Read articles of interest for district administrators, payroll coordinators, and other district administrative staff.

Articles are available from the past year and are sorted by quarter based on the Benefits NewsBrief email for Wisconsin public school district employers. If you would like to be alerted to timely articles, please sign up at the Benefits NewsBrief subscription page.

July 2023 articles

Mutual Fund Change in July

A mutual fund change is coming in July. There will be a blackout period from July 24 to July 27, 2023. During this time, distributions, loans, exchanges, rebalances, and updates to future investment elections will be held for processing until after the fund changes. All of the other details can be found in a recent mutual fund change email. View a copy of the mutual fund change email here.

403(b) Automatic Enrollment Reminder

As one school year ends, another begins and with it comes the hiring of new employees. For districts using automatic. 403(b) enrollment, this means that the new hires need to be added to the 403(b) plan. An email will be sent to automatic enrollment Plan Sponsors that use WEA Member Benefits plan documents. The email will provide the Plan Sponsor with a copy of the automatic enrollment annual notice, which needs to be provided to all new employees. The email will be coming in late July or early August. Contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

Employment Status Updates and Plan Sponsor Access

Employment Status Updates

The end of the school year brings about employee changes. If your district has experienced employee retirements or terminations, it is important to relay this information to WEA Member Benefits each year. Updated employment status allows for processing of employee requests such as distributions and rollovers that require a qualifying event.

In addition, if your district offers an Employer contribution with a vesting schedule, it is important that unvested funds are removed from terminated/retired employees. It is good to get into the habit of updating separation of employment information on an annual basis in yourPlan Access system.

Employment status is located under “Participant Information.” Please call 1-800-279-4030, Extension 8579, to have the Plan Administration Team walk you through the online process.

Plan Sponsor Access – yourPLAN ACCESS™

The administrative office is not spared from employment changes. It is important to make sure that only active office personnel have access to the district’s 403(b) plan sponsor portal. In addition, it is important to make sure that authorized office personnel are only using the access that is assigned to them. If your district has experienced a change of employment in the business office, please make sure to contact us to remove the former employee and set up new access for the active employee. Contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

Introducing Brad Brinkmeier, Senior Retirement Enrollment Consultant

Brad Brinkmeier has been with WEA Member Benefits for seven years. During those seven years, his role as a Retirement and Investment Services Specialist provided him with opportunities to assist with new account enrollments. Brad is a registered representative and an outstanding resource for any employee who would like to ask questions and/or get assistance with enrollment. Brad can assist your staff with retirement account enrollments, answer questions about investments, and rollover outside accounts. Please provide his link to employees that are looking to set up the 403(b) or an IRA. Link: https://calendly.com/bbrinkmeier/403b-ira-phone-consultation.

SECURE 2.0 Update

The WEA Member Benefits Plan Administration team continues to evaluate SECURE 2.0. We will be providing additional education on the provisions as more IRS guidance is provided. A plan review with your Worksite Benefit Consultant (WBC) will be part of that education. Contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

Employee Financial Wellness Starts with the Employer and Benefits Everyone

Engagement in workplace retirement plans is fundamental to employees’ retirement readiness. When saving for the future, how prepared are your employees?

Member Benefits can help you explore the role school districts have in preparing their employees for retirement. Here are some of the topics we can help you address.

• Why having financially healthy employees saves school districts money.
• Why your employees aren’t saving and what you need to know to help them become financially healthy.
• The importance of financially healthy employees and the need for workplace financial wellness programs.
• A checklist every 403(b) plan should have.
• Future trends in school district 403(b) plans.
• Effective ways to encourage retirement savings at no additional cost to the district.

Your district’s WBC is here to assist you with your financial education plan. If you are unsure of your WBC’s contact information, contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com and they can provide you with that information.

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April 2023 articles

Qualified Birth and Adoption Distributions (QBAD)

Qualified Birth and Adoption Distributions (QBAD) became an optional in-service withdrawal under a 403(b) with the passing of The Setting Every Community Up for Retirement Enhancement (SECURE) Act that was passed in December 2019 and became law as of January 1, 2020. QBAD withdrawals are an optional provision that can be added to your 403(b) plan. If we are your document provider, the QBADs were part of the 2022 amendment process that was discussed with your Worksite Benefit Consultant.

