Just Catching Up? Oops! Congress Clarifies Catch-Up Contributions Are Here to Stay

By Sarah L. Engle and Brian Tiemann on July 7, 2023

Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act

Section 603 of the SECURE 2.0 Act requires catch-up contributions made by certain high-wage earners to be made on a Roth basis beginning in 2024. But it also contains one of the most talked about technical errors in the legislation, one that resulted in Congress eliminating all catch-up contributions—for everyone. Not surprisingly, that isn’t quite what Congress had in mind.

Sarah L. Engle
Sarah Engle focuses her practice on employee benefits matters. She counsels clients regarding a variety of issues, including the design, drafting and operation of tax-qualified pension and profit sharing plans, health and welfare arrangements, and deferred compensation plans. Sarah has experience advising clients on employee benefits design, implementation and transition matters arising in connection with corporate mergers and acquisitions. Read Sarah Engle's full bio.

Brian Tiemann
Brian J. Tiemann counsels public and private companies on a broad range of employee benefit matters, including matters related to pension plans, 401(k) plans and executive and incentive compensation. He advises plan fiduciaries with respect to their fiduciary duties, investment policies and alternative investments. He also advises multinational clients on global employee benefits matters, particularly with respect to global incentive compensation plans. Brian has extensive experience negotiating investment management agreements and service provider agreements. Read Brian Tiemann's full bio.

Just Catching Up? Oops! Congress Clarifies Catch-Up Contributions Are Here to Stay

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