IRS Expands Ability of Safe Harbor Plan Sponsors to Make Mid-Year Changes

The IRS recently issued guidance providing safe harbor 401(k) plan sponsors with increased flexibility to make mid-year plan changes. Notice 2016-16 sets forth new rules for when and how safe harbor plan sponsors may amend their plans to make mid-year changes, a process which traditionally has been subject to significant restrictions.

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McDermott Will & Emery






Jeffrey Holdvogt
Jeffrey (Jeff) M. Holdvogt regularly counsels public and privately held companies and tax-exempt organizations on a wide range of employee benefits matters. These include the design and administration of complex pension, 401(k) and 403(b) plans, nonqualified and executive deferred compensation arrangements, fiduciary and plan investment issues under the Employee Retirement Income Security Act (ERISA), internal compliance reviews and voluntary correction filings, and benefit plan matters arising from mergers and acquisitions, as well as other ongoing day-to-day retirement and executive compensation issues. Read Jeff Holdvogt's full bio.


Stephen Pavlick
Stephen Pavlick focuses his practice on employee benefits matters for multinational corporations. He concentrates on qualified plans, related fiduciary and other Employee Retirement Income Security Act (ERISA) issues, deferred compensation and equity arrangements, and funding strategies for post-retirement welfare benefits. He has worked extensively with cash balance plans. Read Stephen Pavlick's full bio.

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