A QBAD gives participants in an eligible 403(b) plan the opportunity for an in-service withdrawal anytime during the one-year period after the birth or legal adoption of a child. The SECURE Act defined QBADs as (1) not subject to the 10% early withdrawal penalty, (2) not treated as an eligible rollover distribution, (3) limited to $5,000 per qualifying event, and (4) repayments that can be made to a qualified retirement plan or an IRA.

The SECURE Act provisions left plan sponsors with more questions than answers. On September 2, 2020, the IRS issued Notice 2020-68, which provided the guidance for implementing QBADs. Notice 2020-68 provided the following clarification:

• Defined “eligible adoptee” as an individual who has not yet attained age 18 or is physically or mentally incapable of self-support. They further clarified that an “eligible adoptee” cannot be the child of the taxpayer’s spouse.
• A QBAD of up to $5,000 may be taken by each parent for the same child.
• The birth of multiple children or adoption of multiple eligible adoptees allows the individual to take a QBAD of up to $5,000 for each eligible child. If the birth or adoption was twins, the individual would be able to take a QBAD of up to $10,000.
• QBADs are discretionary. The plan sponsor is not required to add the option to their 403(b) plan. However, if it is allowed, the plan must allow for rollover contributions. The plan must allow the individual to repay the QBAD back into the plan.
• The individual requesting the QBAD can self-certify that they qualify unless the plan sponsor has actual knowledge to the contrary.
• An individual that takes a QBAD must provide the name, age, and taxpayer identification number of the child on their income tax returns for the year in which the distribution was made.

SECURE 2.0 became law on December 29, 2022, and cleared up the repayment of QBADs. Prior to SECURE 2.0, there was no time limit on the repayment of the QBAD. The enactment date of December 29, 2022, changed the repayment time limit to 3 years.

Is employment status information up to date for your employees?

Separation from service is one of the IRS qualifying events that allows employees access to their funds. It is important to have updated employment status information in the online system to aid in determining if a withdrawal or rollover is an option.

Updating employment status is quick and easy through the yourPLAN ACCESS™ portal. If you are not already updating employee information through yourPLAN ACCESS, we encourage you to contact Plan Administration at 1-800-279-4030, Extension 8579, or email at WEAPlanAdmin@weabenefits.com. We know that you will find this to be a convenient and easy way to make employee updates.

IRS 2022-2023 Priority Guidance Plan

The Priority Guidance Plan is a joint effort between the Department of the Treasury and the Internal Revenue Service to outline their focus for a 12-month period from July 1, 2022, through June 30, 2023. The full Priority Guidance Plan has 205 projects and will be updated throughout the plan year to allow for flexibility for new legislative developments. The second quarter update was released on February 21, 2023. The update reflects 101 items that were either completed or in process by December 31, 2022. There were 6 additional projects added in the February update. There are several Secure 2.0 items on the list, which will provide the additional guidance that is required to implement. Here are items that relate to the governmental 403(b):

• Regulations under 72(t) relating to the 10% additional tax on early distributions.
• Regulations relating to the timing of the use or allocation of forfeitures in qualified retirement plans.
• Regulations updating electronic delivery rules and other guidance for providing applicable notices and making participant elections.
• Guidance on student loan payments and qualified retirement plans and 403(b) plans.
• Guidance on missing participants, including guidance on uncashed checks.

WEA Member Benefits will continue to monitor and provide updates. Contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

SECURE 2.0 decisions need to be made

SECURE 2.0 became law on December 29, 2022; however, it is still a very fluid situation. There are a lot of questions that require further guidance from the IRS. One certainty is that another round of plan document amendments is needed. There are several optional provisions that plan sponsors should start looking at to determine if they will be added to plan documents. If WEA Member Benefits provides your plan documents, your Worksite Benefit Consultant (WBC) will review these in more detail during a 403(b) plan review. The optional items to start considering are:

