Broker Check

Meritage Periodical - January 2023

Advisor Perspective

Prompting critical thinking and conversations around issues in our industry. Not intended as personal financial advice.

What you need to know about SECURE 2.0

On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023, an omnibus spending bill that includes the SECURE 2.0 measure (a.k.a. the Securing a Strong Retirement Act 2.0). Broadly, SECURE 2.0 is intended to make retirement saving more straightforward and accessible to a wider range of people. As such, it encompasses many aspects of financial planning and retirement saving.

With time, as the new law is interpreted and applied, nuances will become clearer. Until then, individuals will have to interpret the law’s effects based on its language and any guidance the IRS issues.

SECURE 2.0 includes a host of provisions affecting the rules for qualified retirement plans (401(k), 403(b), etc.) and their administration. This periodical, however, addresses only key provisions pertaining to individual retirement savers (or accounts) and rules applicable to individuals rather than plan sponsors and administrators. The bill is quite broad (more than 4,000 pages), so we intend this periodical to be a high-level summary addressing the items most likely to affect individuals.

Key Provisions of SECURE 2.0 Relating to Individuals

SECURE 2.0 includes many provisions outside the scope of this summary that could be deemed relevant for certain individuals, so it’s important to confer with a tax professional before executing any strategy based on this new legislation. Note as well that the bill has a wide range of effective dates for the various provisions.

  • Delays the age of RMDs from age 72 to 73, with an eventual increase to age 75 by 2033 (More important, individuals who turned 72 in 2022 should not be affected by this new rule, and the imposition of the new RMD age does not seem to afford the individual the option of delaying their first RMD beyond April 1, 2023.)
  • Allows employers to provide matching contributions to an employer sponsored retirement plan equal to an employee’s qualified student loan payments
  • Authorizes taxpayers to create SIMPLE Roth IRAs and SEP Roth IRAs
  • Eliminates RMDs for Roth accounts in employer sponsored plans
  • Indexes IRA catch-up contributions for inflation year-over-year
  • Permits qualified charitable distributions (QCDs) from an IRA to be made to a split-interest entity (such as a charitable remainder trust or charitable gift annuity) up to a lifetime limit of $50,000
  • Indexes QCDs (currently limited to $100,000 per individual) for inflation year-over-year
  • Permits unused funds remaining in 529 college savings plans to be rolled into Roth IRAs (subject to restrictions, including a lifetime rollover limit of $35,000 and a 15-year minimum on account age)
  • Introduces new post-death beneficiary withdrawal options for surviving spouses of retirement plan owners by permitting the surviving spouse to elect to be treated as if they were the deceased spouse
  • Adds numerous exceptions to the 10 percent penalty for early withdrawal from a retirement account (exceptions include withdrawals for domestic violence victims and for qualified long-term care expenses), with each carrying varying limits on withdrawal timing and amount
  • Eases limitations on the use of a qualified longevity annuity contract (QLAC) by removing the 25 percent account balance rule and increasing the maximum contribution amount to $200,000
  • Makes 529 ABLE accounts accessible to more blind and disabled individuals by raising the age from which disability must be present from 26 years old to 46 years old

Many of the provisions that make up SECURE 2.0 are designed to allow individuals more time for tax-deferred saving and savings growth before requiring distributions and to incentivize and promote retirement saving.

To potentially counter some of the lost revenue associated with tax deferral, SECURE 2.0 includes a provision designed to limit tax benefits related to a strategy the IRS says runs afoul of the tax code. As such, individuals engaged in “risky” tax strategies (e.g., use of a tax deduction through contribution to a charitable easement) should use extra caution and seek appropriate counsel before executing the strategy.

What’s Not in the Bill

Prior bills presented in Congress sought to limit the ability of taxpayers to engage in Roth conversions and what is known as the Backdoor Roth conversion. SECURE 2.0 did not address these items, and therefore, Roth conversion strategies should remain viable.

Additionally, the bill does not address the confusion surrounding inherited retirement accounts and whether RMDs would apply to a beneficiary each year. Such final regulations to the original SECURE Act remain pending.

Securing a Path to Retirement

As more information becomes available regarding the interpretation of SECURE 2.0, it’s important to continue to review all aspects of your financial plan and tax strategies to ensure that you understand how you and your family have been affected. Be sure to contact your tax professional or our office for help navigating your situation.


