SECURE 2.0 amendment

What is everyone doing for SECURE 2.0?  I realize the amendment is not yet due and we are tracking the very few optional provisions elected by clients.

I don't believe I've seen an interim amendment from FIS other than for a terminating plan.  We've notified clients of the LTPT rule for 2024 and then again for the 2025 change.  I'd like to get a SMM out with that, along with the higher cash-out limit.

Thank you

Tom

Mostly just the distributions at this point. Adding roth to any plans that don't have it. 

I believe FIS is tentatively planning to have a SECURE/2.0 amendment available late 3rd quarter of this year. The amendment for tax-exempt 457(b) plans is slated to be available sooner.

Of course, it ain't over 'till it's over. As we saw in the massive choke by Duke... 

@Tom is your question coming solely from the standpoint of the plan document, or is it more from the standpoint of plan administration?

From the standpoint of the plan document, I am not aware of any of the major Mass Submitter having issued a SECURE 2.0 amendment. 

From the standpoint of plan administration, several recordkeepers have notified their plan sponsor clients that they will apply default administrative decisions to the plans for which they provide recordkeeping services.  The most common provision I have seen in increasing the cash-out threshold from $5000 to $7000.  It remains up to the plan sponsor client to request an override of the default.

If any clients have made affirmative, documented administrative elections of SECURE 2.0 choices, then these choices should have been clearly communicated to all employees.  These communications technically are not SMMs given that an SMM discloses a modification to the plan documentation.  Nevertheless, it is important that plan sponsors do communicate the changes to employees as if the plan was amended.