Automatic enrollment in 2025

So, suppose you have a plan that doesn't qualify for any of the exceptions, so the SECURE auto-enrollment provisions apply. Plan is an ACA, but not an EACA, so will have to be amended to be an EACA, SECURE provisions, etc., etc. 

If the participant already has an election in place, can this be "carried over" under the updated SECURE plan provisions? Would your answer change if the election in place is LESS THAN the minimum 3%? 

23 hours ago, Belgarath said:

 

If the participant already has an election in place, can this be "carried over" under the updated SECURE plan provisions? Would your answer change if the election in place is LESS THAN the minimum 3%? 

I'd have to check to be sure but my gut says that an affirmative election should be good for both your examples. 

Thanks - that was what my gut was telling me also, but SECURE/2.0 sometimes causes digestive ailments...

Will the revised automatic-contribution arrangement call for a notice, perhaps 30 days before the new year begins?

If so, is that an opportunity to specify a new default that, unless the participant opts out, applies starting with the first pay date in the new year?

Might such a default, regarding a participant who already has a cash-or-deferred election in effect, be the greater of the usual default under the revised automatic-contribution arrangement or the election (whether affirmative or a default) in effect just before the revised takes effect?

These are open questions. I do not know the tax law, plan documents, or other practicalities of how automatic-contribution arrangements work.