December 2025

Plan Sponsor News

Welcome to the December 2025 issue of Plan Sponsor News! In this quarterly issue, learn about strategies to encourage employees to maximize their retirement benefits without exceeding contribution limits, review our webinar about some SECURE 2.0 Act provisions and explore Social Security basics that employees need to know.

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Tips for Not Exceeding Contribution Limits

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You want your employees to get the most out of their retirement benefit, but plan participants can be challenged by the complexity of the Internal Revenue Service (IRS) rules. How do you help plan participants maximize their retirement benefits while not exceeding contribution limits?

In the December 2024 article, “Plan Sponsors: How to Set Yourself Up for Success in the New Year,” we discussed four common plan administration errors and how to avoid them. This year, we explore a less common compliance issue for 403(b) and 401(k) plans: exceeding contribution limits.

Here’s what you need to know.

Mistake: Exceeding Contribution Limits

Understanding how contribution limits apply, and educating participants on the limits, helps plan sponsors avoid excess contributions and potential penalties. As a quick background, following are the rules and regulations:

  • IRC Section 402(g): the maximum amount an individual can contribute in elective deferrals to certain retirement plans for a calendar year. For 2026, this amount is $24,500.
  • IRC Section 415(c): the maximum amount that can be allocated to an individual participant’s account in a defined contribution retirement plan during a given year. These total contributions (employee plus employer) include elective deferrals, employer matching, profit-sharing and after-tax contributions (but not rollovers). For 2026, this amount is $72,000.
  • Note: Employer matching contributions are included in the IRC Section 415(c) annual additions limit, even if they are made based on employee catch-up contributions; however, the employee catch-up contribution is not.

The following employee elective deferrals are in addition to the 402(g) limits above:

  • Age 50+ catch-up contributions: Individuals turning age 50 or older during the year can contribute up to an additional $8,000.
  • SECURE 2.0 Act enhanced “super” catch-up for participants attaining age 60, 61, 62 or 63: Individuals turning 60, 61, 62 or 63 can contribute an additional $3,250.
  • Note: Beginning in 2026, catch-up and enhanced catch-up contributions must be made on a Roth basis if the participant earned at least $150,000 in FICA wages in 2025.

How to Avoid Exceeding Limits

  • Mutual of America Data Validation Web (DVW) will track contributions per participant throughout the year and will alert you if a participant’s contributions exceed the annual limit. Talk to your Mutual of America CRM for more information about DVW.
  • Coordinate with payroll vendors to monitor limits. Your payroll vendor may monitor contribution limits for you. You should consult with your vendor to see if that is a service they provide.
  • Conduct year-end reviews. As the year-end approaches, it is prudent to review the annual contributions made to the plan to make sure your participants are not overcontributing.
  • Educate employees on contribution caps.
  • Include information on contribution limits when onboarding, including that the 402(g) limit is per individual, per year and not plan specific.
  • For employers with non-calendar-year plans, keep in mind that these are calendar-year limits.

Pro Tip: Contribution Limits and Onboarding Guidance

When onboarding new employees or enrolling participants into retirement plans, it’s important to communicate the IRS contribution limits, especially the 402(g) elective deferral limit. For 2026, this limit is $24,500, and it applies per individual, per calendar year, not per plan. This means that if an individual participates in multiple retirement plans (e.g., works for two employers offering separate 401(k) plans), their combined elective deferrals across all plans cannot exceed the $24,500 limit.

This distinction is crucial for compliance and helps participants avoid excess contributions, which can result in tax penalties. Including this information during onboarding ensures participants understand their annual limits and can plan their contributions accordingly.

How to Fix It

If an error does occur, here’s information on how to fix it:

  • Distribute excess deferrals to the participant by April 15 of the following year to avoid penalties.
  • After April 15, there may be tax and penalty implications for the participant and plan sponsor. It is considered an operational failure for plan sponsors.

Four Ways Mutual of America Helps

  1. For clients who use DVW, we automatically monitor contributions, reject excess contributions and notify the plan sponsor if a participant exceeds 415(c) or 402(g) limits. (Note: given the information we have, which does not include previous employers. We track per participant, per plan contributions.)
  2. For exclusive and coordinated services clients, we test for compliance with contribution limits during annual compliance testing.
  3. Should an error occur, we can help with corrections.
  4. We provide tools and education for your employees. Download our 2026 IRS retirement plan numbers participant tool.  

Final Tip

By staying informed, working closely with plan services providers, conducting regular reviews and educating your plan participants, you can keep your plan compliant while helping your participants maximize their retirement benefit. Should an error occur, we’re here to help. Reach out to your CRM with questions.

Better your tomorrow.

Contact your Mutual of America representative today.