• Emergency savings accounts provide employees an opportunity to save toward an emergency savings account linked to their employer plan (optional). These accounts are capped at $2,500, and the contributions are made on a Roth-like basis. The contributions are treated as elective deferrals and are included in matching contributions. Distributions are deemed to be qualified Roth distributions and are not taxable. A participant can take a distribution at least monthly, and the first four distributions may not be subject to any fees or charges. Any subsequent distributions may be charged reasonable fees. At separation of service, the emergency savings account can be rolled to a Roth source (if plan allows), rolled to a Roth IRA, or cashed out to the employee. This is available January 1, 2024.
• Emergency Distributions are a new hardship distribution of $1,000 per year (optional). However, the account owner is not eligible for another emergency distribution until the earlier of; 3 years or when the distribution amount is recontributed to a plan.
• Increase the mandatory distribution limit from $5,000 to $7,000. An employer may transfer former employee accounts from their retirement plan to an IRA if the balance is between $1,000 and $7,000 (optional). This is available January 1, 2024.
• Domestic abuse penalty-free distributions may be permitted in the amount of the lesser of $10,000 or 50% of the presently vested account balance (optional). The distribution can be self-certified and is available up to one year after the date the individual became a victim of domestic abuse. The distribution can be repaid within three years. This is effective after December 31, 2023.
• Student loan payments are treated as elective deferrals for purposes of matching contributions (optional). This will permit employers to make matching contributions to an employee’s 403(b) account based on the employee’s qualified student loan payments. An annual self-certification by the employee is required. This is available January 1, 2024.
• Hardship withdrawals can be taken from elective deferrals, qualified nonelective contributions, qualified matching contributions and earnings from all before mentioned contribution sources (optional). This is available for plan years beginning January 1, 2024.
• Safe harbor correction for elective deferral failures involving automatic enrollment or escalation is made permanent. If a correction is made within 9½ months after the end of the year of the failure (or sooner if notified by employee), a missed deferral does not have to be made (optional). This applies to a failure to implement a feature of automatic enrollment or a failure to offer an eligible employee an election. Treasury needs to provide more details on the regulations. As stated, the employee should be provided with a notice acknowledging the error and a QNEC made for any missed matched contributions.

Also, one of the mandatory provisions needs to be reviewed. In 2024, a plan that offers catch-up contributions needs to have the 403(b) Roth deferral source to continue to offer these contributions.

• Catch-up contributions are to be made in the form of Roth contributions. If a 403(b) plan allows catch-up contributions, those contributions must be made on an after-tax (Roth) basis. This means that a plan allowing catch-up contributions must also allow Roth contributions. An exception is made for employees with compensation of $145,000 or less (indexed). This is available January 1, 2024. This is mandatory, but if your plan does not offer Roth, it needs to be added to the plan to continue with catch-up contributions.

The items outlined above will be available January 1, 2024. WEA Member Benefits will be providing additional education on the provisions. A plan review with your WBC will be part of that education. This article is to start the thought process on what items fit with the goals for your district’s 403(b) plan. Contact the WEA Member Benefits Plan Administration team at 1-800‑279‑4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

I suggest standardizing either “effective after December 31” or “available January 1” throughout the document.

Automatic Enrollment and Auto Escalation

Automatic enrollment and auto escalation are great tools and a proactive way to encourage employees to save for retirement. Inertia is a common barrier to employees starting to save—automatic enrollment and auto escalation uses inertia to benefit the employee by switching the required action to opting out rather than requiring each employee to complete a 403(b) enrollment. The plan sponsor (school district) sets a default deferral amount and enrolls employees into the 403(b). The employee receives notice of enrollment and can opt out of the default deferral amount by entering zero, a different percentage, or flat dollar amount. A change from the defaulted pre-tax source to the Roth deferral is also an option for the employee.

Auto escalation is an added feature to the automatic enrollment benefit. Auto escalation automatically increases an employee’s 403(b) deferral rate at set intervals until reaching a predetermined maximum contribution rate selected by the employer. Like automatic enrollment, auto escalation uses inertia to benefit employees by overcoming the procrastination that commonly occurs with increasing contributions over time. The plan sponsor indicates the rate of increase (ex. 1%) and sets the maximum percentage (ex. 10%). In this example, the default deferral rate will increase 1% annually and will stop when the default deferral reaches 10%.

