PLANADVISER - Summer 2023 - 36
Compliance Analysis
Match for Student Debtors
The top 6 things plan advisers need to know
EMPLOYERS that sponsor savings-based plans such as
401(k)s and who employ college graduates will want to
know more about the SECURE-for Setting Every Community
Up for Retirement Enhancement-2.0 Act provision that
permits matching contributions for eligible employees who
are paying off their qualifying student loans. Plan advisers
can help plan committees understand and implement this
new opportunity. And the time to study it is now, because,
if the change is implemented January 1, 2024, plans should
inform employees about it before the end of this year.
Here are six things plan advisers should keep in mind:
1) Qualified student loan payments. The new provision
applies to matching contributions for " qualified student loan
payments, " made by employees eligible to make deferrals
to the retirement plan. A QSLP is payment for indebtedness
incurred by the employee solely to pay for that person's qualified
higher education expenses. Even though the employee
does not actually contribute to the plan, the QSLPs are
treated as if he had deferred those amounts to it. The QSLP
" deferrals " are subject to the annual dollar limit that otherwise
applies to elective deferrals. Plan sponsors have the
option of matching QSLPs once a year after the year ends,
vs. on a payroll basis, and it is likely that most will do that.
For plan sponsors that implement this provision, there
could be a significant increase in the number of participants
receiving matching contributions, namely employees who
have not been deferring because of their student loan obligations
but who will want to receive QSLP matching contributions.
Plan committees will need to consider this cost-
i.e., the additional matching contribution-in determining
whether to implement the provision.
2) Employee certifications. The plan sponsor can rely on
an employee's certification that QSLPs were made. This is
good news, and advisers should make sure plan committees
know they don't need to verify the payments. Recordkeepers
will likely be preparing election forms to help implement this.
3) It's not just for 401(k) plans. QSLP matching contributions
can be offered under a range of deferral-based plans,
including 401(k)s, 403(b)s, SIMPLE IRAs [savings incentive
match plan for employees individual retirement accounts]
and 457(b) governmental plans. Advisers should discuss this
new feature with their client plan sponsors and committees.
4) Participant education. Advisers can work with clients'
recordkeepers to help the committees educate participants
36 planadviser.com | Summer 2023 | Awards & Innovation
Art by Brian Scagnelli
http://www.planadviser.com
PLANADVISER - Summer 2023
Table of Contents for the Digital Edition of PLANADVISER - Summer 2023
Leadership in Practice
SECURE 2.0 Insecurities
The Need for NQDC Support
Advisers’ Huge Opportunity
Do 3(38)s Assume More Risk?
Match for Student Debtors
'The Question Stands
PLANADVISER - Summer 2023 - C1
PLANADVISER - Summer 2023 - C2
PLANADVISER - Summer 2023 - 1
PLANADVISER - Summer 2023 - 2
PLANADVISER - Summer 2023 - 3
PLANADVISER - Summer 2023 - 4
PLANADVISER - Summer 2023 - 5
PLANADVISER - Summer 2023 - 6
PLANADVISER - Summer 2023 - 7
PLANADVISER - Summer 2023 - 8
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PLANADVISER - Summer 2023 - 10
PLANADVISER - Summer 2023 - 11
PLANADVISER - Summer 2023 - 12
PLANADVISER - Summer 2023 - 13
PLANADVISER - Summer 2023 - 14
PLANADVISER - Summer 2023 - 15
PLANADVISER - Summer 2023 - Leadership in Practice
PLANADVISER - Summer 2023 - 17
PLANADVISER - Summer 2023 - 18
PLANADVISER - Summer 2023 - 19
PLANADVISER - Summer 2023 - 20
PLANADVISER - Summer 2023 - 21
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PLANADVISER - Summer 2023 - 23
PLANADVISER - Summer 2023 - 24
PLANADVISER - Summer 2023 - 25
PLANADVISER - Summer 2023 - 26
PLANADVISER - Summer 2023 - 27
PLANADVISER - Summer 2023 - SECURE 2.0 Insecurities
PLANADVISER - Summer 2023 - 29
PLANADVISER - Summer 2023 - 30
PLANADVISER - Summer 2023 - 31
PLANADVISER - Summer 2023 - The Need for NQDC Support
PLANADVISER - Summer 2023 - 33
PLANADVISER - Summer 2023 - Advisers’ Huge Opportunity
PLANADVISER - Summer 2023 - Do 3(38)s Assume More Risk?
PLANADVISER - Summer 2023 - Match for Student Debtors
PLANADVISER - Summer 2023 - 37
PLANADVISER - Summer 2023 - 'The Question Stands
PLANADVISER - Summer 2023 - 39
PLANADVISER - Summer 2023 - 40
PLANADVISER - Summer 2023 - C3
PLANADVISER - Summer 2023 - C4
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