SECURE Act and Long Term Part-Time Employees

[ErnieG]

Would appreciate opinions/comments on this.  Going through §112 of the SECURE Act referencing elective deferrals for long-term part-time employees.  Section 112 (a)(1) references §401(k)(2)(D) which is the Code Section that allows for a cash or deferred arrangement.  Section 112 does not reference §402A relating to Roth contributions.  Therefore a long-term part-time employee can make elective deferrals but not Roth contributions.  Is this an oversight?  Or am I missing something?  Thank you.

[duckthing]

Not sure I follow your reading of 401(k)(2)(D). That specific item relates only to the statutory service requirement under 410(a)(1), and all they've done is change it to the earlier of the prior requirement or 500 hours in 3 consecutive years.

[ErnieG]

duckthing, thank you.  I understand the statutory service requirement.  What I am questioning is, does the reference to "elective deferrals" apply to Roth contributions as outlined in the SECURE Act §112?

[C. B. Zeller]

I don't imagine it was their intention to exclude long-term part-time employees from Roth eligibility. Since no one will become eligible under these rules for a few years still, hopefully there will be some official guidance to clear the issue up before then.

[ErnieG]

CB agreed, thank you.