The SECURE 2.0 Act of 2022 is now a year old, allowing us to assess the wide variety of retirement-related provisions covering three key areas:
- Participation and access
- Retirement income and distributions
- Financial wellness
In 2023, industry stakeholders leaned in to better understand the implications of various provisions, especially those effective immediately, including a change in the required minimum distribution age from 72 to 73 (which will change to 75 in 2033).
In 2024, several mandatory provisions will become effective. These include an increase in the mandatory cash-out limit of $7,000 (increased from $5,000), allowing employers to transfer former employees’ accounts below that threshold to an IRA without consent. This change should help ease the burden on sponsors for continuing to maintain accounts with small balances, many of which are at high-risk for becoming lost participants. Also effective in 2024 will be new rules allowing employees who complete 500 hours of service in three consecutive years to contribute to 401(k) plans.
Perhaps most discussed were changes to catch-up contributions. Under the new rules, participants with compensation exceeding $145,000 would only be allowed to make catch-up contributions on a Roth aftertax basis. This was originally effective for 2024, which would require plans to be amended to allow for Roth contributions. Adding to the confusion was a technical drafting error that removed catch-up contributions entirely in the year 2024. In response to industry concerns, the IRS delayed the effective date of this provision by two years, allowing sponsors to begin administering this provision in 2024 if desired but permitted them to delay implementation until January 1, 2026 if more time is needed.
Widely discussed but optional provisions related to emergency savings and student loans are also set to go into effect in 2024, although the IRS has not yet issued guidance. The new rules allow student loan payments to be treated as elective employee contributions for the purpose of matching contributions. This provision should assist savers in being able to take advantage of their employer matching contributions even if their student loan payment obligations impact their ability to make contributions to the retirement plan. SECURE 2.0 also includes two approaches with respect to emergency savings:
- Allowing participants to take a $1,000 distribution from their account once every three years without being subject to a distribution tax
- Allowing withdrawals up to $2,500 from a separate emergency savings account subject to numerous conditions
We asked sponsors which of these provisions they planned to implement and found a combined 45% plan to add emergency savings features. However, when asked what changes they would make if they were not limited by budget or resource constraints, the answers change considerably, with 57% indicating they would match student loan payments, and a combined 76% indicating they would create a vehicle for or provide access to 401(k) assets for emergency savings.