By Mark Olsen, Managing Director at PlanPILOT
Just when retirement plan sponsors were getting used to the SECURE Act that went into effect in 2020, new legislation was passed in 2022 designating new rules in the SECURE Act 2.0. Some of those changes went into effect immediately and other changes are set to start as far out as January 2024. This means it’s crucial for employers and plan sponsors to familiarize themselves with these upcoming modifications and prepare for their implementation. By staying informed and proactive, plan sponsors can assist in a smooth transition to the new rules, maximizing benefits for employees and maintaining compliance with regulatory requirements. Here’s how to plan ahead for all the upcoming changes.
Understand Recordkeeping Readiness
As the new provisions come into effect, it’s essential to assess your organization’s current recordkeeping provider. Start by requesting insight from your recordkeeper on their capability plans to handle the new provisions, including:
- Allowing employees to designate employer contributions as Roth contributions, which will impact employee taxes and require considerations for vesting. (optional provision)
- Permitting qualified student loan payments to receive employer matching contributions, which will have budget implications for plan sponsors. (optional provision)
- Establishing an emergency savings plan for non-highly compensated employees linked to the defined contribution plan, potentially with a 3% auto-enrollment feature, subject to specific account balance and investment limitations. (optional provision)
- Ensuring catch-up contributions for employees with compensation over $145,000 (indexed for future years) are contributed on a Roth basis, and allowing all participants to make catch-up contributions on a Roth basis. (mandatory provision)
- Increasing the catch-up contribution limit for individuals aged 60-63 to the greater of $10,000 or 150% of the regular catch-up contribution amount ($11,250 for 2023), indexed for cost-of-living increases. (optional provision)
The next step is to determine which of these optional provisions are aligned with your outlook on the employee benefit plan. An additional consideration is “packaging” a number of these changes versus rolling them out on an individual basis.
And that’s just some of the changes to come! Needless to say, there will have to be a lot of modifications to your recordkeeping process. Which of these changes will be easier to make, and which might present a challenge? Establish an open line of communication with your recordkeeper to make a smooth transition and minimize potential disruptions to your internal staff that are supporting these changes.
Lastly, you can keep tabs on all the changes in our SECURE 2.0 Plan Sponsor Checklist.
Plan for Multi-Stage Employee Communication
In making this transition to the new SECURE 2.0 provisions, it’s a good idea to plan your employee communication carefully. Since a number of changes are coming up, a multi-stage communication strategy can help create awareness and understanding among employees.
Begin by announcing the upcoming changes and providing a brief overview of how they affect your employees. This initial communication should be clear, concise, and informative, giving employees a basic understanding of what to expect.
Next, dive deeper into the specific provisions that are most discussed and asked about, especially on topics that impact employees’ retirement planning. Offer detailed explanations and resources to help employees understand the changes and how they can benefit from them. This stage is critical to keeping employees well informed and feeling confident in their retirement planning decisions.
Finally, host Q&A sessions and provide additional resources to address any lingering questions or concerns. These sessions can be conducted as webinars or in-person meetings, allowing employees to ask questions and clarify any confusion. Provide written materials and online resources for employees to reference as needed. The good news is your plan recordkeeper will likely be in a position to assist you with some or all of these additional communication resources.
Review Impacts to the Employer’s Budget
Implementing the SECURE 2.0 Act provisions will likely have financial implications for your organization. Begin by assessing the costs associated with implementing the new provisions, such as technology upgrades or additional administrative tasks. At the same time, estimate potential savings from voluntary provisions like the tax credit for small businesses that adopt automatic enrollment.
Adjust your organization’s budget to accommodate these changes. Allocate resources for necessary updates and adjustments, and balance the budget to maintain financial stability. Be prepared to reallocate funds as needed to help implement a smooth implementation of the SECURE 2.0 Act provisions.
Is Your Plan Ready for SECURE 2.0?
The list of rules and regulations businesses need to follow in both the SECURE Act as well as the SECURE Act 2.0 can be daunting and overwhelming. If you’d like help preparing for these changes and more, we’d welcome the opportunity to assist you. At PlanPILOT, we have been navigating legal and regulatory changes as qualified plan consultants for over 20 years. If you’re ready to take the next step with your employer-sponsored retirement plan, we would love to hear from you. Call us at (312) 973-4913 or email mark.olsen@PlanPILOT.com to get started today.
About Mark
Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, Stable Value Investment Association, and CUPA-HR.