SAP & SECURE 2.0 Act of 2022

[former_member339104]

Do we have a ETA for the SAP & SECURE 2.0 Act of 2022 release ?

[ViswaRamamurthy]

Hello Henrique,
We are currently reviewing the requirements and working through multiple clarifications on the employer responsibilities and the implementation of the legislation with the authorities and partners as well. We plan to publish information on this in the coming weeks through Announcement of Legal Changes - SAP ONE Support Launchpad. Thank you for your patience.

~ Viswanath Ramamurthy
Product Manager - Payroll USA & Canada

[psrinivas12]

Hi Vishwanath,

We need to implement a solution for one secure 2.0 item which takes effect on Jan. 1st. Employees whose 2023 FICA taxable wages is more than $145,000 should have all their 2024 catchup contributions in Roth. i.e. no catchup contribution in pre-tax.

By when will SAP provide us a solution. Please let us know.

Regards

Paddy

[richaknotts79]

Hi Vishwanath,

Is there any update on the OSS note for Secures Act 2.0 requirement above?

Since this requirement is based on prior years FICA wages what happens if EE's go back and forth between making more than 145k one year but then less the next year.

This happens a lot in Healthcare and Higher Education sector.

Best Regards,

Richa

[ericjohnson]

Any update on this? Our 401k provider has released their guidance around what they are expecting when we send data over. I'd like to understand what SAP is planning on doing so we can begin to plan additional work if needed?

[richaknotts79]

Hi Attreyee,

Can you please add me to that list as well.

My email is richa.knotts@duke.edu

Best,

Richa

[Attreyee_B]

Hi Richa, invitation sent.

[Mike-Peace]

Hi Attreyee, I would like to be copied as well. Mike Peace

[shay_oberziger]

Dear customers,

The information is already available in the Announcement of Legal Changes - SAP ONE Support Launchpad .

Please refer to the following links:

Section 603 - Elective deferrals generally limited to regular contribution limit

Section 110 - Treatment of student loan payments as elective deferrals for purposes of matching cont...

Section 604 - Optional treatment of employer matching or nonelective contributions as Roth contribut...

Best regards,

Shay Oberziger

SAP Globalization Services

[ericjohnson]

Shay,

Thanks for pointing that out. Based on the comments in this thread, the issue that impacts most people is section 603. If you click on that link here is the wording from SAP. The solution is currently under analysis and it is still pending IRS clarification on some aspects of this Secure 2.0 Act statute. When can we expect a solution for section 603?

[greg_zifchock]

Section 604:

Has anyone configured a Wage Type for company match that would be considered on a Roth Basis. Someone has to pay the tax on that as "Roth" would imply. Do we treat that as income to the employee for tax purposes? Seems this would be complicated as it infers the employee has a choice to elect Pre-tax or Roth employer matching. The post indicates what SAP has already meets the need but how would we toggle between Pre and Roth on an employee by employee basis? There has to be something on IT169 that would indicate employee choice.

[Attreyee_B]

Dear Customers,

We continue to work on the above Sections and will update the timeline accordingly. However, to continue the discussion while maintaining the requisite level of confidentiality, I would request you to please join the SAP OnPremise Benefits Managment WorkZone Group. Please let me know if you face any issues doing so.

Thank you,
Attreyee

Product Manager, SAP OnPremise Benefits Management, US & CA

[ericjohnson]

I tried to click on the link but I get an access denied error.

[Attreyee_B]

I see, if you would be okay sharing your email id, I could invite you there.

[ericjohnson]

Sure its eric.johnson@tellurianinc dot com

[Attreyee_B]

Thank you, I sent you an invitation.

[ericjohnson]

Any update? We are almost in August.

[Attreyee_B]

Hi Eric

We continue to work on the Sections. For a further details, I would request you to read my comment further below.

Thank you,

Attreyee

Product Manager, SAP OnPremise Benefits Management, US & CA

[hemasuman_yalavarthi]

SAP Team,

We were asked to follow-up on this topic in the Community Forum. Due to multiple Legal Changes & the enormous amount of work involved, we are planning to implement the Solution as soon as we can. Please let us know if SAP has an update on this as it still says "In Analysis" under Legal Change Section.

Thanks,

Suman.

[kevinnguyen]

"I understand, we hope to have an ETA in a few more days, perhaps by next week."

Please keep us posted, since our benefit team keeps asking about it and what we can do from system perspective.

Thanks,

[ericjohnson]

Attreyee,

I looked and the update is that there is no update. Can you let us know when we will have an update that includes SAPs approach? This was a long time to wait for a no update update.

The solution is currently under analysis and it is still pending IRS clarification on some aspects of this Secure 2.0 Act statute.

[Attreyee_B]

Hi Eric,

I understand, we hope to have an ETA in a few more days, perhaps by next week.

Regards,

Attreyee Banerjee
Product Manager - SAP OnPremise Benefits Management USA & Canada

[Attreyee_B]

Hi Padmanabh, Richa, and Eric,

We are currently still working through multiple clarifications on the employer responsibilities and formulation an implementation proposal for the SECURE 2.0 Act requirements, including the Section 603 that you are referring to. Information on this via the Announcement of Legal Changes - SAP ONE Support Launchpad should be available tomorrow. Please follow it for further updates.

Regards,

Attreyee Banerjee

Product Manager - SAP OnPremise Benefits Management USA & Canada

[Maggie3654]

Is there any changes available for section 109 which allows employees age 60 through 63 to contribute the greater of $10,000 or 150% of the regular age 50 catchup contibution limit?