Back-to-School Special: IRS Offers Insight on Implementing Qualified Student Loan Payments

By , and on October 15, 2024

On August 19, 2024, the Internal Revenue Service issued Notice 2024-63 (the Notice), providing guidance regarding the implementation of Section 110 of the SECURE 2.0 Act of 2022, which permits employers with a 401(k) plan or 403(b) plan to provide matching contributions to employees based on employee student loan payments. Through various questions and answers, the Notice provides practical information on how to administer eligibility rules, employee certification, nondiscrimination testing, and other procedures.

Jeffrey Holdvogt
Jeffrey (Jeff) M. Holdvogt regularly counsels public and privately held companies and tax-exempt organizations on a wide range of employee benefits matters. These include the design and administration of complex pension, 401(k) and 403(b) plans, nonqualified and executive deferred compensation arrangements, fiduciary and plan investment issues under the Employee Retirement Income Security Act (ERISA), internal compliance reviews and voluntary correction filings, and benefit plan matters arising from mergers and acquisitions, as well as other ongoing day-to-day retirement and executive compensation issues. Read Jeff Holdvogt's full bio.


Lisa Loesel
Lisa Loesel focuses her practice on employee benefits matters, including the design, amendment and administration of pension and 401(k) plans, nonqualified deferred compensation arrangements, and employee stock ownership plans. She counsels privately and publicly held corporations regarding the employee benefits design and transition matters arising from corporate mergers, acquisitions and divestitures. She also advises clients regarding fiduciary and plan investment issues under the Employee Retirement Income Security Act of 1974 (ERISA). Lisa also has experience counseling plan fiduciaries with respect to the claims and appeals procedures under ERISA. Read Lisa Loesel's full bio.


Teal Trujillo
Teal Trujillo focuses her practice on employee benefits and executive compensation matters for public and private companies. She regularly leads due diligence and advises on liability related to retirement plans, health and welfare plans and executive compensation in stock purchase and asset purchase transactions. Read Teal Trujillo's full bio.

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