IRS Provides Initial Guidance on Pension-Linked Emergency Savings Accounts: A New Avenue for Employee Savings

Internal Revenue Service (IRS)

WASHINGTON, D.C. — The Internal Revenue Service (IRS) has released preliminary guidance to assist employers in implementing the newly introduced Pension-Linked Emergency Savings Accounts (PLESAs). These accounts, authorized under the SECURE 2.0 Act of 2022, are poised to revolutionize how employees save for financial emergencies.

PLESAs represent a significant shift in personal finance planning, offering a structured and incentivized approach to emergency savings. These individual accounts are integrated into defined contribution plans, which are retirement plans where employees, employers, or both make contributions on a regular basis.

Starting from plan years beginning after December 31, 2023, employers have been permitted to offer PLESAs. In some cases, this means eligible employees could have started contributing to a PLESA as early as January 1, 2024.

One of the standout features of PLESAs is that they come with matching contributions. Employers match PLESA contributions at the same rate as contributions made to the linked defined contribution plan, subject to certain restrictions. This employer-matching aspect can provide a strong incentive for employees to contribute to these accounts, bolstering their emergency savings.

Interestingly, employees don’t necessarily need to be participating in an employer’s defined contribution plan to contribute to a PLESA. As long as they are eligible to participate in the plan and their employer offers a PLESA, they can contribute.

However, there are some limits. The maximum balance in a PLESA, attributable to contributions, is set at $2,500. But employers have the discretion to establish a lower limit if they wish.

From a tax perspective, PLESAs are treated as designated Roth accounts. While contributions are not tax-deductible, withdrawals are generally tax-free. This is particularly beneficial during a financial emergency when every dollar counts. Participants can access their funds held in the PLESA at least once a month, providing a safety net during financial hardships.

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The IRS’s guidance comes as a welcome resource for employers navigating this new terrain. Notice 2024-22, posted on the IRS website, provides insights on measures employers who offer PLESAs can take to prevent potential manipulation of the PLESA matching contribution rules. The notice also opens the floor to public comment, inviting perspectives from all stakeholders.

The introduction of PLESAs represents an important step forward in promoting financial security among employees. By encouraging emergency savings and offering a tax-efficient way to access these funds, PLESAs could play a crucial role in mitigating the financial impact of unexpected expenses. For employers, offering PLESAs could enhance their benefits package, potentially aiding in employee retention and recruitment. As we move into 2024, the impact of this innovative approach to emergency savings will be keenly watched.

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