By: Bryan Uecker, QPA, QPFC, AIF, AIFA

Under the SECURE 2.0 Act, a new feature allows employees to access emergency savings within their 401(k) plans. This is designed to provide workers with more flexibility to cover unexpected expenses without needing to resort to high-interest loans or credit cards. Here’s a breakdown of the potential benefits and drawbacks of incorporating emergency savings accounts inside a 401(k) plan:

Pros:

1. Accessibility for Employees:

• Emergency Fund Access: Employees can set aside up to $2,500 in an emergency savings account within their 401(k). This provides a quick and easy way to access emergency funds without having to worry about depleting personal savings or taking on high-interest debt.
• Early Withdrawals without Penalty: If structured correctly, employees may withdraw emergency funds without incurring the 10% early withdrawal penalty (though income tax may still apply).

2. Tax-Advantaged Growth:

• Tax-Deferred Contributions: Contributions to the emergency savings account within the 401(k) plan grow tax-deferred. This can be an attractive option for employees, as the funds will accumulate without being subject to annual income taxes.
• Potential for Employer Contributions: Employers may be able to match emergency savings contributions, further boosting employees’ savings potential.

3. Encouragement of Savings:

• Automatic Payroll Deductions: Employees may be able to set up automatic contributions directly from their paychecks. This can help establish the habit of saving for unexpected expenses, even if it’s just a small amount each pay period.
• Financial Security: Access to emergency savings in a 401(k) plan gives employees peace of mind, knowing that they have a built-in safety net to deal with unforeseen financial burdens.

4. Enhanced Retirement Contributions:

• Employees may contribute to their emergency savings and retirement savings simultaneously, allowing for the long-term benefits of retirement planning while addressing short-term liquidity needs.

Cons:

1. Limited Emergency Fund Access:

• Withdrawals Are Still Subject to Income Tax: While the penalty is waived, emergency fund withdrawals are still subject to income tax, which may reduce the amount of the funds employees actually receive.
• Limits on Withdrawals: Withdrawals from the emergency savings account are restricted to specific qualifying circumstances. Employees may not have the same flexibility as they would with a regular savings account, and not all emergencies may qualify.

2. Reduced Contributions to Retirement Fund:

• Emergency Savings Could Impact Retirement Contributions: If employees are putting funds into their emergency account within the 401(k), it may reduce their ability to maximize contributions to their retirement savings. This could impact long-term financial planning for retirement.
• Potential for Missed Investment Growth: While the funds in emergency savings are protected from market volatility, they may also miss out on the higher returns associated with more aggressive investments in the main portion of the 401(k) plan.

3. Complexity and Administration:

• Additional Administration for Employers: Employers will need to track both regular 401(k) contributions and emergency savings contributions. This adds another layer of complexity to plan administration and may require additional time and resources.
• Employee Confusion: Employees may be confused about how their emergency savings are structured within their 401(k) and how this fits into their overall retirement planning strategy. Clear communication and guidance from employers will be necessary to avoid confusion.

4. Potential for Overuse:

• Overreliance on Emergency Savings: Employees might be tempted to use emergency funds more frequently, draining the emergency savings account. This can reduce the funds available for true emergencies, potentially leaving employees without the necessary resources when they need them the most.

5. Impact on Future Withdrawals:

• Tax Implications: Since the emergency savings are inside the 401(k), any withdrawals from this account will still count toward the total 401(k) balance, potentially increasing the taxable amount when the employee retires or takes distributions.

Conclusion:

The inclusion of emergency savings accounts within a 401(k) plan under SECURE 2.0 offers significant benefits, particularly in providing employees with an accessible, tax-advantaged way to manage unexpected expenses. However, it also comes with challenges related to tax implications, withdrawal restrictions, and the potential for reduced retirement savings growth.

Employers and employees must carefully weigh the pros and cons, ensuring they balance short-term financial flexibility with long-term retirement planning goals. With proper structure and communication, emergency accounts within 401(k) plans can be an excellent tool for enhancing financial security and preparedness.