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If a new plan with more than 10 people elect to have a QACA instead of the EACA with safe harbor basic matching, would this satisfy the auto-enroll requirement under SECURE 2.0?

Posted

EACAs and QACAs have different features.  Section 101 of SECURE 2.0 says the plan needs to be an EACA (to allow employee to withdraw any contributions and earnings made shortly after being auto-enrolled.)

A QACA does not have this withdrawal provision, but it does have the safe harbor match.

To answer the question, a non-grandfathered plan must be an EACA and can be both a QACA and an EACA.  A standalone QACA without an EACA is not permitted.

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