FLASHPOINT: MAKE NO MISTAKE – IT’S STILL EFFECTIVE 1/1/2026!

By: Ilene H. Ferenczy, Esq., CPC, APA

Yes, the Treasury issued final regulations in relation to the SECURE 2.0 changes to catch-up contribution rules on September 15, 2025.  However, some of the articles published in the retirement plan press quickly may have confused you or given you a false sense of security about a possible delayed effective date.

We are writing today, in advance of finishing our analysis of the regulations, to simply state:  the new catch-up rules – including the requirement that certain highly paid individuals make catch-up contributions only in the form of Roth contributions – are still effective as of January 1, 2026.  For the period between that date and the date on which the final regulations are effective (i.e., January 1, 2027), you must comply with the new rules in good faith.  The safest way to do that is to follow the proposed or final regulations during 2026.

We are working hard to give you our thoughts and our practical recommendations about the regulations in an upcoming Ferenczy FlashPoint. Stay tuned.

And, if you have questions in the meantime, call us. Remember, we are your ERISA solution.