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Is It a Good Time to Consider a Student-Loan Repayment Match?
Experts from Groom Law Group and CAPTRUST answer questions concerning retirement plan administration and regulations.
Q: A while ago, after consulting with our ERISA attorney, we decided to delay approval of a student-loan-repayment match feature in our ERISA 403(b) plan because, as our counsel put it, there were too many outstanding questions regarding the benefit. Given the recent release of IRS Notice 2024-63, which provides clarification on retirement plan student loan repayments, do you think we can revisit this provision?
Kimberly Boberg, Kelly Geloneck, Emily Gerard and David Levine, with Groom Law Group, and Michael A. Webb, senior financial adviser at CAPTRUST, answer:
A: First of all, the Experts commend you for consulting with counsel prior to moving forward with a student loan repayment match, since we believe that counsel should be contacted prior to changing any plan provision, particularly one with such a significant impact.
As you note, IRS Notice 2024-63 provides important clarifications on retirement plan student loan repayments, answering a lot of questions, though some issues remain outstanding (with comments requested in a number of areas.) That said, in light of this recent release of the notice, the Experts do indeed suggest that it would be timely to revisit this issue with your ERISA attorney to consider the feature’s fit within your plan, particularly as you have already considered adding this provision.
NOTE: This feature is to provide general information only, does not constitute legal advice and cannot be used or substituted for legal or tax advice.
Do YOU have a question for the Experts? If so, we would love to hear from you! Simply forward your question to Amy.Resnick@issgovernance.com with Subject: Ask the Experts, and the Experts will do their best to answer your question in a future column.