Automatic enrollment and auto escalation is part of SECURE 2.0 and will be mandatory for new ERISA 403(b) plans established in 2024. Existing plans are grandfathered. This does not apply to non-ERISA (governmental) 403(b) plans that are provided by public school districts. Although not required for your 403(b) plan, the addition of this benefit to SECURE 2.0 highlights the value of this option.

Hooray for summer (it is coming)!

There are a couple things that summer brings around that are not so exciting. These are construction and audit season. We have no relief for orange cones, but we can help with audits. The online system of yourPLAN ACCESS has a tab for reports which provides a great array of data for your audit.

The system can provide you with a list of employees that have 403(b) accounts in your plan. There are reports to display general census information, current contributions, employee balance information, or recent withdrawals. The reports available should aid in your audit needs. Please check out the options available in yourPLAN ACCESS under the “Reports” tab. If you have any questions or would like a tutorial, contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

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January 2023 articles

2023 contribution limits

Let your employees know that the 403(b) employee contribution limit increased to $22,500 in 2023 (2022 limit was $20,500). Those age 50 or over at the end of the calendar year can also make catch-up contributions of $7,500 (2022 catch-up was $6,500) beyond the basic limit on elective deferrals. If permitted by the 403(b) plan, an employee who has at least 15 years of service with the same eligible 403(b) employer may be able to contribute an additional $3,000.

The total contribution limit for both employee and employer contributions to 403(b) plans under section 415(c)(1)(A) increased from $61,000 to $66,000.

For more information on contribution limits in the 403(b) and IRA retirement savings programs, visit weabenefits.com/limits.

Required notices for 403(b) plans

The Universal Availability Notice (UAN) and 415 Notice need to be provided annually. There is no “provide by” date requirement; however, a common practice is to provide these documents with the W-2 distribution. The notices can be emailed, but a hard copy needs to be provided to employees who do not have access to email.

The UAN has two key components: opportunity and eligibility.

• The UAN opportunity provides the employee with the frequency of when salary reduction agreements can be made or changed.
• The UAN eligibility provides the details on which employees are permitted to make elective deferrals.

The 415 Notice provides employees with contribution limits and explains their responsibility for staying within those limits. It outlines the types of retirement accounts that are combined for that contribution limit.

If WEA Member Benefits is your document provider, an email was sent on January 4, 2023, with a link to the document portal. If you did not receive this link or have questions on the documents, please contact Plan Administration at 1-800-279-4030, Extension 8579, or WEAPlanAdmin@weabenefits.com.

SECURE 2.0 is law

The Senate passed the Consolidated Appropriations Act of 2023 (CAA) on December 22, 2022, and the House passed it on December 23. The bill was signed into law on December 29.

A part of CAA is SECURE 2.0. SECURE 2.0 is the consolidation of: Securing A Strong Retirement Act—House bill, the Enhancing American Retirement Now (EARN) Act—Senate Finance bill, and the Retirement Improvement and Savings Enhancement to Supplement Healthy Investment for the Nest Egg (RISE & SHINE) Act—Senate Health, Education, Labor and Pensions committee bill. As a result, it is a lengthy document that we will continue to review.  However, we wanted to highlight a few items that will directly impact your 403(b) plan.

Some provisions may be included (or not) at the discretion of the employer. These provisions are noted as “optional.”

Effective now:

