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On August 25, 2023, the IRS published Notice
2023-62 to provide initial guidance on, and a two-year delay of, the SECURE 2.0 Act requirement related to Roth catch-up contributions for high earners.
This delays the rule until January 1, 2026.
There will be a two-year “administrative transition period” with respect to the rule during which it will not be enforced. In other words, the IRS granted the two-year delay that was requested.
The Notice also confirms that participants will continue to be able to make catch-up contributions in 2024 and beyond.
Additionally, The IRS announced that it intends to issue further, more detailed, guidance about this rule during the next two years. However, this two-year delay is a big win for plan sponsors and participants because it prevents sponsors from having to make a choice between eliminating catch-up contributions effective January 1, 2024, or trying to implement a rule with so many unknowns.
As managing director, Todd leads the Lawley Retirement Advisors team and oversees retirement planning, customized investment, and relationship management.