by Prof. Robert Bloink and Prof. William H. Byrnes
The SECURE Act 2.0 created a powerful new employment benefit that allows employers to make matching contributions to employee retirement accounts based on the employee’s student loan payments, rather than retirement contributions. However, the employer match is only permitted when the employee makes “qualified” student loan payments, or QSLPs. The SECURE Act 2.0 offered only minimal guidance on the new QSLP match option, leaving employers uncertain about whether to offer the benefit in the first place. The IRS has now provided important interim guidance on QSLPs via Notice 2024-63, answering many important questions to give employers a more concrete foundation for their obligations when offering a QSLP match.
Notice 2024-63 QSLP Guidance