SECURE 2.0 Act Webinar Replay: What’s Coming in 2026

Secure 2.0 Act Webinar: What's Coming in 2026

On December 11, Mutual of America Financial Group held a webinar covering SECURE 2.0 Act key provisions and insights that plan sponsors need to know about for 2026, including:

  • Expanded long-term, part-time (LTPT) worker coverage, including eligibility and vesting requirements, and compliance considerations.
  • Roth catch-up contributions, including employer responsibilities, employee eligibility, benefits and deadlines.
  • How Mutual of America is supporting compliance and education, as well as the next steps needed for your organization’s retirement plan.

Watch a replay of “SECURE 2.0 Act: What’s Coming in 2026,” with speakers Troy Johnson, Executive Vice President, Head of Service and Sales – West; Nick Curabba, Senior Vice President and Associate General Counsel; and Morgan Pace, Vice President, Client Relationship Manager Operations.

Contact your regional Mutual of America Financial Group representative with any questions you may have about how this information may affect you and your employees.

Better your tomorrow.

Contact your Mutual of America representative today.


Social Security Basics: What Employees Need to Know

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When it comes to retirement, almost 9 out of 10 employees (87%) are counting on Social Security to be a source of income; yet only 69% say they understand how the program works.1 This is an opportunity for plan sponsors to support employees with information to help current and future decision-making.

Social Security Is Not Meant to Be the Only Source of Retirement Income

Before we get into the how the program works, perhaps the most important insight that employees need to know is that Social Security is not meant to be the only source of income for people when they retire. Social Security functions as a form of longevity insurance. It provides a guaranteed stream of inflation-adjusted income for life.

The following facts from the Social Security Administration’s Understanding the Benefits booklet may help employees understand the gap between the amount provided by Social Security and the amount needed to retire comfortably.

Social Security replaces a percentage of a pre-retirement income. Two factors determine this percentage:

The estimated average 2025 monthly Social Security benefit for all retired workers is $1,976. Approximate percentage ranges of pre-retirement income provided by Social Security for a worker taking benefits at age 67 are:

  • 79% for low earners
  • 43% for medium earners
  • 28% for maximum earners

In contrast, most financial advisers recommend workers will need about 70% to 80% of pre-retirement income—including Social Security benefits, investments and personal savings—to live comfortably in retirement.

Social Security: Five Things to Know

While there are different Social Security benefits available— disability, survivor, family, Supplemental Security Income and Medicare—our focus here is retirement benefits.

  • Social Security is funded through payroll taxes (commonly referred to as FICA) deducted from employees’ paychecks. Social Security tax is currently 6.2% and Medicare 1.45% from both employee and employer.
  • Monthly benefits typically become available beginning at age 62 if an employee has worked and paid into Social Security for at least 10 years. The years do not have to be consecutive but are based on a credit system where an employee can earn up to four credits per year for each $1,810 earned based on 2025 numbers (adjusted each year).
  • The amount employees will receive is impacted by their age when applying for benefits (between 62 and 70), lifetime earnings and other factors, such as taxes on benefits or Medicare Part B premiums (in 2025, the standard monthly premium for Medicare Part B is $185).
  • Employees are entitled to their full benefits once they reach full retirement age—between ages 66 and 67, depending on birth year.
  • Applying for benefits is allowed up to four months before the first payment.

Considerations in Deciding When to Take Benefits

Deciding when to receive Social Security is an individual choice; however, monthly benefits will be larger the later the start date.  Weighing a range of factors, from anticipated financial obligations to expected longevity, is generally advised before making the decision.

Your employees may choose to apply for Social Security while still working. Doing so, they should be aware of yearly earnings limits that could reduce their benefit amount if they’ve not yet reached full retirement age.  

Employees Can Get a Social Security Benefits Estimate

The good news is that employees can get estimates of their Social Security retirement benefits and compare the effects of beginning to take benefits at different ages by creating a personal my Social Security account at www.ssa.gov/myaccount.

Regardless of when they claim benefits, employees likely want to plan for additional income sources in retirement, including, of course, taking advantage of their workplace plan.

1EBRI Retirement Confidence Survey Funders Report, Slide 7.



Infographic titled "Key Q1 dates for January plan years" with a calendar icon at the top. Sections for January, February, March, and April list important compliance deadlines for retirement plan providers, including Form 1099-R issuance, quarterly benefit disclosures, corrective distributions, and required minimum distributions. Mutual of America Financial Group logo and disclaimer appear at the bottom.

This infographic does not identify all compliance obligations or due dates. View the Full Calendar.

