Retirement Plans

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Seyfarth Synopsis: Section 103 of the SECURE Act 2.0 replaces the Saver’s Credit with a new matching contribution from the federal government. Since the enactment of SECURE 2.0, there have been a number of questions about the implementation of this new matching contribution, and how it will operate. In IRS Notice 2026-48 (“Notice”), the Treasury Department and IRS announced that they intend to propose regulations and other guidance regarding the Saver’s Match program. The Notice does not establish proposed or final regulations. Rather, it outlines the government’s current views on how it expects the Saver’s Match program to work and previews issues that Treasury and the IRS anticipate addressing in future guidance.

What is the Saver’s Match?

Beginning in 2027, the Saver’s Match will replace the federal Saver’s Credit. By way of background, the Saver’s Credit is an income tax credit of up to $1,000 ($2,000 if married filing jointly) that reduces a taxpayer’s federal income tax liability.   

Instead of providing a tax credit, the Saver’s Match is a contribution to an employer’s qualified retirement plan or an IRA from the federal government of up to 50% of what the taxpayer contributes to the retirement plan or IRA, capped at a match of up to $1,000. The Saver’s Match rate is based on an individual’s tax filing status and modified adjusted gross income. For married individuals filing jointly, the match applies to each spouse. Certain individuals, such as those that are under age 18, are not eligible. After SECURE 2.0 was enacted, a number of open questions arose with respect to the Saver’s Match, primarily administrative questions and concerns. For example:

  • Are employer-sponsored retirement plans required to accept these contributions?
  • How will taxpayers “apply” for the Saver’s Match contribution?
  • How will these Saver’s Match contributions be transmitted from Treasury to an employer-sponsored retirement plan?
  • What do employer’s do with these contributions once they are in the plan?  Do they have to be separately tracked?
  • What withdrawal, distribution and reporting requirements apply to Saver’s Match contributions?
  • Will recordkeeper/TPA platforms support these contributions?
  • What if errors arise in the calculation and/or transmittal of the Saver’s Match? How are these issues corrected?

The Notice directly addresses several of the questions outlined above, while leaving room for additional guidance and regulations.

Continue Reading New Saver’s Match, New Plan Sponsor Decisions
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On February 25, 2026, the Department of Labor (DOL) issued proposed regulations implementing Section 338 of SECURE 2.0, which generally requires defined contribution plan administrators to furnish at least one benefit statement on paper every calendar year and defined benefit plan administrators to furnish at least one pension benefit statement on paper every three calendar…

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Since 2019, Congress has enacted three major pieces of legislation impacting retirement plans, significantly changing the retirement landscape. The legislation contained a number of amendments to the Internal Revenue Code and the Employee Retirement Income Security Act, as amended, that impact employer-sponsored retirement plans (e.g., 401(k) plans, 403(b) plans, defined benefit plans, and even Puerto…

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If you are tired of keeping track of which retirement plan investments are deemed “good” and which are suddenly “bad”, we have encouraging news. The Department of Labor’s (“DOL’s”) latest proposed rule goes back to the fundamentals and our favorite mantra—it’s not what you pick, it’s how you pick it.

The DOL’s proposed…

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Seyfarth Synopsis: The IRS is back to work and just announced the 2026 annual limits that will apply to tax-qualified retirement plans. But wait, there’s more – a surprise increase in the inaugural FICA wage limit for purposes of the mandatory Roth catch-up requirement.  Employers maintaining tax-qualified retirement plans will need to make sure their plans’ administrative procedures are adjusted accordingly.

In Notice 2025-67, the IRS announced the various limits that apply to tax-qualified retirement plans in 2026. The “regular” contribution limit for employees who participate in 401(k), 403(b) and most 457 plans will increase from $23,500 to $24,500 in 2026. The “catch-up” contribution limit for individuals who are or will be age 50 by the end of 2026 is increased from $7,500 to $8,000. 

