NAGDCA Executive Director Matt Petersen and Kelly Hiers, Defined Contribution Plans Administrator for the Virginia Retirement System, discuss the challenges and decision-making process around implementing both mandatory and optional provisions of SECURE 2.0. Kelly shares insights on plan design, participant needs, and administrative considerations that may help inform your approach.
Click here to download the results from our SECURE 2.0 implementation survey.
Correction Notice
During the webinar, a question was asked about whether all catch-up contributions could be changed to Roth to simplify the salary determination process. In response, Matt Petersen stated that this was possible. However, after further review, we’d like to clarify that the most recent IRS Proposed Regulation indicates that this approach does not meet the intent of the legislation. We apologize for the error and appreciate your understanding.
Reference: "16. Commenters also suggested that a plan be permitted to avoid having to correct section 414(v)(7) failures by requiring that all catch-up contributions be made as designated Roth contributions. The Treasury Department and the IRS have considered that suggestion and concluded that, for a participant who is not subject to the Roth catch-up requirement, allowing a plan design that requires all participants' catch-up contributions to be designated Roth contributions would be inconsistent with the language of section 402A(b)(1), which provides that a designated Roth contribution must be elected by an employee “in lieu of all or a portion of elective deferrals the employee is otherwise eligible to make.”
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- March 18, 2025 Create Date
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