SECURE 2.0 - Amend now or later?

[Sully]

We just received the 2025 SECURE 2.0 Amendment from ftWilliam. Most, if not all, of our clients will be going with the default selections in the amendment.

Out of curiosity, are firms having their clients formally adopt the amendment now, or are most waiting until the required deadline of December 31, 2026?

Thank you!

[Peter Gulia]

It’s now 20 years since I last had an inside-the-service-provider responsibility about scheduling plan amendments. So, other BenefitsLink neighbors might help you with current thinking about business interests in organizing the work.

Consider plan sponsors’ preferences. Although some might like delay, some might prefer to avoid being time-pressured or feeling burdened in a cycle or season of the plan sponsor’s business.

If some of your clients use a lawyer’s review to supplement yours, consider a courtesy of allowing time before the last months of a year. Many lawyers, including employee-benefits lawyers, face increasing work compressions as a year’s close nears. If a December 31 is a relevant due date, time in November and December can be heavily pressured, or even no longer available.

If some of your clients neglect to respond promptly to what you send, consider how many reminders and warnings you want to build into your work process.

[Belgarath]

Re followups - we were late to the party for implementing electronic signature software. I'm not sure what the technical name is (that's for the systems wizards - I'm just a user). It is an Adobe system, and OMG, the time it saves! When you send the document to be signed and dated, you input the need=by date, and the follow-up frequency - once every week, for example. System does it for you, and sends you the signed and dated document once the client does it. I love it!

[Gilmore]

7 hours ago, Belgarath said:

It is an Adobe system

Is it Adobe Sign?  We use the version that comes with our Adobe Acrobat Pro so it is not as robust as the full Adobe Sign or DocuSign, but for us it works and it was a game changer.