However, the “super” catch-up contribution limit for individuals aged 60 to 63 on December 31, 2026, remains $11,250. Some were expecting that limit to be indexed to 150% of the regular catch-up limit. However, the Internal Revenue Code provides that the limit is the greater of $10,000 or 150% of the 2024 catch-up limit (i.e., $7,500). As a result, the “super” catch-up contribution limit remains $11,250 for 2026, and the $11,250 limit may be indexed for inflation in future years. 

Continue Reading Shutdown’s Over—IRS Wastes No Time Reminding You You’re Still Not Saving Enough
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The Treasury and IRS have released final regulations implementing key SECURE 2.0 provisions, including the Roth catch-up requirement for high earners and…

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Seyfarth Synopsis: Earlier today, Treasury and the IRS issued highly-anticipated final regulations addressing several changes to the catch-up contribution provisions implemented by SECURE 2.0.  Proposed regulations were issued earlier this year (see our Legal Update here), and administrative questions lingered following the issuance of the proposed regulations. The much-welcomed final regulations answer a number of open questions that we had been grappling with following the enactment of SECURE 2.0 and the issuance of the proposed regulations earlier this year. Below is a high-level overview of several pressing issues that have been addressed by the final regulations. We will be issuing a more comprehensive Legal Update on the final rules in the coming days.

1. Designated Roth Contributions Counted for Purposes of Roth Catch-up Requirement

Under the proposed regulations, designated Roth contributions made by a participant at any point within a calendar year must be counted towards satisfying the Roth catch-up requirement (“Roth Catch-Up Requirement”). This provision caused administrative concerns and several commenters asked that the final rules make this permissive so that plans had the choice as to whether to include Roth deferrals made by the participant at any point in the calendar year towards the Roth Catch-Up Requirement. The final regulations provide plan administrators that use the deemed Roth approach with some – but not universal – flexibility. The final regulations do not seem to go so far as making this optional approach available in all situations, which we will cover in the forthcoming Legal Update. 

Continue Reading Final Catch-Up Rules: What Now? (Spoiler Alert: There is No Extension)

In this episode, Richard is joined by Alan Wilmit, serving as co-host, as they welcome Ada Dolph, a Partner in Seyfarth’s ERISA Litigation group, to unpack the complexities of pension risk transfers (PRTs). Ada explains what PRTs are, how they’re used to manage pension liabilities, and why they’re drawing increased scrutiny. The conversation covers…

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Seyfarth Synopsis: Just before its summer recess, the Supreme Court agreed to review whether multiemployer pension funds can impose withdrawal liability based on actuarial assumptions adopted after the relevant plan year. The expected decision may have significant implications for employers’ ability to assess the impact of a contemplated withdrawal.

At the end of June, the Supreme Court granted certiorari in M & K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund, No. 23-1209 (U.S. June 30, 2025 amended July 3, 2025) to consider an important question in calculating how much employers withdrawing from multiemployer pension funds are legally obligated to pay.

Withdrawing employers have to pay a portion of the fund’s unfunded vested benefits (i.e. the amount of vested benefits that a fund is legally obligated to pay but for which the fund does not have sufficient assets to meet). The withdrawal liability calculation is to be determined based on the fund’s financials as of the end of the plan year before the withdrawal. It can take many funds six months if not more after the end of a plan year to finalize their year-end financials and thus be able to issue a withdrawal liability assessment in the following plan year. In that interim, as the financials are being finalized, fund actuaries have on occasion changed actuarial assumptions, such as interest rates or mortality tables, retroactive to the prior plan year.

Continue Reading Changing Last Year’s Assumptions This Year: Gotcha or Copacetic?
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Seyfarth Synopsis: Under the current administration, the Department of Labor has once again changed course on its view of permissible investing strategies for retirement plans, warming to crypto and private equity, and confirming their distrust of ESG.

Over the last decade, there has been quite a bit of back and forth surrounding permissible investments…