• The required minimum distribution age increased from 72 to 73 beginning January 1, 2023. It will increase to age 75 in 2033.
• Qualified birth or adoption now restricted to three years (from no restriction). This became effective on date of enactment, which was December 29, 2022.
• Hardship withdrawals can be taken from elective deferrals, qualified nonelective contributions, qualified matching contributions, and earnings from all before-mentioned contribution sources. This is effective for plan years beginning after December 31, 2022.
• Hardship withdrawals can be self-certified. An employee can self-certify that they have a hardship event that is in compliance with safe harbor rules. This provision became effective when the Act was enacted, December 29, 2022.
• De minimis financial incentives can be offered by employers to encourage employees to contribute to retirement plan. The de minimis financial incentives cannot be paid from plan assets. There is no definition of what is considered de minimis. This provision also became effective when the Act was enacted, December 29, 2022.
• Student loan payments are treated as elective deferrals for purposes of matching contributions (optional). Employers are permitted to consider student loan payments to be elective deferrals for purposes of making matching contributions to the retirement plan. An annual self-certification by employee is required. This is effective January 1, 2023.
• Withdrawals for certain emergency expenses are exempted from the 10% premature tax penalty (optional). The emergency expense withdrawal is for unforeseeable or immediate financial needs relating to personal or family emergencies. One distribution per year of up to $1,000 is allowed with the option to repay the distribution within three years. An additional emergency distribution would be allowed if the account is “rebuilt”—either repayment within the three-year period of the prior distribution or making contributions equal to the distribution. This is effective after December 31, 2023.
• Employer matching or nonelective contributions can be designated as Roth contributions (optional). Employees have the option of receiving matching or nonelective contributions as Roth. It became effective at enactment on December 29, 2022.

Effective later:

• Saver’s match replaces the saver’s credit. The saver‘s credit is a refundable tax credit, while the saver’s match will apply a federal matching contribution directly to a taxpayer’s IRA or retirement plan account. The match equals 50% of an individual’s first $2,000 of contributions to an IRA or retirement plan. The maximum match amount is $1,000 and the minimum match is $100. The match phases out between income of $41,000 and $71,000 for taxpayers filing a joint return and $20,500 to $35,500 for single filers. This is effective for taxable years beginning after December 31, 2026.
• Increase to catch-up limit for those age 60, 61, 62, and 63. Plan participants may be able to add $10,000 more per year above the standard contribution limit. The limits may be different when this becomes effective after December 31, 2024.
• Emergency savings accounts provide employees an opportunity to save toward an emergency savings account linked to their employer plan (optional). These accounts are capped at $2,500, and the contributions are made on a Roth-like basis. The contributions are treated as elective deferrals and are included in matching contributions. Distributions are deemed to be qualified Roth distributions and are not taxable. A participant can take a distribution at least monthly, and the first four distributions may not be subject to any fees or charges. Any subsequent distributions may be charged reasonable fees. At separation of service, the emergency savings account can be rolled to a Roth source (if plan allows), rolled to a Roth IRA, or cashed out to the employee. This is effective after December 31, 2023.
• Increase the mandatory distribution limit from $5,000 to $7,000. An employer may transfer former employee accounts from their retirement plan to an IRA if the balance is between $1,000 and $7,000 (formerly $5,000). This is effective after December 31, 2023.
• Retirement savings “lost and found” to be created by the Department of Labor (DOL). It is an online searchable database for lost retirement accounts. The database will contain information on benefits owed to missing, lost, or non-responsive participants and/or beneficiaries in tax-qualified retirement plans. Participants and beneficiaries that have lost track of their retirement account will be able to search the database for plan administrator contact information. The database needs to be created no later than two years from the enactment date of December 29, 2022.
• Domestic abuse penalty-free distributions may be permitted in the amount of the lesser of $10,000 or 50% of the presently vested account balance. The distribution can be self-certified and is available up to one year after the date the individual became a victim of domestic abuse. The distribution can be repaid within three years. This is effective after December 31, 2023.
• Roth plan distributions to owner for required minimum distributions are eliminated to match Roth IRA rules. This eliminates pre-death required minimum distributions requirements for Roth accounts in employer plans. This is effective after December 31, 2023.
• Catch-up contributions are to be made in the form of Roth contributions. If a 403(b) plan wants to allow catch-up contributions, those contributions must be made on an after-tax (Roth) basis. This means that a plan allowing catch-up contributions must also allow Roth contributions. An exception is made for employees with compensation of $145,000 or less (indexed). This is effective after December 31, 2023.

Still mailing in checks for 403(b) remitting?

The start of a new year is a great time to make the switch from mailing paper checks to electronic remitting through the Automated Clearing House (ACH). The ACH option eliminates the extra time needed for mailing. This is beneficial given the Department of Labor rule that contributions should be made no later than 15 business days following the month of the payroll withholding. The transmission of contributions through an electronic method is the best way to reduce delay. If you are interested in setting up an electronic pull/push from your bank, please call our Plan Administration Team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com.

