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 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 |
Evaluating We’re evaluating solutions based on IRS guidance. |
Terminal illness early distribution penalty tax exception Section 326 (optional) |
Distributions made after December 29, 2022 |
Ready 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 |
In progress 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 |
Ready to support by early 2025. |
Distributions for certain emergency expenses Section 115 (optional) |
Distributions made after December 31, 2023 |
Ready to support in late 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
|
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. |