2024 Required Amendments List Issued, Notice 2024-82

The IRS has issued its 2024 Required Amendments List (2024 RA List) for individually designed employee retirement plans. RA Lists apply to both Code Secs. 401(a) and 403(b) individually designed plans.

Required Amendments for 2024

The entries listing changes in qualification requirements on the 2024 RA List are:

• Rural electric cooperative plans no longer apply compensation-based limits for non-highly compensated employees under Code Sec. 415(b)(12).
• Ownership attribution rules are updated to exclude automatic attribution between spouses with separate businesses in community property states and revise parent-child ownership rules.
• Optional waivers for 2020 Required Minimum Distributions (RMDs) must comply with guidance in Notices 2020-51, 2023-54, and 2024-35.
• Plans can permit qualified birth or adoption distributions as per SECURE Act Section 113 and Notice 2020-68.
• Ownership attribution rules are updated to exclude automatic attribution between spouses and revise parent-child ownership rules.
• The Miners Act reduces the minimum age for allowable in-service distributions, requiring plan updates if adopted.
• The SECURE Act increases the automatic enrolment cap for safe harbor Code Sec. 401(k) plans, with guidance in Notice 2020-86.
• Repayment for birth or adoption distributions is now limited to three years under SECURE 2.0 Act Section 311.
• Employer matching or nonelective contributions can now be designated as Roth contributions under SECURE 2.0 Act Section 604.

Notice 2024-82