SECURE 2.0 Implementation: Insights from a Plan Sponsor

NAGDCA [National Association of Government Defined Contribution Administrators]

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. 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: "The Treasury Department and the IRS have considered [this] suggestion and concluded that ... requiring all participants’ catch-up contributions to be designated Roth would be inconsistent with the language of section 402A(b)(1), which requires that a designated Roth contribution must be elected by an employee in lieu of elective deferrals."

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