ask your Hunnex & Shoemaker Plan Consultant about getting connected. Click here to learn more about Dynamis. Be sure to get signed by December 1st , 2026 so your 2026 annual census data will be ready for year end administration by January 2027!
Plan Notice
Retirement plan notices help employees understand their benefits, fees, and plan provisions or changes. As a plan sponsor, you are responsible for making sure the required notices are properly distributed to the appropriate people. Some notices are prepared by Hunnex & Shoemaker; others come from your recordkeeper. While certain notices are sent directly to participants, others are provided to you for distribution. Knowing who handles each notice helps ensure nothing is missed.
These responsibilities extend beyond employees currently contributing to the plan. Depending on the notice, former employees with account balances and eligible employees who have not enrolled may also need to receive it. Accurate participant information is essential, along with a delivery process that follows applicable requirements. Electronic delivery has specific regulatory rules, and some recipients may need paper notices.
Documentation is another important part of that process. Keep records of what was sent, to whom, when, and how unsuccessful deliveries were addressed. Returned mail and undeliverable emails may signal outdated contact information and a need to locate a participant. A documented missing participant process guided by Department of Labor best practices helps demonstrate the steps taken if your plan faces a compliance review or audit.
To simplify this work, Hunnex & Shoemaker has partnered with Plan Notice, a company specializing in retirement plan notice management and delivery. This voluntary service works with us and your recordkeeper to gather participant information, distribute covered notices, and document the work in an online portal. It supports your annual notice package and covered notices throughout the year, including management of undeliverable emails and returned mail. Optional participant location searches require your approval and an additional fee.
Your team has fewer mailings to coordinate, less information to gather, and one place to see the work completed. Plan Notice also provides indemnification for the work it performs under its service agreement.
Click here to learn more about the service, review annual pricing, and enroll your plan.
Disclaimer: This content is for informational purposes only and does not constitute legal, tax, or financial advice.
** This article contains an advertisement for Dynamis and Plan Notice. Dynamis and Plan Notice are not affiliated with Hunnex & Shoemaker. The inclusion of information related to the services of Dynamis and Plan Notice is not an endorsement or recommendation by H&S, and H&S makes no representations regarding, and assumes no liability for, any services provided by any third-party provider. Plan fiduciaries should perform their own due diligence before selecting any service provider. Please refer to the fee disclosures for such service providers regarding cost of services and any associated fees.
Written by: Sam Dart, on behalf of Hunnex & Shoemaker