Letter shares comments with respect to catch-up contributions; requests additional guidance on PLESAs
FOR IMMEDIATE RELEASE
Lexington, KY, October 27, 2023—The National Association of Government Defined Contribution Administrators (NAGDCA) today announced that it has sent a comment communication to legal counsel at the U.S. Department of the Treasury and Internal Revenue Service in response Notice 2023-62, Guidance on Section 603 of the SECURE 2.0 Act. NAGDCA is the premier professional association for plan administrators and services providers of government-sponsored defined contribution retirement plans.
As stated in the comment letter, signed by NAGDCA Executive Director Matt Petersen, “…we gratefully express our thanks on behalf of our government members for the delay to section 603 provided in Notice 2023-62. Governmental plans often need additional time to implement new laws and regulations due to complexities in local law enabling requirements, payroll systems, and administration that most private sector employers do not face. We appreciate your efforts in crafting SECURE 2.0 guidance to date and provide the following feedback in response to your request for comments.”
Specifically, NAGDCA’s comment letter dated October 24, 2023 addresses three areas:
- Calculation of the $145,000 Limit
- defining compensation
- multiple employer plans
- FICA wages
- Long-Term, Part-Time Workers
- Emergency Savings Accounts
Additionally, the letter requests guidance regarding pension-linked emergency savings accounts (PLESAs):
- whether PLESAs may be established with current investment options, and
- what type of investments are considered satisfactory for government PLESAs.
Full text of the NAGDCA comment letter may be accessed here.
ABOUT NAGDCA
NAGDCA provides education, information, and training in all aspects of public plan administration to support members in creating plans that enable secure retirement outcomes for their participants. Additionally, NAGDCA is a co-founder with the Employee Benefit Research Institute of the Public Retirement Research Lab, a retirement industry-sponsored collaborative effort. The PRRL mines data from the PRRL Database, the first-ever database specific to public sector plan- and participant-level defined contribution data, to produce research aimed at enhancing understanding of the design and utilization of public sector defined contribution retirement plans. NAGDCA also conceived National Retirement Security Week to encourage retirement saving among government workers. Through its efforts, National Retirement Security Week evolved into National Retirement Security Month, a national effort to inspire American employees to save adequately for a secure retirement that is observed throughout the retirement industry during the month of October. It has received bipartisan Senate resolution since its conception in 2006. To learn more about NAGDCA, visit https://www.nagdca.org/.
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