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SECURE 2.0: Guidance on Exception to Early Distribution Penalty for Terminally Ill Individuals

Seyfarth Synopsis: As previously reported here, on December 20, 2023, the IRS issued Notice 2024-2 (the “Notice”) providing guidance on several outstanding questions related to provisions under SECURE 2.0. This blog post...more

“SECURE-ing” the Answers to Outstanding Questions on the Rothification of Employer Contributions

Seyfarth Synopsis: Under Section 604 of Secure 2.0, sponsors of 401(k), 403(b) and governmental plans may allow employees to designate employer match (including match on student loan repayments) or nonelective contributions...more

SECURE Act 2.0: Hold My Beer

Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019 (“SECURE 1.0”), significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the...more

Beware of the “Overshare”: Construe Requests for ERISA Plan Documents Narrowly!

Seyfarth Synopsis: Administrators of ERISA plans frequently receive requests from participants, beneficiaries, and their representatives for plan-related documents. A recent decision from the Court of Appeals for the Fifth...more

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