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.
• Roth Employer Contributions
• Small Incentives for Contributing to a Plan
• Tax Credits
• RMD Increased to Age 73
• Self-Certification of Hardship Distributions
• Penalty Free Withdrawals for Terminal Illness
• Required Roth Catch-Up Contributions
• Penalty Free Withdrawals for Victims of Domestic Abuse
• RMDs Not Required for Roth 401(k) and 403(b)
• Emergency Withdrawals
• Matching Student Loans
• Force-Out Rollover Limit
• Automatic Portability
• “Side Car” Emergency Savings Account
• Retirement Lost and Found
• Improving Retirement Plan Access for Part-Time Workers
• Automatic Enrollment and Escalation – Retirement Savings on Autopilot
• Higher Catch-Up Limits for 60 – 63 Year Old Employees
• Enchance and Promote Saver’s Match
We continue analysis of the provisions and will share comments as guidance is received. In the meantime, we will reach out to arrange a time for dialogue of which provisions may be appropriate for your plan and your employees.
Since 2012 at Rose Street, Scott has been responsible for helping the firm’s individual wealth management clients with income strategies for retirement and consulting with employers with their employee retirement plans. In free time, he enjoys golf, biking, skiing, cooking, and traveling. Fun fact, Scott has a hobby of filling growlers with coins!