Secure Act 2.0 Question

Hello,

Under SECURE 2.0, there is a provision that requires catch up contributions for employees making $145k/year to be done on a Roth basis. I know this does NOT apply to SIMPLE IRA plans. Is there any clarification as to whether this would be required for a SIMPLE 401k plan?

Thank you.



I think it applies to SIMPLE 401k plans since they fall under Sec 401k, not 408(p) which are exempt from this provision of Secure 2.0. (Sec 603). That said Sec 603 will not go into effect until 2026 as the IRS needs more time to consider the extensive guidance that will be needed.  The added complexity this will cause all parties is such that this provision would be better off not having been included in Secure 2.0.



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