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Posted

Does SECURE 2.0 Mandatory Roth Catch-up Section 603 apply to the 403(b) special 15 year of service catch-up rules? I have not read anything that says it doesn't, but haven't specifically seen or heard anything that says it does. 

Any reason why the new rules would not apply to the special 15 year catch-up? 

edit: confirmed Section 603 only applies to age based catch-up.

Thanks

Posted

The mandatory Roth catch-up provision is part of section 414(v). Failure to comply negates section 414(v)(1), which allows plans to include "regular" catch-up contributions. The special 403(b) catch-up is provided by section 402(g)(7)(A), an entirely separate rule. Therefore, the Roth requirement doesn't affect it.

Tom Veal

ERISA Cavalry PLLC

www.ERISACavalry.com

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