SECURE 2.0: 401k plans that don't have Roth in them

Can a 401k plan continue to function without Roth in a post-SECURE 2.0 world?

Ignore the 'corner cases' where no one defers any catchup (whether because they defer low or there is no ADP failure recharacterized) or no one earns more than $145K (seriously, $145K?  Like we needed another limit to track?).

If someone earning $150K is required to make their catchup as Roth, then the plan has to allow Roth deferrals, right?  I know we don't have all the answers yet, but it seems unlikely that there will be a special carve-out we can use to not amend the typically older plans that never had Roth in them before to allow Roth deferrals.  And that amendment would have to be in place before any regular Roth deferrals are allowed, because the SECURE 2.0 amendment coming to a document near you in 2025 will only cover the catchup amounts.

I - and I'm sure most of us - have a whole segment of plans that just want to keep things nice and easy, and I'm looking for a way to do that here... and not finding it.  I'd rather the plan run smoothly than charge for correcting plan errors, personally.

Just one of the many things in Secure 2.0 where we need guidance but speculating it seems likely that the guidance maybe - amend out catch-ups (at least for folks over the $145K indexed) or amend in ROTH.

1 hour ago, Lou S. said:

Just one of the many things in Secure 2.0 where we need guidance but speculating it seems likely that the guidance maybe - amend out catch-ups (at least for folks over the $145K indexed) or amend in ROTH.

ROTH only for those making [pick a number at random] coming in SECURE 3.0.  But don't worry about plans terminating, it will also include a plan mandate for employers with [pick a number any number] employees.

kidding aside, I'm 99% sure we will see this in the next 10 years.