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New options under SECURE 2.0
The SECURE 2.0 Act was signed into law as part of the Consolidated Appropriations Act, 2023. One of its optional provisions enables participants to access their retirement accounts for emergencies.
Effective January 1, 2024, SECURE 2.0 expanded employees’ emergency access to their retirement funds. Plan sponsors may, but aren’t required to, offer an in-service withdrawal provision that allows employees to take one emergency withdrawal per year of up to $1,000.3
Plan sponsors may also establish pension-linked emergency savings accounts (PLESAs), which allow participants to build short-term savings through Roth payroll deferrals.4 Emergency withdrawals are easier to implement than PLESAs, so employers may be more likely to offer them in the near term.5
Should plan sponsors offer emergency withdrawals?
When determining whether to allow emergency withdrawals, plan sponsors must first decide whether to give employees access to their retirement savings for nonretirement reasons. The plan’s experience with loans and other types of nonretirement withdrawals might offer guidance.
For plans that offer loans, the number issued for less than $1,000 may indicate employee need for emergency funds. Plan sponsors may also want to review hardship and other in-service withdrawal rates. In 2023, among participants allowed to take those types of withdrawals, 3.6% took a hardship withdrawal and 4.0% took a nonhardship withdrawal.6 Emergency withdrawals could reduce the number of small loans and in-service withdrawals.
As alternatives, plan sponsors should consider whether to offer employee assistance programs (EAPs) and disability benefits that give participants access to funds in case of an emergency.
Preventing leakage by encouraging 401(k) plan withdrawal replacement
Emergency withdrawals from 401(k) or 403(b) plans can provide liquidity in times of financial stress, but they may also raise the risk of costly leakage from retirement savings. Annual withdrawals of $1,000—and the compounded market returns they forgo—could substantially slow participants’ retirement wealth accumulation.
Plan sponsors can help minimize leakage by encouraging participants to repay emergency withdrawals by increasing their contribution rates. Repayment nudges, including communications to participants who have requested withdrawals, could help participants to repay the withdrawn funds promptly, essentially treating the withdrawal as a loan. Our research shows that most participants would be able to repay the withdrawal amount over a reasonable time while maintaining their contribution rate.
To add optional emergency expense withdrawal provisions to your plan, contact your client success executive.
1 Board of Governors of the Federal Reserve System, Economic Well-Being of U.S. Households in 2022. May 2023.
2 Employee Benefit Research Institute. How Financial Factors Outside of a 401(k) Plan Can Impact Retirement Readiness, EBRI Issue Brief, No. 591. September 7, 2023.
3 Participants can’t take additional distributions for the next three calendar years unless they repay the distribution, either as a lump sum or through ongoing elective deferrals. After repaying, a participant may take another emergency withdrawal after one year (instead of having to wait three years). Any emergency withdrawal is taxable in the year of distribution, but participants under age 59½ won’t be subject to the 10% early distribution penalty.
4 Despite “pension” in their name, PLESAs are established in defined contribution retirement plans.
5 See, for example, Adam McMahon and Michael Hadley, Early Secure 2.0 Implementation Challenges for Recordkeepers & Employers, Bloomberg Law. September 2023.
6 Vanguard, How America Saves 2024.