SECURE Act 2.0: Now What’s Next?

As you are aware by now, the SECURE Act 2.0 was passed in late December 2022 as part of the Consolidated Appropriations Act.  It is the biggest retirement plan related legislation we have seen in years designed to accomplish four primary goals – 1) increase the availability of retirement plans 2) help people save more 3) streamline retirement plan rules and 4) help workers preserve income in retirement.  SECURE Act 2.0 has over 90 provisions, some major and some minor; some mandatory and some optional; some retroactively effective and some won’t be effective for years to come. And some with unanswered questions.

While we have listed what we see as the most impactful provisions, it is now time to begin planning.  We are advising plan sponsors to first take a deep breath and understand the majority of everything that is in this will not be taking effect as of today because it requires additional guidance, processes and procedures.  Yes, let’s look at it and let’s plan ahead.  However, there is a lot more we need from the IRS and DOL before we can fully give analysis of the nearly 90 provisions and how this is going to impact plans on a day-to-day basis.  In addition, more is needed on how various provisions will be implemented with recordkeepers and plan administrators.

Our list of the most impactful provisions listed by effective date is as follows.