Secure 2.0 - Self Correction of Retirement Plans
Theresa Conti, QKA, APR, ERPA, CPFA
Retirement Industry Consultant, Author, Speaker/Coach for Women in Financial Services
My final post relating to Secure 2.0 is about the expansion of what can be self-corrected in retirement plans.? What we are talking about when we talk about self-correction is things that happen in the day to day administration of a retirement plan.? We all know that mistakes happen and that retirement plans continue to become complex so having a method for doing self-correction is always preferred.
In 2021, EPCRS was updated to allow for self-correction of “insignificant” operational failures in plans
Secure 2.0 was expanded to now allow us to correct any “eligible inadvertent failure
So basically, in my mind, most of the things we come across now can be corrected under the Secure 2.0 act.? If it is something that is not covered, I personally would refer it to an ERISA Attorney as there is probably way more involved that needs to be dealt with!
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The other thing that is allowed is that typically we can correct things before the IRS has found them and is corrected in a reasonable amount of time.? Some of the things that we could not previously correct under self-correction but now can include failures involving plan loans, plan document failures like a failure to timely adopt an amendment, and it could include eligibility types of failures.
A few things that plan sponsors should consider when it comes to self-correction is to work with an established and experienced TPA
The final note is to make sure complete records are kept relating to the correction so that if it is ever questioned that you can prove what was done and all related calculations.? Again, a good reason to use an experienced service provider to help you!