Impending SECURE Act 2.0 Auto-Enrollment Requirement Prompts These Questions
Of Counsel Michelle Capezza’s insights were included in a Fiduciary News article about the SECURE Act 2.0’s auto-enrollment requirement.
Michelle comments on how the plan’s commencement date presents some complexity, especially considering existing IRS guidelines. She says, “A key factor to keep in mind, especially in the corporate transaction context, is that the requirements do not apply to 401k plans and 403(b) plans adopted before December 29, 2022 (among other exceptions). IRS Notice 2024-2 clarified that if two 401(k) plans established before December 29, 2022 are merged, the plan can continue to be exempt from the SECURE 2.0 Act auto-enrollment requirements.”
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