What Your Retirement Plan Provider Should Be Discussing with You Before Year-End

Start with what's required

The most immediate priority for many plan sponsors is ensuring they’re prepared for required SECURE 2.0 provisions and the upcoming plan amendment deadline. It’s important to stress that sponsors can’t simply assume plan providers are handling everything. Successful implementation requires coordination with a variety of key partners.

To start, organizations should review which SECURE 2.0 provisions apply to their plan, including items such as Roth catch-up requirements, automatic enrollment provisions for eligible new plans and long-term part-time employee requirements.

Next, they'll need to assess:

• Whether plan operations align with those requirements
• Readiness for the December 31, 2026 amendment deadline
• Coordination among payroll providers, recordkeepers, TPAs and ERISA counsel
• Any potential compliance or operational gaps

As part of that review, sponsors should ensure that operational practices align with the provisions included in their plan documents.

"Plan documents and plan operations need to tell the same story," shares Tyler Slaght, Retirement Plan Consultant at Associated Bank. "Many SECURE 2.0 provisions have already been in effect for some time, and fiduciaries should be comfortable knowing that those changes have been implemented correctly.”

Slaght emphasizes that “reviewing operational practices now and finalizing amendments before the deadline is an important part of prudent plan governance."

Understand the Roth catch-up requirement

One of the most discussed SECURE 2.0 changes is the Roth catch-up requirement.

For eligible higher-income participants, catch-up contributions must now be made on a Roth basis. While the provision may sound straightforward, instituting it often means multiple systems and stakeholders.

Plan sponsors should be having discussions around timely topics, including:

• Payroll readiness
• Employee communication strategies
• Recordkeeping considerations
• Potential testing and administrative impacts
• Ongoing operational monitoring

A knowledgeable provider can help coordinate these conversations and identify issues before they become participant or compliance concerns.

Look beyond compliance to participant needs

Not every SECURE 2.0 provision is required, but several optional features may be worth evaluating based on your employee demographics and organizational goals.

For example, SECURE 2.0 created new opportunities to support employees facing unexpected financial challenges through provisions such as:

• Emergency expense distributions
• Student loan matching contributions
• Domestic abuse distributions

The right solution depends on your mix of employees. A younger workforce managing student debt may have different needs than an organization with aging employees preparing for retirement.

That's why SECURE 2.0 discussions should be focused on people, not just the regulations.

A provider who understands your business, your culture and your employees can help determine which optional provisions may improve participation, engagement and retirement readiness while supporting your business objectives.

Questions for plan sponsors to ask before year-end

As you evaluate your plan, consider:

• How are we preparing for the SECURE 2.0 amendment deadline?
• Do our plan operations match the amendments we intend to adopt?
• Have all service providers confirmed implementation readiness?
• Are there optional SECURE 2.0 provisions that could benefit our employees?
• How do these choices align with our employee demographics and business goals?

Why the right retirement plan partner matters

SECURE 2.0 isn't just about checking a compliance box. It's an opportunity to evaluate whether your retirement plan is meeting the needs of today's workforce while maintaining strong fiduciary oversight.

“Whether you're finalizing required amendments, navigating Roth catch-up implementation or evaluating participant-focused provisions, having the right partner is imperative.” Slaght continues with a strong reminder, “Don't wait until the amendment deadline is around the corner. Stay informed, ask questions and take time now to evaluate your options.”

Associated Bank's retirement plan consultants can help your organization understand which SECURE 2.0 provisions apply, identify implementation gaps and evaluate opportunities that may benefit both employers and employees. Connect with an Associated Bank retirement plan consultant today.