Dear NAGDCA Members,

We’re excited to announce that we’ve revamped how we communicate NAGDCA news and information.

Going forward, we will be providing two distinct communications. NAGDCA News will continue to be delivered to your inbox at the end of each month and will include association news, upcoming deadlines, conference updates, and member resources.

The second communication is a Director’s Brief, which will be sent mid-month. This communication will provide you with updates on the “behind the scenes” activities informing our advocacy and educational efforts, along with responses to member questions and requests for your thoughts, and retirement industry developments of import for you and your participants. Where meaningful, links to greater detail will be included for those of you interested in learning more. Additionally, the blog will be divided into clearly delineated sections and topics for ease of navigation.

We hope you find this new approach to communicating all that NAGDCA offers proves valuable. Please let me know what you think of the new format!

NAGDCA IN ACTION

Your Executive Board members, our representatives from Groom Law Group, and I recently traveled to Capitol Hill to advocate on your behalf. Our new “Midyear Update” contains a recap of those visits and includes thoughts on the road ahead. We have had productive conversations with congressional staff, but the legislative world will be quiet until after the mid-terms. It’s possible some of our Legislative Priorities could be addressed in a lame duck session after the elections, but that will depend on the results. We will have an update during our conference legislative session in Orlando, so stay tuned.

I also had the privilege of meeting with the board of the Municipal Employee Retirement System (MERS) of Michigan last month. I spoke about the big picture of what’s going on in retirement, and how it will impact our industry going forward. Thanks to Kerry Vanden Bosch and her team for the invite. I’ve spoken at several other committee meetings for members in the past, and if you’re interested in having me share my perspective with your board, don’t hesitate to ask.

MEMBER CORNER

SECURE 2.0 Section 603 (Roth Catch-Up) Uncertainty
We recently released an update to our Fact Sheet with answers to questions we received from many of you. One detail to note is that, while 457(b) plans are not expressly eligible for deemed elections, Roth contributions made before reaching the regular deferral limit can be considered when determining whether the Roth requirement has been satisfied.

Note, however, that some payroll providers are requiring all catch-up contributions for impacted employees to be Roth due to system limitations. Be sure to check with your payroll provider to understand their process and how it may impact your participants.

Delaware Passes Automatic Enrollment
Also, congratulations to our members from the State of Delaware who recently supported a state bill to allow automatic enrollment in their 457 plan! Delaware joins a growing list of states that have created legislation to help public employees save. Are you working on automatic enrollment legislation in your state? If so, we have tons of resources to aid you through the process, and I can write a letter of support for your initiative. Let us know how we can help.

Coming Soon: Certificate Courses for Public Sector DC Professionals
NAGDCA is developing a series of certificate courses designed specifically for public sector DC plan professionals. Our first course, The Fundamentals of Public Sector DC Plans, will be available later this year. The cost will be $500, with a $100 discount for those who attend a 2026 pre-conference workshop.

If you’re interested in learning more or participating, keep an eye out for an email from us in the coming weeks with additional details and information on how to sign up.

ACROSS THE INDUSTRY

Why Christian Non-Profits Are Asking for CITs in 403(b) Plans
We have advocated for a change to securities laws to authorize the use of CITs in 403(b) plans for several years given their typically lower costs. Most non-ERISA 403(b) plans cannot use CITs because securities laws have not changed to explicitly allow them. I say “most” 403(b) non-ERISA plans because Church Plans are an exception. Several years ago, Church 403(b) Plans were authorized to use CITs, and they have been doing so ever since.

However, the definition of a Church Plan excludes many organizations associated with religious groups, such as trade associations and non-profit organizations. Now, a coalition of those organizations is asking for Congress to act to allow them the same access to CITs as other plans. This is good news for our efforts, as it broadens the chorus of voices asking for investment vehicle parity across the industry.

Congressional staff is well aware of our stance, and we will continue to work on your behalf until this issue is resolved.

The DOL’s Proposed Rule on Private Assets
This recently-proposed rule addresses fiduciary selection of designated investment alternatives. The comment period is closed, and we chose not to comment. Your plans are not subject to DOL regulation, so we did not deem it appropriate to comment, and we did not want to give the impression that the DOL has authority over your plans.

That said, the proposed regulation had a lot of information that could provide good material for non-ERISA plans to inform your fiduciary processes when considering alternative assets. As such, once the rule is finalized, we will be creating material to share this information with you.

All the Best,

Matthew Petersen
Executive Director, NAGDCA