Retirement
January 03, 2023
With the new year comes a new federal law that makes it easier for retirement plan participants to save—and save more—and for plan sponsors to offer plans and enroll participants.
The SECURE Act 2.0, a follow-up to the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019, brings largely good news.
“SECURE 2.0 will give millions of Americans a better chance for retirement success, and can help employers attract and retain talented employees,” said Janet Luxton, senior ERISA consultant at Vanguard. “Employees will be able to save more through increased catch-up contributions, receive matches on student loan repayments, and maximize retirement savings with increased Roth opportunities.”
Most of the new law’s provisions are not effective until January 1, 2024, or later. However, some optional provisions are effective immediately.
Here are several highlights of the new law and explanations of what they mean for plan sponsors and participants.
Participants ages 60 through 63 can contribute the greater of $10,000 or 50% more than the standard catch-up amount to their defined contribution (DC) plan beginning in 2025. But because the government intends to use the taxes collected from Roth contributions to fund other provisions in the legislation, all catch-up contributions by workers making more than $145,000 must be Roth (that is, made with after-tax dollars) starting in 2024.1 Lower-paid employees may still contribute catch-up contributions on a pre-tax basis. Plans will have to offer a Roth option to allow catch-up contributions of any kind. Both the $10,000 and $145,000 amounts will be indexed for inflation once effective.
What it means for plan sponsors and participants: We encourage the sponsors of plans that do not allow for Roth contributions to consider offering that option, so participants already making catch-up contributions can keep making them—and newly eligible participants can start.
Beginning in 2024, employers can make employer matching contributions for their employees’ student loan payments, even if the employees aren’t contributing to their plan. These contributions could help employees who are paying off their student loans to start saving sooner—or save more—for retirement.
What it means for plan sponsors and participants: Plan sponsors should consider the participation and saving behaviors of their employees (6-page PDF) before deciding to offer student loan payment matching contributions.
Previously, employers’ matching and nonelective contributions could only be pre-tax. Effective immediately, 401(k), 403(b), and government 457(b) plans have the option of allowing participants to designate their employers’ matching or nonelective contributions as Roth contributions. Only matching contributions that would otherwise be 100% vested can be designated as Roth contributions.
What it means for plan sponsors and participants: Designating certain employer contributions as Roth can provide additional retirement savings flexibility and financial planning opportunities for participants. Plan sponsors should weigh whether adopting this option might benefit their participants, based on the participant population’s demographics and income levels. Participants who fall under a plan with this option might consult an advisor to assess the potential benefit.
A new provision allows for the automatic transfer of a participant’s account valued at under $5,000 into the new employer’s retirement plan unless the participant chooses otherwise.
What it means for plan sponsors and participants: Participants can benefit from a novel portability feature Vanguard is proud to have helped pioneer. Auto-portability helps plan participants receive benefits to which they are entitled by consolidating retirement accounts from various employers. For plan sponsors, this feature could help reduce the incidence of “missing participants.”
The new law requires employers to adopt automatic saving provisions in DC plans that are established after 2024. Employers offering new retirement plans must automatically enroll new hires at a saving rate of at least 3% of pay and automatically increase their saving rate by at least 1% every year up to at least 10% but not to exceed 15%.
What it means for plan sponsors and participants: Employers that currently offer 401(k) or 403(b) plans are not required to add these automatic features. However, Vanguard research shows that automatic plan designs increase both saving and participation rates. For plans without automatic plan design, plan sponsors may want to consider adding these features.
Despite intensive advocacy efforts by Vanguard, among others, the new law does not include the necessary provisions to allow 403(b) plans to offer low-cost investments through collective investment trusts (CITs)—popular options in 401(k) plans. For now, participants in 403(b) plans can invest only in mutual funds and certain insurance products.
Vanguard will continue to advocate for allowing CITs to be part of a 403(b) plan’s investment lineup. We are committed to seeing this investment opportunity extended to all retirement plans.
This article highlights only a few of the changes that SECURE Act 2.0 brings. We will continue to study the details and provide guidance on their likely impact on investors, plan sponsors, and participants.
This article was updated February 2, 2023, with information about the optional Roth designation for employers’ matching and nonelective contributions and the provision to allow 529 plan assets to be rolled over into a Roth IRA.
1 "After-tax” means that participants must pay taxes on the earnings they contribute in the year in which they earn the money. All Roth contributions are after-tax.
All investing is subject to risk, including the possible loss of the money you invest.
Collective trusts are not mutual funds. These investments are available only to tax-qualified plans and their eligible participants. Investment objectives, risks, charges, expenses, and other important information should be considered carefully before investing.
Investments in target-date funds are subject to the risks of their underlying funds. The year in the fund name refers to the approximate year (the target date) when an investor in the fund would retire and leave the work force. The fund will gradually shift its emphasis from more aggressive investments to more conservative ones based on its target date. An investment in target date funds is not guaranteed at any time, including on or after the target date.