⚠ URGENT COMPLIANCE DEADLINE · JANUARY 1, 2026 ⚠

Is Your Payroll
Already
Breaking the Law?

SECURE 2.0 Section 603 changed the rules for 401(k) catch-up contributions. If you have employees age 50+ earning over $150,000 — your plan may be NON-COMPLIANT right now.

$150KIncome Threshold
50+Age At Risk
30minTo Fix It
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⚠ The 2-year IRS delay is officially over ✓ Final IRS regulations issued September 15, 2025 ⚠ Non-compliance risks plan DISQUALIFICATION ✓ Fix takes under 30 minutes with the right guide ⚠ Your payroll company won't catch this automatically ✓ Affects employees age 50+ earning over $150,000 ⚠ The 2-year IRS delay is officially over ✓ Final IRS regulations issued September 15, 2025 ⚠ Non-compliance risks plan DISQUALIFICATION ✓ Fix takes under 30 minutes with the right guide ⚠ Your payroll company won't catch this automatically ✓ Affects employees age 50+ earning over $150,000

The Rule Change

What Changed?
The Plain English Version

❌
Before SECURE 2.0

The Old Way

Employees age 50+ could make catch-up contributions to their 401(k) on a pre-tax basis — deferring taxes until retirement. Simple, flexible, no conditions.

⚖️
Section 603 — Effective Jan 1, 2026

The New Rule

If an employee is age 50+ AND earned over $150,000 in prior-year FICA wages (W-2 Box 3), their catch-up contributions MUST go into a Roth (after-tax) account. No exceptions. No more delays.

SECURE 2.0 · SECTION 603

Eligibility Test

Who is a "High Earner"?

Is the employee Age 50+?
↓
YES
↓
Did they earn over $150,000 in Box 3 FICA wages last year?
↓
YES
↓
⚠ ROTH CATCH-UP RULE APPLIES
NO
↓
Ordinary Limits Apply
NO
↓
Ordinary Limits Apply

Use this chart to determine if this rule applies to each employee in your plan.

⚠ CRITICAL NUANCE: The Self-Employed Exception

Are you a sole proprietor or partner with only self-employment income — no FICA wages from a corporate entity? If YES, you are EXEMPT from the mandate. You may continue making catch-up contributions on a pre-tax basis regardless of your income level.

Action Required

The 3 Questions You Must Ask
Your Payroll Provider Today

Do not just forward them an article. Call them directly and ask these exact questions. Document their answers in writing — your compliance depends on it.

01
The Wage Threshold

"For the 2026 plan year, the threshold for mandatory Roth catch-ups is $150,000 based on prior-year FICA wages. Does your system use Box 3 (FICA wages) or Box 5 (Medicare wages) to identify high earners?"

⚡ Why ask: The IRS specifically requires FICA wages (Box 3). Box 5 includes pre-tax deductions and will flag the wrong employees.

✅ Correct Answer: "We use Box 3."
02
The "Deemed Roth" Mechanism

"For employees identified as high earners, how do you handle the spillover? If an employee hits the regular 401(k) deferral limit mid-year, does your system automatically switch their catch-up contributions to Roth?"

⚡ Why ask: The final regulations allow for a "deemed Roth election" to automate this. You need to know if their software supports it — or if you need separate elections from each employee.

✅ Correct Answer: "We have a deemed Roth feature we can activate for specific employees."
03
The Plan Document Amendment

"We need to amend our plan document to comply with the Roth catch-up rule. What is your deadline for submitting amendment requests to ensure compliance by 1/1/2026?"

⚡ Why ask: Some providers (like Bank of America) had deadlines as early as September/December 2025. If you've missed the window, you need the correction procedure immediately.

⚠ Correct Answer: They give you a specific date. If it has passed — ask for the correction procedure IMMEDIATELY.

Your Complete Toolkit

What's Inside Your Free Cheat Sheet

⚖️
The Mandate Explained

Plain-English breakdown of Section 603 — exactly what changed and why it matters for your business.

📊
Eligibility Flowchart

Visual decision tree to identify every High Earner in your plan — unambiguous and easy to apply.

❓
The 3 TPA Questions

Word-for-word questions to ask your payroll provider — with the correct answers you should hear.

✅
Compliance Checklist

Sign-and-date checklist that documents your fiduciary due diligence — keep it in your compliance file.

🔧
The "Fix It" Script

Exact script to use when your TPA seems confused — gets them moving in the right direction fast.

🛡️
Correction Methods

If an error already happened — W-2 correction, In-Plan Roth Rollover, and the De Minimis exception explained.

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The $27 Package

Everything You Get —
Over $260 in Value

📋
The SECURE 2.0 Compliance Cheat Sheet
Main Guide — 2026 Edition with Final IRS Regulations
$97
✉️
Bonus #1: Done-For-You Employee Email Templates
3 ready-to-send emails — notify staff, answer FAQs, engage your TPA
$49
📊
Bonus #2: High Earner Identification Worksheet
Step-by-step fillable worksheet + employee tracking table
$47
📅
Bonus #3: The 30-Day Compliance Action Plan
Day-by-day task roadmap across 4 phases — nothing falls through
$47
📖
Bonus #4: SECURE 2.0 Key Terms Glossary
16 plain-English definitions for every term your TPA will use
$27
TOTAL REAL-WORLD VALUE$267
YOUR PRICE TODAY
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30-Day Money-Back Guarantee. If this package doesn't give you everything you need to feel confident about your plan's compliance, email us within 30 days for a full refund — no questions asked.
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Isaac Trinidad, Business Consultant

Isaac Trinidad

Business Consultant · Retirement Specialist

Isaac Trinidad is a Retirement Specialist, business consultant, and financial educator with over 15 years of experience. He has dedicated his career to assisting business owners, professionals, and families in crafting smarter retirement and tax-efficient financial strategies. As a Service-Disabled Veteran business owner and published author, Isaac leverages real-world experience and practical compliance knowledge to demystify complex financial regulations.

  • Optimizing retirement plans for small and mid-size businesses
  • Educating on 401(k) and Roth strategies
  • Aligning payroll taxes and benefits
  • Providing compliance guidance for employers and fiduciaries
  • Enhancing financial literacy for entrepreneurs and high-income professionals

Don't Wait

Do Not Wait for Your Payroll Company
to "Figure It Out."

Every payroll cycle without confirmation increases your exposure to penalties, plan disqualification risk, and employee dissatisfaction.

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Your cheat sheet is on the way. Ready to make sure everything is locked in?

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📞  561-801-0654 ✉️  Isaac@Isaac-Trinidad.com 🌐  isaac-trinidad.com

This guide is for informational purposes only and does not constitute legal or tax advice. Consult a qualified professional regarding your specific situation.