Spring Forward…But Don’t Sleep on This One.
A message from Chad Carleton
We all lost an hour last month. The clocks jumped forward, the days got longer, and most of us stumbled through that first Monday a little groggier than usual. If only we could hit snooze on everything else that’s due.
Unfortunately, the IRS doesn’t come with a snooze button — and if you sponsor a 401(k), 403(b), SIMPLE IRA, or SEP plan, your SECURE Act 2.0 plan amendment is on the clock. The good news? You’ve still got time. The even better news? We’re here to help you not sleep through it.
⏰ What’s the Alarm Going Off About?
The SECURE Act 2.0 — signed into law in late 2022 — made some meaningful changes to how retirement plans operate. The IRS has actually been pretty generous with the snooze button on these amendments, extending deadlines more than once. But for most 401(k) and 403(b) plan sponsors, December 31, 2026 is the final wake-up call. No more extensions are expected.
Here’s a quick look at the key changes your plan document needs to reflect:
RMDs got pushed back. The required minimum distribution age is now 73 (and will eventually move to 75). If your plan document lists a specific age, it needs to be updated.
Hardship distributions got simpler. Participants can now self-certify that they qualify for a hardship withdrawal, rather than having to dig up documentation. Your plan document needs to reflect this updated standard.
Roth catch-up is coming in 2026. Employees earning over $150,000 will be required to make catch-up contributions on a Roth (after-tax) basis. If your plan allows catch-up contributions, this one’s important to have on your radar now.
New penalty-free distribution reasons. Emergency expenses, domestic abuse, terminal illness, and federally declared disasters have all been added as qualifying reasons for penalty-free withdrawals. If you want your plan to allow these, the document has to say so.
Student loan matching is now a thing. Employers can treat qualifying student loan payments as deferrals for matching purposes. It’s optional — but a benefit worth a conversation.
☕ You’ve Already Gotten Up — Now Let’s Make the Bed.
Here’s something a lot of plan sponsors don’t realize: many of these provisions are already supposed to be in effect operationally. The amendment isn’t introducing something brand new — it’s formalizing what your plan should already be doing.
Think of it like this: the hard part (getting out of bed) is already done. The amendment is just making the bed. And yes, it still has to happen.
☀️ Tennessee Pension Administrators Has Your Coffee Ready
You don’t have to figure this out half-awake. Here’s what working with our team looks like:
We’ll review your current plan document and identify exactly which amendments apply to you
We’ll provide suggested best practices and recommended elections for each provision — so you’re not guessing
We’ll draft the amendment and walk you through everything that needs to be signed
We’ll help you think through optional provisions — like student loan matching — that might be a great fit for your team
The days are getting longer. Let’s use the extra light.
📅 A Few Things to Keep in Mind
Don’t wait until December. Amendments typically need internal review and sometimes board or trustee approval before they can be signed. Give yourself a runway.
Coordinate with payroll and HR. Especially around the Roth catch-up requirement — your systems will need to be ready when 2026 arrives.
Update your SPD. Once the amendment is adopted, participants are entitled to notice of any material changes. We can help with this too.
📞 Ready to Get Moving?
Reach out to your TPA Plan Manager today and let’s get this scheduled. Whether you have a quick question or you’re ready to kick off the full amendment process, we’re glad to help — no extra caffeine required.
TPA has put together a summary of our best practices related to the SECURE Act 2.0 amendment. Please follow the link below to review our best practices.