Things
to know

1

Customer Protection Guarantee

In the March Plan Sponsor News article “Plan Sponsors: Encourage Your Participants to Set Up an Online Account,” we provided tips to help employees protect their accounts from cyber-enabled fraud. We are pleased to share our Customer Protection Guarantee. We guarantee reimbursement for any money lost due to unauthorized activity in an employer-sponsored retirement plan account. To qualify, a participant must: register the account online with Mutual of America, regularly review and keep contact information up to date, and report any suspected identity theft or other suspicious activity to Mutual of America immediately. To learn more, view the Customer Protection Guarantee.

2

More Efficient Online Process for Participant Loans Begins Soon

Beginning December 15 for plans offering loans, participants may submit applications for plan loans through our new online loan functionality. This new process eliminates the need for participants to download and complete the loan application form; instead, participants will be able to complete and submit their loan applications online. This functionality will also include an integrated plan sponsor approval process. Taken together, these enhancements will improve loan application accuracy and reduce processing time.

3

Contribution Limits for 2026

The Internal Revenue Service (IRS) has announced the dollar maximums and limits for qualified pension plans and other retirement-related items for 2026. These reflect the applicable cost-of-living adjustments required by federal tax law and are effective for the 2026 tax year only. View the limits.

4

SECURE 2.0 Act: Long-Term, Part-Time Worker Provision Defaults and Options

In a recently released bulletin, we focused on the long-term, part-time (LTPT) worker requirements and their impact on various provisions of your plan. There is one provision—employer contributions—that you can choose to change from its default provision. If you choose to make employer contributions to LTPT workers, then a separate amendment for employer contributions will be necessary. However, if instead you choose to administer your plan using only the default provisions, then no additional, separate plan amendment is necessary, and your plan can be brought into compliance with all of the default LTPT requirements through the SECURE 2.0 Act compliance amendment (which we will provide by the December 31, 2026, deadline to plan sponsor clients for whom we provide document services).

5

Reminder About Roth Catch-Up Contributions for High Earners

As discussed in “SECURE 2.0 Act: What You Need to Know to Prepare for 2026,” starting in 2026, employees aged 50 or older who earned more than $150,000 in FICA wages from their current employer in 2025 will be required to make catch-up contributions as Roth (after-tax) contributions. This applies to 401(k), 403(b) and most 457(b) plans.

6

Enhancements to the Participant Profile Report

We’ve made enhancements to the Participant Profile Report. Participant Deferral Rates are now available on this report (including participant elected “%” and “$” amounts). The report also includes expanded participant status criteria (of note are eligible participants with zero balance) and an added Marital Status column.

7

Select MoA Funds Are Now Available on Fidelity and Schwab Platforms

Investors who have brokerage accounts with Fidelity and Schwab can now purchase select MoA Funds in their accounts. To learn more about the funds and the investment professionals at Mutual of America Capital Management, an independent, wholly owned subsidiary of Mutual of America, visit moafunds.com.Table showing Mutual of America funds available through Fidelity and Schwab, including fund names and corresponding tickers. Fidelity lists eight funds: MoA Balanced Fund (MACHX), MoA Core Bond Fund (MABDX), MoA Equity Index Fund (MAEIX), MoA Intermediate Bond Fund (MAMBX), MoA International Fund (MAIFX), MoA Mid Cap Equity Index Fund (MAMEX), MoA Small Cap Growth Fund (MAGKX), and MoA Small Cap Value Fund (MAVKX). Schwab lists two funds: MoA International Fund (MAIFX) and MoA Balanced Fund (MACHX). Note: Transaction fees may apply. MoA Funds distributed by Foreside Fund Services, LLC. Mutual fund investing involves risk. Principal loss is possible.

Better your tomorrow.

Contact your Mutual of America representative today.

You should consider the investment objectives, risks, and charges and expenses of the investment funds and, if applicable, the variable annuity contract, carefully before investing. This and other information is contained in the funds’ prospectuses and summary prospectuses and the contract prospectus or brochure, if applicable, which can be obtained by calling 800.468.3785 or visiting mutualofamerica.com. Read them carefully before investing.

Mutual of America’s group and individual retirement products that are variable annuity contracts are suitable for long-term investing, particularly for retirement savings. The value of a variable annuity contract will fluctuate depending on the performance of the Separate Account investment options you choose. Upon redemption, you could receive more or less than the principal amount invested. A variable annuity contract provides no additional tax-deferred treatment of benefits beyond the treatment provided to any qualified retirement plan or IRA by applicable tax law. You should consider a variable annuity contract’s other features before making a decision.

The articles and opinions in this publication are for general information only and are not intended to provide specific advice or recommendations for any individual. Consult your attorney, accountant or financial or tax adviser with regard to your individual situation.

The tax information contained herein is for informational purposes only. You should consult your financial adviser or attorney regarding your individual circumstances.