- The SECURE Act 1.0 gave us Pooled Employer Plans, PEPs, for qualified plans.
- SECURE Act 2.0—effective for plan years beginning after December 31, 2022—extends PEPs and MEPs to 403(b) plans.
- While the legal effective date is already here, I haven’t yet seen any 403(b) MEPs or PEPs in the marketplace. So, the ”practical effective date” may be the 2024 plan year.
The President signed the Consolidated Appropriations Act, which included SECURE Act 2.0, on December 29, 2022.
SECURE Act 2.0 has over 90 provisions, some major and some minor; some mandatory and some optional; some retroactively effective and some that won’t be effective for years to come. One difference between the SECURE Act 2.0 and previous retirement plan laws is that many of 2.0’s provisions are optional…that is, plan sponsors are not required to adopt the provisions, but can adopt them if they decide that the change will help their plans and participants. This series discusses the provisions that are likely to be the most impactful, either as options or as required changes.
This article discusses the continuing extension of 401(k) concepts to 403(b) plans, specifically the SECURE Act 2.0 provisions for 403(b) PEPs and MEPs. This probably reflects the growing awareness of the higher costs in the 403(b) market, especially for smaller and midsized plans.