The Washington Report
May 14, 2025
Note to Subscribers
While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.
Retirement
IRS Releases Plan-Specific Substitute Mortality Tables Used to Determine Present Value
On May 6, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-21, which modifies Section 12 of Revenue Procedure 2024-32. Revenue Procedure 2024-32 specifies the procedure by which the sponsor of a defined benefit plan that is subject to the funding requirements of Section 430 of the Internal Revenue Code may request approval from the IRS for the use of plan-specific substitute mortality tables in accordance with Section 430(h)(3)(C) and Section 1.430(h)(3)-2 of the Treasury Regulations. Section 12.02 of Revenue Procedure 2024-32 specifies that, in conjunction with the replacement of the generally applicable mortality tables, certain plan sponsors that wish to continue using plan-specific mortality tables must develop and request approval for the use of new plan-specific substitute mortality tables for plan years beginning on or after January 1, 2026. Revenue Procedure 2025-21 provides immediate relief for some of those plan sponsors by narrowing the category of plan sponsors that are required to request approval of new plan-specific substitute mortality tables.
IRS Revenue Procedure 2025-21 is available here.
Aon Publications
IRS Announces HSA Limits for 2026
On May 1, 2025, the Internal Revenue Service (IRS) issued Revenue Procedure 2025-19, which announced the inflation-adjusted limits for Health Savings Account (HSA) contributions for the 2026 calendar year. The announcement also updated the minimum deductible amounts and maximum out-of-pocket limits for High-Deductible Health Plans.
The Aon bulletin is available here.
Now Available: Legal Consulting & Compliance Quarterly Update
The Retirement Legal Consulting & Compliance practice is pleased to present its Quarterly Update of recent legal developments for the second quarter of 2025. In this issue you will find the following articles:
- Fiduciary Liability Insurance Primer
- Is It In Or Is It Out? That's the Pay Code Question
- IRS Releases Proposed Regulations for SECURE 2.0's Catch-up As Roth Requirement
- DOL Adds Self-Correction Feature to VFCP
- DOL Presents "Opportunity" to Escheat Small Balances to States
- The Latest Model: DOL Issues Guidance on SECURE 2.0 Changes to Annual Funding Notice
- Quarterly Roundup of Other New Developments
The second quarter 2025 issue of the Retirement Legal Consulting & Compliance Aon Quarterly Update is available here.