Multnomah Group’s 2025 Retirement Plan Regulatory Update delivers insights on the latest legislative, IRS, Department of Labor, litigation, and industry developments affecting institutional retirement plans.
Key Topics Covered
- SECURE 2.0 Act Changes
- IRS Final Regulations
- Department of Labor Guidance
- ERISA Litigation Trends
- Retirement Industry Innovations
Navigating 2025 Retirement Plan Regulations: FAQs
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What are the key legislative changes for retirement plans in 2025?
Recent years have seen major shifts with the SECURE and SECURE 2.0 Acts, but 2025 legislative activity has been limited. Notably, Congress is considering lowering the minimum age for plan eligibility from 21 to 18, which could expand retirement savings opportunities for younger workers. Another bill aims to allow 403(b) plans to use Collective Investment Trusts (CITs), potentially reducing costs and expanding investment options for charities and educational institutions.
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How do new IRS rules impact catch-up contributions and plan compliance?
SECURE 2.0 requires catch-up contributions for high earners (over $145,000) to be made on a Roth after-tax basis starting January 1, 2026. The IRS has provided a temporary exception to help plan sponsors and recordkeepers prepare. Additionally, the optional ‘super catch-up’ provision allows participants aged 60–63 to contribute up to $11,250 in 2025, but it’s not mandatory for plans to offer this feature. 403(b) plan sponsors must also adopt updated Cycle 2 pre-approved plan documents by December 31, 2026 to maintain compliance.
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What’s changing at the Department of Labor (DOL)?
With new leadership at the Employee Benefits Security Administration (EBSA), the DOL is signaling a shift toward deregulatory reforms.
This includes revisiting fiduciary standards, ESG investing guidelines, and access to cryptocurrency in retirement plans. The DOL is actively reviewing and potentially rescinding rules introduced in previous administrations, which could impact enforcement and litigation trends.
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How is ERISA litigation evolving?
Litigation continues to shape best practices for fiduciary committees. The Supreme Court has made it easier for prohibited transaction claims to proceed, shifting the burden of proof to plan fiduciaries. Lawsuits are increasingly focused on the use of forfeitures, recordkeeper use of participant data, and prudent process in fund selection. Recent cases highlight the importance of documenting fiduciary decisions and maintaining independent oversight.
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Are alternative investments and annuities gaining traction?
Federal actions and industry innovation are expanding access to private equity, cryptocurrency, and embedded annuity products in defined contribution plans. While these options offer potential for greater diversification and higher returns, they also introduce new risks and administrative complexities. The guide explores how these products are being integrated into managed portfolios and what plan sponsors should consider before adoption.
Multnomah Group is a registered investment adviser registered with the Securities and Exchange Commission. Any information contained herein or on Multnomah Group’s website is provided for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and, unless otherwise stated, are not guaranteed. Multnomah Group does not provide legal or tax advice.
