SECURE 2.0 tries to accomplish three primary goals:

• Get people to save more for retirement.
• Improve retirement rules.
• Lower the employer’s cost of setting up a retirement plan.

The following points are some of the most important provisions among the 90-plus contained in the final bill that are most likely to impact retirement plan sponsors and participants.

Effective in 2023

• Allowing 403(b) plans to participate in multiple employer plans (MEPs) and pooled employer plans (PEPs).
• Gradually increasing the required minimum distribution (RMD) age from the current 72 to age 75.
• Allow employers to offer small financial incentives for contributing to a plan.
• Improving coverage for part-time and seasonal workers. This change doesn’t really “become effective” in 2023. The actual coverage requirement begins in 2025. However, employers would be well-served to start tracking part time hours in 2023.
• Expanding the Employee Plans Compliance Resolution System (EPCRS) to, among other things, allow more types of errors to be corrected internally through self-correction.
• Providing permanent rules for the use of retirement funds in connection with qualified federally declared disasters.
• An employer may designate matching contributions or nonelective contributions as Roth contributions, provided that the participant is fully vested in such Roth employer contributions.

Effective in 2024

• Allowing employers to treat student loan payments as elective deferrals for purposes of matching contributions.
• Allow participants to take a withdrawal for emergency personal expenses which would be exempt from the IRS 10% premature distribution penalty tax.
• Allows the establishment of new emergency savings accounts linked to individual account plans.
• Increases the dollar limit for mandatory distributions from $5,000 to $7,000.
• Provides a safe harbor for corrections of employee elective deferral failures.
• Allows Age 50 and above to catch-up contributions that can only be made as Roth contributions for participants whose prior year wages were more than $145,000 (subject to annual cost of living adjustments in $5,000 increments).

Effective in 2025 and beyond

• Implementing higher catch-up limits for participants between the ages of 60 and 63.
• Establishing a Retirement Savings Lost and Found – the ACT directs the creation of the database no later than two years after the date of enactment.

Plan Amendments

Plan amendments to satisfy the Act must be adopted no later than the end of the 2025 plan year for nongovernmental plans, and the end of the 2027 plan year for governmental plans and collectively bargained plans. The Act also extends the plan amendment deadline for Setting Every Community Up for Retirement Enhancement Act of 2019, the Coronavirus Aid, Relief, and Economic Security Act (CARES) Act, and the Taxpayer Certainty and Disaster Tax Relief Act of 2020 to align with the plan amendment deadlines noted above.

This information was developed as a general guide to educate plan sponsors but it’s not intended as authoritative guidance or tax or legal advice. Each plan has unique requirements, and you should consult your attorney or tax advisor for guidance on your specific situation. In no way does Old National assure that, by using the information provided, a plan sponsor will be in compliance with ERISA regulations.