Secure 2.0 requirements for 401k coming 1/2024

Does anyone know if Infor has said anything about plans to address the new rule going into effect on 1/2024 requiring "higher paid" employees to make catch-up contributions through a Roth 401k? If you aren't aware yet, the new rule is: Higher Paid Participants” with compensation exceeding $145,000 for any plan year can only make catch-up contributions on a Roth after-tax basis. If at least one participant is subject to this mandate, participants who are not “higher paid” must be given the option to make Roth catch-up contributions."

We currently offer only a traditional 401k and are working on adding the Roth 401k plan to accommodate this rule. We are trying to work through all the nuances of having 2 plans, ensuring limits are considering contributions in both plans, and how the system can identify these "higher paid" employees in a non-manual way. We are using Lawson BN for the plans and Lawson PR for the processing (V10). Wondering if anyone is further ahead than us and/or if anyone knows Infor's plans.

ERs with less than 5_20200508.xlsx

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Craig Breverman

Glad you brought this up.
I spoke with INFOR on this subject a few weeks ago and was not under the impression INFOR was taking a position on it directly, and instead encouraging clients to use their own resources.

Would appreciate this string being used for updates and information.

Darla Hengel

At this time, Infor does not have anything in the works to address the Secure 2.0 requirements as the existing functionality of the Benefit system will accommodate for the changes via customer setup. Infor does not process catch-up contributions; those are processed by BSI via links to Infor's Group Code field. BSI has not yet informed Infor of any changes they will be making regarding Secure 2.0.

If BSI releases new functionality to support Secure 2.0, and changes need to be made by Infor, further assessment of those changes will be made at that time.

sandy-clemons

I also reached out to BSI about this and they have indicated that they monitoring the Secure Act 2.0 Catch Up Contribution changes and they are still waiting for regulatory guidance before introducing the changes in a future regulatory bulletin.

Craig Breverman

@djh Any updates to this?

Darla Hengel

There have been no updates from BSI regarding any changes.

mp33580

More SECURE 2.0 - Has anyone heard anything from BSI about handing the Higher Catch-Up Limit Applicable to participants who will turn ages 60 to 63 during the calendar year effective 1/1/2025?

cindy-taylor

I would like to know also. I think we will need to add a new group with the limits for ages 60-63 and that group code would be added to the employee's HR11 record.

BMF_Entwurf_20120321.pdf

dbrucke1

That is our thought process and is what we are planning on doing as well.

mp33580

We are hoping that it is as simple as that.

kristen-rotzenberg

We run payroll/benefits in cloudsuite currently. I have a ticket open with Infor to confirm how they recommend we implement this change. I just heard back that they are recommending to add a new group in BSI with the increased limit for those age 60-63. Planning to test this out later this week. Wanted to share even though we are no longer using S3 as that piece works similarly.

dEPM-655.mp4

lisa-noles

Any update on the highly compensated employees and the catch-up contributions through an aft-tax ROTH plan? Our Retirement team is asking questions about how this will be handled by Infor and BSI in 2026.

lindsey-cole

It's my understanding Infor has a solution for HR Talent Cloudsuite, but not for S3 Lawson. We are working towards a custom solution since we are still running payroll in S3.

Gelangens_Anlage_Entwurf.pdf

0811181026417683.xls

lisa-noles

Thank you Lindsey. We are on S3 also. I entered a ticket with Infor asking what their plan is. I'll let you know how they respond. We are also thinking of a plan B if Infor/BSI won't do anything for S3.

rm_benefit_administration_aca_training.pptx

Infor Nexus_SC_DQ_Jan26_2021_OceanOnTimeKPI.mp4

denise-buggs

Do either of you mind sharing your thought process for the custom solution? Our team is in the process of investigating solutions.

Please let me know if you care to have offline conversations.

linda-telles

I would also be interested in hearing about the custom solution. We have had a few employees upset that we are not participating this year.

valerie-latawiec

We were thinking 4 different BSI groups.
As of 01/01/2026, we can split the BSI401CATCH deduction group employees into 2 groups and those in BSI401SIXTY into 2 groups.
1. A new BSI group for ages 60-63 & FICA wages >= $145k in the previous year. (i.e. BSI401SIXTY2)
• Contribution limit for BSI401SIXTY2 for 401(k) (DED_CODE=4KPE) would be at the standard max.
• Contribution limit for BSI401SIXTY2 for Roth (DED_CODE=4KRE) would be at the standard max plus the age 60 catch-up max.
2. A new BSI group for age 50+, excluding those ages 60-63 & FICA wages >= $145k in the previous year. (i.e. BSI401CATCH2)
• Contribution limit for BSI401CATCH2 for 401(k) (DED_CODE=4KPE) would be at the standard max.
• Contribution limit for BSI401CATCH2 for Roth (DED_CODE=4KRE) would be at the standard max plus the catch-up max.
3. BSI group for ages 60-63 and FICA wages < $145k in the previous year. (BSI401SIXTY)
• Contribution limit for BSI401SIXTY for 401(k) (DED_CODE=4KPE) would be at the standard max plus the age 60 catch-up max.
• Contribution limit for BSI401SIXTY for Roth (DED_CODE=4KRE) would be at the standard max plus the age 60 catch-up max.
4. BSI group for age 50+ and FICA wages < $145k in the previous year. (BSI401CATCH)
• Contribution limit for BSI401CATCH for 401(k) (DED_CODE=4KPE) would be at the standard max plus the catch-up max.
• Contribution limit for BSI401CATCH for Roth (DED_CODE=4KRE) would be at the standard max plus the catch-up max.

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