December 2023

Authors: Steven Grieb Kelly Lazzara


On December 20, 2023, the IRS issued Notice 2024-2, which contains guidance in question-and-answer format regarding a host of compliance changes pursuant to the SECURE 2.0 Act of 2022. The Notice isn't intended to provide comprehensive guidance, but rather is intended to provide direction on discreet issues to assist retirement plan sponsors when beginning to implement certain SECURE 2.0 provisions. The Notice states that the IRS will continue to issue further guidance, including regulations, on SECURE 2.0 matters.

This paper addresses the following significant provisions of the Notice relating to defined contribution plans.

  • Automatic enrollment mandate
  • Tax credits for start-up plans of small employers
  • De minimis financial incentives
  • Distributions to terminally ill participants
  • Correcting elective deferral errors in automatic enrollment plans
  • Contributing employer contributions on a Roth basis
  • Amendment deadlines

The paper also gives Gallagher insights into the mandates, notably that the Notice answers some common questions about applying the automatic enrollment mandate and what financial incentives are considered de minimis.

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