Operational Failures, SECURE 2.0, and Correction Strategies
Presented by Angela M. Stockbridge, Partner at Falcon Rappaport & Berkman LLP
A December 31, 2026 Deadline Plan Sponsors Can't Miss
Time is running short for plan sponsors to act. Under SECURE 2.0, SECURE 1.0, and the CARES Act, most 401(k), profit-sharing, and other tax-qualified retirement plans — along with 403(b) plans — must be formally amended by December 31, 2026, regardless of the plan's fiscal year. This single deadline consolidates years of required and discretionary changes, including provisions for automatic enrollment, expanded eligibility for long-term part-time employees, updated hardship withdrawal rules, and the new mandatory Roth catch-up contribution requirement for higher-income earners. Plans that miss the deadline risk disqualification, so CPAs and plan sponsors should confirm now that their documents — and the operational practices behind them — are ready before the window closes.
Program description
Retirement plan problems rarely begin as legal disputes. They usually begin as operational disconnects: payroll codes that do not match the plan document, eligibility rules that are not applied consistently, participant contributions deposited later than the plan sponsor’s actual administrative capability, loan procedures that drift from the written policy, required minimum distributions that are missed, or notices and committee records that cannot be produced when regulators ask for them.
This practical webinar is designed for CPAs who advise employer plan sponsors and want to spot retirement plan issues before they become IRS audit, DOL enforcement, fiduciary, or plan qualification problems. The session will focus on what CPAs should notice first, how to triage common failures, when correction may be required, and how to coordinate efficiently with TPAs, recordkeepers, payroll teams, and counsel.
The program uses real-world “what would you spot first?” scenarios to connect familiar CPA touchpoints to the retirement plan compliance issues that often require prompt correction.
Practical takeaways
• A CPA-focused red-flag checklist for retirement plan operations.
• A triage framework for deciding when to involve the TPA, recordkeeper, payroll team, or counsel.
• A practical understanding of how correction programs map to tax qualification, fiduciary, delinquent filing, and late-deposit issues.
• Case-study prompts that CPA firms can use internally to train teams on what to spot first.
Key topics addressed
• Payroll and operational plan errors relating to including W-2 income, equity compensation, bonuses, and annual compensation limit issues.
• Eligibility and enrollment failures involving part-time employees, rehires, transfers, controlled groups, merged-in populations, and automatic enrollment procedures.
• Late participant contribution deposits and loan repayment issues, including DOL timing expectations, lost earnings, documentation, and correction pathways.
• Plan loan failures, in-service distributions, hardship procedures, RMD administration, beneficiary follow-up, and missing-participant diligence.
• Plan document, amendment, SPD, notice, testing, vesting, forfeiture, QDRO, investment policy, fiduciary committee, and service-provider documentation red flags.
• How SCP, VCP, Audit CAP, VFCP, and DFVCP options fit into the correction decision tree.
Expanded Learning Objectives:
1. Identify common retirement plan compliance red flags that CPAs may encounter through payroll, tax, audit, Form 5500, or client advisory work.
2. Explain why documented practices, internal controls, proof of notice delivery, committee minutes, and retained records are important in IRS and DOL examinations.
3. Recognize common operational failures involving compensation definitions, eligibility, enrollment, participant loans, RMDs, late deposits, distributions, testing, vesting, forfeitures, and plan amendments.
4. Distinguish among qualification failures, fiduciary issues, delinquent filing concerns, and late-deposit problems when triaging potential correction pathways.
5. Describe how SECURE 2.0 affects self-correction strategy, including eligible inadvertent failures, participant loan corrections, DOL coordination, and the need for established practices and procedures.
6. Evaluate when a plan sponsor may need SCP, VCP, Audit CAP, VFCP, DFVCP, or another correction approach, and identify the documentation needed to support the correction.
7. Coordinate more effectively with TPAs, recordkeepers, payroll teams, plan committees, and counsel to resolve issues and reduce repeat errors.
Who should attend, esp. CPAs?
• CPAs advising employers that sponsor 401(k), profit-sharing, pension, or other qualified retirement plans.
• Employee benefit plan auditors, tax professionals, client advisory services teams, and firm leaders who support plan sponsor clients.
• Professionals who coordinate with TPAs, payroll providers, recordkeepers, ERISA counsel, and internal plan committees.
NASBA CPE Credits: 2 IRS CE: 2
Level: Intermediate
Prerequisites: General familiarity with qualified retirement plan administration and ERISA compliance concepts.
Adv. Prep.: None
Audience: CPAs, EAs, and TPAs who advise plan sponsors on retirement plan compliance and corrections.
IRS CE Credits: 2 IRS CE Course # IVYPC-Q-00013-26-O
About the Presenter:
Angela M. Stockbridge | Partner, Falcon Rappaport & Berkman
Angela M. Stockbridge is an employee benefits and executive compensation attorney. Her experience in law firms, in-house legal departments, and HR consulting roles informs her perspective on matters including M&A deal diligence, complex 409A and 280G issues, plan compliance and corrections, and fiduciary governance.
Angela advises executives and human resources professionals on compliance matters relating to qualified and nonqualified retirement plans, group health plans, and voluntary benefits. Angela offers actionable advice to plan sponsors with compliance concerns under the Employee Retirement Income Security Act of 1974 (ERISA), the Health Insurance Portability and Accountability Act (HIPAA), and the Patient Protection and Affordable Care Act (ACA). She represents plan sponsors under audit by the Internal Revenue Service and Department of Labor, assists with Form 5500 returns, and submits plan correction applications to the IRS under the Employee Plans Compliance Resolution System.
About the SponsorThe CPA Trendlines Academy (Thomas Advisors LLC d/b/a), #170718, is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors via its website at nasbaregistry.org.
