Beginning January 1, 2024, plan sponsors were going to have to provide mandatory Roth catch-up contributions for certain employees. This mandatory Rothification of catch-up contributions comes by way of Section 603 of Division 2 T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 4459 (2022) (SECURE 2.0 Act). However, without any Internal Revenue Service (IRS) guidance, many plan sponsors, recordkeepers, and payroll providers were struggling to understand the scope and proper implementation of this new provision (and even whether catch-up contributions were going to be permitted after 2023 in light of a glitch in the drafting of the legislative language implementing the change, which removed the clause permitting catch-up contributions to be tax-deferred. [IRC § 402(g)(1)(C), deleted pursuant to SECURE 2.0 § 603(b)] Thankfully, the IRS heard the call for help, and clarified the following three important points in Notice 2023-62...

Originally published in the Journal of Pension Benefits.