Secure 2.0 - Document / Qualification Issues after 1/1/25?

Hello! Apologies if I missed a prior conversation on this. Has the IRS issued guidance for a plan that does not timely operate in accordance with the 3% minimum auto-enroll (plus appropriate auto increase and 90 day withdrawals)? Also, what about plans with exemptions that no longer qualify mid-year since EACA has to be a full plan year?

Thanks for your thoughts!

Section 350 of SECURE 2 provides generous corrections for failures related to auto enrollment.

The exemptions to 414A for new and small businesses don't expire immediately. It's 3 years for new businesses and the end of the year after the year in which they normally employ more than 10 employees for small businesses.  So there should be plenty of time to get the plan amended once the status changes.

Thank you CB!

No problem. I haven't seen any IRS guidance on plans not meeting the 3% auto-enroll. Those mid-year exemption issues can be tricky, though.