News & Announcements

October 14, 2024

Status of recordkeeping support for SECURE 2.0 Act provisions

The SECURE 2.0 Act marked a significant step toward enabling more small business owners and employees to pursue retirement stability. 

Outlined below is the status of our recordkeeping support for some key SECURE 2.0 provisions (sections) for your RecordkeeperDirect® workplace retirement plan. For a better understanding of these provisions, refer to SECURE 2.0 Act of 2022 ― A boost to retirement saving (PDF) or speak with your plan’s financial professional. 

Recordkeeping status for key SECURE 2.0 Act provisions

Provision

Effective date 

Recordkeeping status

Qualified disaster recovery distributions

Section 331 (optional)

Effective for disasters occuring on or after January 26, 2021

Ready to support

Employer Roth contribution option

Section 604 (optional) 

Effective for contributions made after December 29, 2022

Intend to support in 2025

We’re evaluating solutions based on IRS guidance. 

Terminal illness early distribution penalty tax exception

Section 326 (optional)

Distributions made after December 29, 2022

Intend to support in 2025

Fewer notices for unenrolled employees

Section 320 (optional) 

Plan years beginning after December 31, 2022

In progress

We plan on developing a new notice template to assist plan sponsors in preparing the required participant notification for those who decide to take advantage of this change.

Relaxed required minimum distribution (RMD) rules ― increased age triggering required beginning date

Section 107 (mandatory) 

Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022

Ready to support

Self-certification for hardship withdrawals

Section 312 (optional) 

Plan years beginning in 2023

Intend to support in 2025

We’re developing a solution to accommodate plans that decide to offer self-certification hardship withdrawals. More information will be communicated on this process in the near future.

Emergency Roth savings accounts

Section 127 (optional)

Plan years beginning after December 31, 2023

Evaluating

We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest.

Hardship distribution change for 403(b) plans

Section 602 (optional)

Plan years beginning December 31, 2023

Ready to support

We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources.

Domestic abuse distributions

Section 314 (optional)

Distributions made after December 31, 2023

Intend to support in 2025

Distributions for certain emergency expenses

Section 115 (optional)

Distributions made after December 31, 2023

Available November 1, 2024

Higher dollar limit for mandatory distributions

Section 304 (optional) 

Distributions made after December 31, 2023

In progress

We’re in the process of updating our Automatic IRA agreement to reflect the higher limit and expect to support this new limit. 

RMD treatment of Roth amounts ― Roth balance exclusion

Section 325 (mandatory) 

Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date 

Ready to support

Student loan payments as elective deferrals

Section 110 (optional) 

Plan years beginning after December 31, 2023 

In progress

We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. 

Required automatic enrollment and auto escalation

Section 101 (mandatory)

 

Plan years beginning after December 31, 2024 

Ready to support

Wider plan eligibility for part-time workers

Section 125 (mandatory) 

Plan years beginning after December 31, 2024 

Ready to support

 

Higher catch-up contribution limit for ages
60 to 63

Section 109 (optional) 

Taxable years beginning after December 31, 2024

Ready to support

Required Roth catch-up contributions for high-income earners

Section 603 (mandatory) 

Taxable years beginning after 2025

Ready to support soon

We encourage your clients to have a conversation with their payroll provider to ensure they’re prepared for Roth contributions and talk to their TPA about any necessary plan document amendments.

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