SECURE 2.0: What it means for plan sponsors, participants 

“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 you and your 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 2026.¹ 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 you and your participants: If your plan doesn’t already allow for Roth contributions, we encourage you to consider offering a Roth option so that 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 you and your participants: Plan sponsors should consider the participation and saving behaviors of their employees before deciding to offer student loan payment matching contributions.

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 you and your 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 you and your participants: Employers who currently offer a 401(k) or 403(b) plan 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. 

• Participant access to emergency savings. Beginning in 2024, SECURE 2.0 provides employers with two ways to allow participants access to funds in case of an emergency. First, employers may offer participants an emergency savings withdrawal of up to $1,000 per year. This withdrawal is not subject to an early withdrawal penalty and may be repaid over three years. Second, in addition to or instead of the emergency savings withdrawal, employers may offer non-highly compensated participants an emergency savings account as part of their retirement plan. Employees may voluntarily contribute or may be automatically enrolled at up to 3% of their annual pay (capped at $2,500). Contributions will be after-tax and subject to the plan’s match (if any). Participants may take a distribution from their emergency savings account at any time.
  
  
• Delayed required minimum distributions (RMDs). The age at which participants must begin taking distributions from their retirement accounts jumps from 72 to 73 beginning January 1, 2023, and to 75 in 2033.
  
  
• Improvements to performance benchmarks for target-date funds. Current regulations require a fund’s investment performance to be compared with a market index benchmark. This does not properly account for target-date funds (TDFs), which feature a mix of asset classes. Under the new law, TDFs will be able to use benchmarks that are more accurate and effective, allowing participants to make more informed investment choices.

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. Employers do not have to implement most changes right away, giving you some time to prepare. Vanguard welcomes these reforms, which should help millions of Americans get on a better path to retirement.