Protect your employees by making sure that only the appropriate business office personal have access to yourPLAN ACCESS

yourPLAN ACCESS, the online employer access site for Member Benefits’ 403(b) plan, offers many options for obtaining information about your 403(b) plan, and this needs to be protected.

Who has access is just as important as the type of access that is given to the employee. There are two types of access: 1) full—which provides access to the entire site and the ability to run reports and set up new accounts, or 2) payroll only—which will allow the user to enter and submit payroll rosters.

Member Benefits kicked off a campaign in mid-January to reach out to Plan Sponsors and ask that they review the employees that have access to yourPLAN ACCESS. Contact the WEA Member Benefits Plan Administration team at 1-800-279-4030, Extension 8579, or email them at WEAPlanAdmin@weabenefits.com with any questions.

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October 2022 articles

Timely 403(b) contributions

When contributions are not deposited timely, an operational failure occurs, which could lead to plan disqualification.  The Department of Labor (DOL) states employee contributions must be remitted to the plan by the earlier of the date when contributions can reasonably be segregated from employer’s general assets or the 15^th business day of the next month.  The DOL requires the employer to make up for the lost earnings on late contributions calculated from the date the deposit should have occurred through the date the actual deposit was made.

In many cases, the reason for late contributions is due to district office staff turnover.  Ideally, the outgoing district staff is available to train the new staff member.  However, this is not always feasible.

If a district finds themselves in this situation, Member Benefits is here to assist with the process.  The first step is to remit any late contributions.  The next step is to reach out to us by email at WEAPlanAdmin@weabenefits.com or call us at 1-800-279-4030 ext. 8579.

New 403(b) contribution limits

In late October or early November, the IRS will be releasing the 2023 contribution limits.  Retirement plan contribution limits are adjusted for inflation each year.  Inflation has been at elevated levels so the prediction is that contribution limits will increase for 2023.

As these rates are announced, it is a great time to review your 403(b) Salary Reduction Agreement (SRA).  The districts that use their own SRA often include 403(b) contribution limits that will need to be updated.  This creates an opportunity to share the updated form with your employees which might spark an increase in retirement savings.

Annual notices coming your way

If your district offers automatic enrollment, the Annual Notice to employees needs to be distributed each year by December 1. If your plan uses WEA Member Benefits’ 403(b) plan documents, we will send the automatic enrollment notice to you in November. Please watch for the email and reach out if you have questions or do not receive the notice by November 21, 2022.

403(b) plan sponsor are also required to provide all eligible employees with the Universal Availability Notice (UAN) and 415 Notice. If your plan uses WEA Member Benefits’ 403(b) plan documents, we will send these notices to you in January 2023. The UAN and 415 Notices reflect current year information, so to ensure that 2023 information is captured they will be sent in January. These notices need to be provided annually to employees but do not have a date requirement like the automatic enrollment notice.

Please contact Plan Administration at 800-279-4030, ext. 8579 or WEAPlanAdmin@weabenefits.com if you have any questions on these annual notices.

EARN Act, RISE and SHINE Act, and SECURE 2.0 Update

The Senate Finance Committee received the fully amended document of the Enhancing American Retirement Now (EARN) Act on Thursday, September 8.  The amended document had only a few minor changes including:

• Individuals age 60 or older could start making higher catch-up contributions in 2025 (versus 2024).
• Employees with wages below $100,000 could make catch-up contributions on a pretax or Roth basis. Employees with wages exceeding $100,000 would still be required to make catch-up contributions on a Roth basis.
• The option to treat employer contributions as Roth contributions would be available starting in 2023 (versus 2024).

The other Senate bill, the Retirement Improvement and Savings Enhancement to Supplement Healthy Investments for the Nest Egg Act (RISE and SHINE Act) is moving through the Senate Committee of Health, Education, Labor and Pensions.

The two Senate bills and the House of Representatives bill of Securing a Strong Retirement Act (SECURE 2.0) will likely be consolidated for the final legislation.  The final legislation is targeted for some time between Election Day and the end of the year.

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