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On August 19, 2024, the IRS released Notice 2024-63, offering interim guidance for sponsors of 401(k) and comparable retirement plans looking to offer matching contributions based on qualified student loan payments (QSLPs) made by their enrolled employees.
A QSLP is a payment made by an employee during a plan year to repay a qualified education loan for the employee, their spouse, or dependent. It must not exceed certain limits when combined with other payments for the year and must be certified by the employee for that plan year.
Background
The Consolidated Appropriations Act of 2023 is a bill that includes Setting Every Community Up for Retirement Enhancement (SECURE) 2.0 legislation. Section 110 of the SECURE 2.0 Act allows employers with a 401(k) plan, 403(b) plan, governmental 457(b) plan, or SIMPLE IRA plan to provide matching contributions based on employees’ student loan payments, rather than based only on elective contributions to retirement plans. It applies to contributions made for plan years beginning after December 31, 2023.
Highlights
The notice provides an overview of QSLP match programs and addresses a variety of plan administration issues including:
- General student loan matching contribution eligibility rules including dollar and timing limitations;
- Requirements for an employee certification that student loan matching contribution requirements have been met;
- Reasonable student loan matching contribution procedures that a plan may adopt; and
- Special nondiscrimination testing relief for 401(k) plans that include student loan matching contributions.
The Treasury Department and the IRS anticipate issuing proposed regulations on Section 110 of the SECURE 2.0 Act and welcome feedback. Plan sponsors can rely on this notice until the proposed regulations are released.
Applicability
The notice applies for plan years beginning after December 31, 2004. For plan years beginning before January 1, 2025, sponsors can rely on a good faith interpretation of Section 110. Download the bulletin for more details.
National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.
