What is Section 110 of the SECURE 2.0 Act?
Section 110 of the SECURE 2.0 Act provides a new opportunity for employees with student debt to grow their retirement savings. It allows employees who are making student loan payments—but may not be able to contribute to their retirement plan due to financial constraints—to still receive employer matching contributions.
How Does It Work?
Under Section 110, employers can now treat student loan payments as if they were elective contributions to a retirement plan. This means that when an employee makes a payment on a qualified student loan, the employer can make a matching contribution to the employee’s 401(k), 403(b), SIMPLE IRA, or similar plan. Governmental employers can also provide this benefit in a 457(b) plan or other eligible plans.
Who Qualifies?
A “qualified student loan payment” is any debt incurred solely to pay for the employee’s own qualified higher education expenses. This opens the door for many employees burdened by student debt to start building retirement savings while paying down their loans.
Nondiscrimination Testing
For employers, Section 110 allows for separate nondiscrimination testing for employees who receive matching contributions on their student loan payments. This helps employers meet testing requirements while offering this unique benefit.
When Does It Start?
Section 110 takes effect for contributions made for plan years beginning after December 31, 2023. This new benefit is designed to help employees manage both their student loans and retirement savings more effectively, paving the way for a stronger financial future.