The IRS limits the amount of money that may be contributed to retirement plans. These limits are updated annually. There are two main types of contribution limits to the FCMM Retirement Plan: the overall limit on annual additions and the elective salary deferral limit.
The limit on annual additions, also known as the 415(c) limit, includes employer contributions of related employers plus all salary deferral contributions made to any 403(b), 401(k), SIMPLE IRA, and SARSEP plans in a calendar year. For 2023, this limit is the lesser of $66,000 or 100% of includible compensation, which excludes a housing allowance.
The elective salary deferral limit, also known as the 402(g) limit, includes all pre-tax and Roth elective deferrals made to any 403(b), 401(k), SIMPLE IRA, and SARSEP plans in a calendar year. The 2023 salary deferral limit is $22,500. The employee's total elective deferrals to all plans combined cannot exceed the annual deferral limit.
A participant of age 50 or older can make additional age-based catch-up deferral contributions, beyond these limits, of up to $7,500 in 2023.
The examples below illustrate some of these limits.
- Example 1:
The Reverend Bill Smith has a cash salary of $15,000 and a $25,000 housing allowance, for a total compensation of $40,000. He does not participate in any retirement programs other than this Plan and his employer makes no contributions to any retirement programs on his behalf. The maximum he may contribute to the Plan is $15,000. Rev. Smith cannot include the housing allowance in determining his maximum contribution amount.
- Example 2:
The Reverend Sam Jones is in the same situation as Rev. Smith except that he has a cash salary of $60,000 and a housing allowance of $15,000, for a total compensation of $75,000. The maximum amount he may contribute to the Plan for 2023 is $22,500 (assuming he is not eligible to make any catch-up contributions).
- Example 3:
The Reverend George Davis has a cash salary of $30,000 and a housing allowance of $25,000, for a total compensation of $55,000. His employer contributes 15% of his compensation* to the retirement plan annually, or $8,250 ($80,000 x 15% = $8,250). The maximum deferral amount he may contribute to the plan in 2023 is $21,750 ($30,000 - $8,250 = $21,750).
*Note, the employer must use total compensation (salary plus housing allowance) when calculating a contribution amount based on a percentage rate. Includible compensation which excludes housing allowance only applies when determining an individual’s contribution limits.