Washington, D.C., October 18, 2024 – The ERISA Industry Committee (ERIC) today applauded the Department of the Treasury and the Internal Revenue Service (IRS) for issuing Notice 2024-63, interim guidance implementing Section 110 of the SECURE 2.0 Act with “Respect to Matching Contributions Made on Account of Qualified Student Loan Payments” (Notice). The Notice outlines guidance for implementing programs providing employer matching contributions to retirement plans on account of qualified student loan payments (QSLPs).
“Employees often choose between paying off their debt or saving for retirement. It should not be a choice between one or the other. Employers want to match student loan payments with contributions to retirement programs to help meet the needs of their employees. But for these programs to be attractive to employers and employees, the parameters for how these programs operate need to be clear,” said Andy Banducci, Senior Vice President of Retirement and Compensation Policy at ERIC. “The interim guidance was a good start, but regulators can do more to help employers design and execute programs that best serve their employees.”
In the comment letter, ERIC requested that forthcoming proposed regulations incorporate technical recommendations that address the following issues:
- Model plan amendments that can be adopted to implement QSLP matches.
- Confirmation that plan sponsors and administrators are permitted to receive information about the amount and date of loan payments either directly from the lender or a third-party service provider.
- Additional examples detailing “reasonable procedures” that employers may institute, including alignment of deadlines under the statute for employees to claim the match.
ERIC member companies sponsor retirement plans, including defined benefit and defined contribution plans, governed by the Employee Retirement Income Security Act of 1974, as amended.
Click here to read ERIC’s comments