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Groom Law Group Releases Brief on the Impact of the SECURE Act on Church Plans
On February 3, 2020, the Groom Law Group released its publication, Church Plans Under the SECURE Act. The brief summarizes the most significant provisions of the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) that apply to church plans. Groom Law indicates that church plan sponsors should begin to consider the impact of the changes on their defined benefit (DB) and defined contribution (DC) plans. Specifically, they should evaluate any required changes of the new distribution rules in plan terms, recordkeeping, reporting and communications.
The brief summarizes the following provisions:
- Clarification that non-qualified church-controlled organizations can participate in Internal Revenue Code section 403(b)(9) retirement income accounts;
- Treatment of 403(b) custodial accounts upon plan termination;
- Treatment of part-timers under 401(k) plans where the 410(b) nondiscrimination rule applies; and
- Distribution changes affecting church plans.
The brief is available here.