Roth 401(k) Plan Design and Compliance

Summary

This practice note addresses how plan sponsors can add a Roth contribution program to an existing 401(k) plan or other individual account plan like a 403(b) or governmental 457(b) plan. Further, it provides guidance on the advantages of adding the Roth feature and explains how to convert non-Roth accounts in a plan to Roth deferral accounts in the same plan. This practice note, which has been updated to reflect changes due to the SECURE 2.0 Act (Division T of Consolidated Appropriations Act, 2023 (Pub. L. No. 117-328)), also outlines issues that may arise with the administration of Roth deferrals and provides best practices when implementing a Roth contribution program.