This material has been provided for general informational purposes only and does not constitute either tax or legal advice. Although we go to great lengths to make sure our information is accurate and useful, we recommend you consult a tax preparer, professional tax advisor, or lawyer.

Timely Topics

Updates and reminders that may impact your personal financial planning

2022 Tax Season is Here!

A few reminders:


Every year, NFS requests a 30-day extension from the IRS’s initial mailing deadline of February 15 to mail tax forms because some investment issuers are unable to submit final tax information in time. Therefore, you can expect NFS to issue your 1099 sometime between mid-February and mid-March. For more details on the NFS 1099 timing, please see the chart below.

  • In an effort to limit the number of corrected forms typically mailed each year, the IRS has granted an extension for the initial mailing of these tax documents. This occurrence is one reason we suggest delaying your tax filing until closer to the deadline.
  • Please note: In instances when tax reporting for an account occurs during the extension period, NFS will provide an online preliminary tax statement starting on February 11. This is viewable only in Investor360° or Wealthscape Investor and will provide a single view of current tax information to help you determine early tax liability.

If you have signed up for electronic delivery of 1099s, watch for a notification from the account custodian to alert you of availability (i.e. NFS, Capital Group, Brinker Capital, etc.)


We recommend receiving tax documents via mail, even if you elect other documents via e-delivery, as you will still have access to the tax documents electronically.


It is not uncommon to receive a corrected 1099. If this happens and you have already filed your return, contact your tax professional for guidance. In most cases, a corrected 1099 is not the result of an error. Often, it happens because securities and investment companies do not have enough data to accurately classify and calculate gains and losses before the designated federal tax filing deadlines. Reclassifications that lead to revised 1099s commonly include qualified dividends, 13-month dividends, substitute payments, and tax-exempt interest.


National Financial Services 1099 Information:

If you are enrolled in e-notification, you will receive an email notifying you that your tax forms are ready to view. If you are not enrolled in e-notification, your form will be mailed within five business days of online posting. In both cases, once issued, you may access an electronic version of your tax forms by visiting Investor360°®: Statements & Documents > Tax Reporting > Most Recent.

  • Tax Form Mailing Dates: Our partner, National Financial Services (NFS), will post and mail consolidated 1099 tax forms in four waves, outlined below. The dates below are when your tax form are estimated to be available online. They will be mailed five to seven days after they are posted online.
  • January 20: Form 5498 available online; for use with contributions to, and year-end market values of, retirement accounts
  • January 20: Form 1099-R available online; for distributions from retirement accounts
  • January 21: 1099 Consolidated Tax Form, mailing cycle 1, available online; Non-retirement accounts with holdings whose income doesn’t require reclassification or additional information from issuers (Generally, this includes accounts holding options, certain equities, and fixed income securities.)
  • February 11: 1099 Consolidated Tax Form, Mailing cycle 2, available online; Equities and fixed income securities, closed-end funds, and non-Fidelity mutual funds where issuer provided final tax information after first mailing; second mailing includes information-only 1099s issued for exempt accounts, including non-prototype and corporate accounts.
  • February 11: 1099 Preliminary Tax Statement available online only; Point-in-time snapshot of reporting activity for customers slated for a later mailing; includes symbols/CUSIPs for positions that lack final tax information as of February 15, 2022 (This is online only, is not reported to the IRS, and should not be used for tax reporting purposes.)
  • February 11: 1099: Info Only (corporate) available online only; supplemental information for corporate and eligible exempt accounts
  • February 25: 1099 Consolidated Tax Form, Mailing cycle 3, available online; for accounts holding securities with income reclassifications to date.
  • March 4: 1099 Consolidated Tax Form, Mailing cycle 4, available online; for brokerage accounts holding later-issuer reclassifications (e.g., UITs, REITs)
  • May 12: Follow-up Form 5498 available online; for contributions made between January 1, 2023, and April 18, 2023 for the 2022 tax year. Not required for tax filing purposes.

The 2022 Tax Filing Deadline is April 18, 2023. The due date is April 18, instead of April 15, because of the weekend and the District of Columbia's Emancipation Day holiday, which falls on Monday, April 17.

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