Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

Summary

SIFMA provided comments to the IRS on Notice 2026-49, supporting efforts to modernize and standardize retirement plan rollovers and transfers under the SECURE 2.0 Act. SIFMA recommends advancing electronic rollovers to reduce delays, improve efficiency and protect retirement savings, while ensuring appropriate safeguards against fraud and sufficient time for industry implementation.

Excerpt

The Securities Industry Financial Markets Association ("SIFMA")1 supports the goal of Notice 2026-49 to standardize and expedite rollovers to eligible retirement plans and trustee-to-trustee transfers of individual retirement plans, as directed by Section 324 of the SECURE 2.0 Act. The notice represents an important step toward modernizing the rollover process and reducing unnecessary friction that can discourage retirement savings preservation.

We strongly support the overall direction the notice has taken in developing standardized rollover procedures. As recognized in the notice, the current rollover process often relies on paper-based documentation and manual processing. Modernization of the rollover ecosystem has the potential to reduce processing delays, improve participant experience, decrease operational costs, and help keep retirement assets within the retirement system. SIFMA supports further advancement of electronic rollovers using a standardized model, while protecting retirement assets from fraud and financial exploitation. SIFMA also recommends appropriate transition time to implement a significant industry-wide solution for rollover modernization.

Benefits of Looking to a Standardized Model

We encourage Treasury to consider a centralized and digital framework to support electronic processing of rollovers as the industry standard. While standardized forms are helpful, the greatest efficiencies will ultimately come from promoting structured secure electronic data exchange and electronic transfer of assets among distributing and receiving institutions. Electronic rollovers can provide significant benefits for both participants and the industry, including:

• Faster and more predictable processing times;
• Reduced risk of lost, delayed, or misdirected checks;
• Lower administrative burdens for plan sponsors, recordkeepers, and financial institutions over time;
• Improved participant experience; and
• Greater ability to maintain accurate records and audit trails.