On October 3, 2024, the IRS issued guidance on applying the Long-Term, Part-Time Employee (LTPT) rules to 403(b) plans beginning in 2025, as enacted in the legislation known as SECURE 2.0 in IRS Notice 2024-73 (Notice). The LTPT rules were first enacted to apply to 401(k) plans in the legislation known as the SECURE Act.
403(b) Plans
Notice 2024-02 Guidance on Distributions to the Terminally Ill
This article is the fifth in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice). The first article addressed the extension of the deadline for written amendments and de minimis…
When Automatic Isn’t Automatic: Notice 2024-02 Guidance on Self-Correcting Auto-Enrollment And Auto-Escalation Failures
This article is the fourth in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice). The first article addressed the extension of the deadline for written amendments and de minimis…
New Plan Automatic Enrollment Guidance Under IRS Notice 2024-02
This article is the third in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice). The first article addressed the extension of the deadline for written amendments and de minimis…
Guidance on Roth Matching or Nonelective Contributions in IRS Notice 2024-02
This article is the second in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 in Notice 2024-02 (Notice). The first article addressed the extension of the deadline for written amendments and de minimis…
COVID-19 Disaster Declarations Permit Employees Access to Hardship Distributions
If you’ve been wondering why I haven’t posted about the effects of COVID-19 on employee benefits it’s because I’ve been practicing social network distancing. Just kidding. While we await Congress to pass and the President to sign the 2 trillion dollar stimulus package known as the CARES Act, I thought I would point out how…
Hardship Proposed Regulations Require Thought About Plan Design
Last November, the IRS issued proposed regulations incorporating several legislative changes regarding the ability of a 401(k) or 403(b) plan to make distributions to participants to relieve a hardship caused by an immediate and heavy financial…