Mike Hadley Featured on Broadcast Retirement Network Morning Program Discussing SECURE 2.0 Roth Catch-Up Requirement
- Published Date: October 29, 2025
Davis & Harman Partner, Mike Hadley, recently appeared as a guest on the Broadcast Retirement Network’s morning program alongside representatives from the SPARK Institute to discuss implementation of the new Roth catch-up contribution rule.
Hadley fielded questions regarding section 603 of the SECURE 2.0 Act of 2022, which requires higher paid employees who elect to make age-based catch-up contributions to do so on a Roth basis.
Hadley discussed the change stating that the most important thing plan sponsors need to know is that “for the vast majority of employers this [mandate] is not being delayed” and “you must comply with the new mandate starting in 2026.” He continued that “the IRS recently confirmed that to be the case. . .[and] plan sponsors are going to need to work your plan recordkeeper and payroll provider” to ensure proper compliance.
Hadley noted that plan recordkeepers are prepared for this change, however, it is important for plan sponsors to communicate with their service providers, including payroll providers, to ensure that all parties are prepared for the mandate taking effect.
Hadley further answered a question from Broadcast Retirement Network’s host, Jeff Snyder about what happens if a plan fails to comply with the new mandate. He stated that for 2026, plan sponsors must comply with the mandate using a “good faith interpretation of the statute. . . [and] in early 2027, if you’ve missed somebody. . . you’re going to have to correct it.” He further stated that if a plan fails to comply in 2027, it could jeopardize the plans qualified status and tax treatment.
A link to the full interview can be found here.
