Thanks for this post on catch-up contributions. I'm trying to determine whether the responsibility for determining the "high-earner" classification lies with the employer plan or the individual employee when multiple employers are involved. I have located information on various sites about the recent guidance on Secure Act 2.0 - this excerpt below seems to imply it's the "current" employer's responsibility (whereas, I believe it is the individual's responsibility to ensure contributions across multiple employers do not exceed the cap in a given year). https://www.employeefiduciary.com/blog/401k-catch-up-contributions
"High Earner: defined as a plan participant who - in the preceding calendar year - received more than $145,000 in FICA wages “from the employer sponsoring the plan”, as reported in Box 3 of the Form W-2.
Aggregation option: If easier to administer, final regulations give employers the option to aggregate the FICA wages paid by members of a controlled group, employers using a common paymaster, and predecessor/successor employers in asset sales.
Comments
Thanks for this post on catch-up contributions. I'm trying to determine whether the responsibility for determining the "high-earner" classification lies with the employer plan or the individual employee when multiple employers are involved. I have located information on various sites about the recent guidance on Secure Act 2.0 - this excerpt below seems to imply it's the "current" employer's responsibility (whereas, I believe it is the individual's responsibility to ensure contributions across multiple employers do not exceed the cap in a given year). https://www.employeefiduciary.com/blog/401k-catch-up-contributions
Post: SECURE Act 2.0 Changes to Retirement Plan Catch-up Contributions
Link to comment from October 24, 2025