The IRS recently issued Notice 2023-43 providing new interim guidance for self-correction of plan errors. This guidance applies to corrections made prior to the anticipated issuance of revisions to the Employee Plans Compliance Resolution System (“EPCRS”). Under this guidance, provided certain conditions are satisfied, most Eligible Inadvertent Failures (defined below) may be self-corrected, though there are specific types of failures that may not be self-corrected at this time (discussed below).
SECURE 2.0
SECURE 2.0 Opens the Door on Retirement Match Based on Student Loan Payments
The grab bag of retirement provisions in the SECURE 2.0 legislation that was enacted at the end of 2022 included an expansion of the ability for a section 401(k) or 403(b) plan, or a governmental section 457(b) plan, to provide matching contributions on participants’ student loan payments. Effective for plan years starting after December 31,…
SECURE 2.0 Brings Significant Changes for 403(b) Plans
As part of our continuing series on SECURE 2.0, signed into law December 29, 2022, this post focuses on significant changes for section 403(b) tax-sheltered annuity plans (“403(b) plans”). 403(b) plans are similar to 401(a) tax-qualified defined contribution plans but sponsored by public schools or non-profit entities and subject to unique requirements under the…

Pocket Guide to SECURE 2.0
SECURE 2.0 includes significant changes for retirement plan sponsors and employers, as discussed in our prior blog posts. If you are looking for a short summary organized by effective date, we have prepared a “pocket guide” chart, which can be downloaded here.
SECURE 2.0 Delivers New Rules for Correcting Retirement Plan Errors
As part of our ongoing series on SECURE 2.0, this post discusses three significant changes to corrections of common retirement plan errors: (1) New rules for correcting overpayments, (2) expansion of the Self-Correction Program under the IRS’s Employee Plans Compliance Resolution System (“EPCRS”) to cover most inadvertent errors, and (3) making permanent the current…
SECURE 2.0 Act of 2022 Arrives: (Another) Landmark Retirement Package
The wait is over for SECURE 2.0, a long-awaited (and debated) package of retirement plan reforms. Today, Congress passed the “SECURE 2.0 Act of 2022” as part of the 2023 Consolidated Appropriations Act; President Biden is expected to sign the bill into law soon. The bill text may be viewed here, and the Senate…