If you’ve heard the term “SECURE 2.0” floating around and wondered what it means for your retirement plan, you’re not alone. It’s one of the most significant pieces of retirement legislation in years, and there’s a lot packed into it.
The good news: for business owners using a cash balance plan, or thinking about adding one, the changes are largely positive. More flexibility. More practical tools. And a little less paperwork in a few places.
Here’s what you actually need to know, and what it looks like in real life.
A quick refresher: what is a cash balance plan?
A cash balance plan is a type of defined benefit plan that allows business owners to contribute significantly more toward retirement than a 401(k) alone. For owners in their 50s or 60s who want to accelerate savings and reduce taxable income, it can be one of the most powerful tools available.
It works by crediting your account each year with two things: a pay credit (the employer contribution) and an interest credit (a defined rate at which the balance grows). The plan operates within a structured framework, which is part of what makes it so effective from a tax and compliance standpoint.
SECURE 2.0 didn’t change any of that. What it did was refine a few of the rules in ways that make these plans more flexible and easier to work with.
What changed, and why it matters
1. Interest crediting rates: more room to work with
One of the more technical updates, but an important one, involves how interest credits can be structured inside a cash balance plan.
Previously, there was some uncertainty around whether interest crediting rates could be tied to a market-based index. SECURE 2.0 clears that up: yes, they can. The rate can now be linked to a market index, giving plan sponsors more flexibility to align the plan’s growth assumptions with real-world conditions.
There’s a clear guardrail, though: the interest crediting rate cannot exceed 6%. This keeps the plan stable and predictable, it’s not turning your cash balance plan into a market-driven investment account. What it does is give your actuary more room to design a plan that reflects how money actually grows.
For owners closer to retirement who want to maximize contributions in the years they have left, this matters. A slightly higher crediting assumption can support larger allowable contributions, which is often exactly the goal.
Real-life scenario
Using a market-based interest rate to contribute more
A professional services firm owner in her early 60s has been running a successful practice for decades. She’s focused now on making the most of the years she has left before stepping back, and she wants to shelter as much income as possible while she’s still in a high-earning season.
She has a cash balance plan, but it was designed with a conservative interest crediting rate. Under those assumptions, there was a ceiling on how aggressively contributions could be structured for her.
With the SECURE 2.0 clarification, her plan is redesigned using a higher, but still fully compliant, crediting assumption tied to a market index. The result:
- Her allowable annual contributions increase meaningfully, based on her age and timeline
- The funding strategy better reflects realistic return expectations
- The plan stays stable and predictable, no open-ended market risk
She gets a clearer path to build significant retirement assets in a shorter window. The plan does more for her without becoming more complicated.
2. Retroactive Safe Harbor contributions: more flexibility at year-end
Cash balance plans are almost always paired with a 401(k). When you combine the two, there are coordination rules that come into play, the most important being something called the “gateway” contribution.
The gateway requirement ensures that non-highly compensated employees receive a minimum level of employer contribution when owners are maximizing benefits through a cash balance structure. It’s an important guardrail, and it’s non-negotiable.
The challenge has always been timing. If a plan wasn’t set up as a Safe Harbor plan at the beginning of the year, options for meeting the gateway requirement later could be limited, or could require pushing the whole decision to the following year.
SECURE 2.0 changes that. A non-Safe Harbor 401(k) plan can now be amended retroactively to add a 4% non-elective Safe Harbor contribution. That gives business owners a practical tool to meet gateway requirements even when planning decisions happen later in the year, which, honestly, is how a lot of real business planning works.
Real-life scenario
Adding a cash balance plan late in the year, without losing the opportunity
A small business owner with 15 employees has had a strong year. By fall, it’s clear the business has performed well, and she starts seriously exploring whether to add a cash balance plan to take advantage of the higher contribution limits.
The challenge: her existing 401(k) wasn’t set up as a Safe Harbor plan. And the gateway contribution required to coordinate a new cash balance plan with the 401(k) hadn’t been planned for.
Under the old rules, this timing issue could have meant waiting until the following year, missing a full year of potential contributions and tax savings.
With SECURE 2.0, the 401(k) is amended before year-end to include a 4% non-elective Safe Harbor contribution, applied retroactively. The result:
- The gateway requirement is satisfied without restructuring the plan mid-year
- She moves forward with the cash balance plan for the current year
- Her employees receive a meaningful employer contribution they weren’t originally expecting
She doesn’t lose a year of opportunity. The employees benefit. And the plan stays fully compliant. That’s a win all the way around.
3. Hardship withdrawals: less paperwork, same standards
This one is more of an administrative update, but it’s a welcome one for anyone who has dealt with hardship withdrawal requests.
Previously, plan administrators were typically required to collect documentation to verify that a participant qualified for a hardship distribution, financial records, supporting paperwork, the works. It was time-consuming for administrators, and it could feel intrusive and slow for employees going through a genuinely difficult time.
Under SECURE 2.0, administrators can now rely on a participant’s self-certification that they’ve experienced a financial hardship. The standards for what qualifies haven’t changed, it’s still the same underlying criteria. What’s changed is the process for verifying it.
For plan sponsors, this means fewer documents to collect, fewer things to store, and a faster turnaround for people who need access to their funds. It removes friction without lowering the bar.
Real-life scenario
Processing a hardship request without the paper trail
An employee at a growing construction company experiences an unexpected financial hardship and needs to request a withdrawal from the 401(k).
Under the old process, the plan administrator would have needed to collect and review supporting documentation, proof of the hardship, financial records, and more. This often meant delays for the employee and extra administrative steps for the employer at an already stressful time.
Under the updated SECURE 2.0 rules, the plan administrator accepts the employee’s self-certification. The request is reviewed for compliance and processed, no documentation chase required. The result:
- The withdrawal is handled quickly
- The employer doesn’t need to collect or store sensitive personal documents
- The administrator can focus on processing the request correctly, not verifying paperwork
For the business owner, it’s one less administrative burden. For the employee, it’s one less barrier during an already hard moment. That’s the kind of change that’s easy to overlook on paper, and really appreciated in practice.
How these changes fit together
Individually, each of these updates addresses a specific piece of plan design or administration. Together, they reflect something consistent: retirement plan rules are getting more practical.
More flexibility in how plans are structured. More tools for meeting compliance requirements on a realistic timeline. And a little less friction in day-to-day administration.
For business owners, especially those using cash balance plans as part of a broader tax and retirement strategy, that combination genuinely matters. It means more responsive planning without stepping outside the boundaries of compliance.
A few questions worth asking your TPA and advisor
Whether you already have a cash balance plan or are thinking about adding one, SECURE 2.0 is worth reviewing with your team. A few places to start:
- Is our current interest crediting rate still the right fit, given the updated guidance?
- Should we revisit how our 401(k) and cash balance plan are coordinated?
- Do we have flexibility to make retroactive Safe Harbor contributions if we need them?
- How are hardship withdrawals currently handled, and does our process reflect the updated rules?
These aren’t complicated conversations, but they’re worth having. Small adjustments in plan design can make a real difference in what you’re able to contribute and how smoothly the plan runs.
We’re here when you’re ready to dig in
At Mirador, this is the kind of work we do every day, helping small business owners understand not just what the rules say, but what they mean for your specific situation.
Cash balance plans have always been powerful. SECURE 2.0 makes them a little more adaptable, a little more practical, and a little easier to get right. If you want to talk through what any of this means for your plan, or whether a cash balance plan might make sense for you in the first place, we’d love to have that conversation.
No pressure, no jargon. Just a real conversation about what’s possible.
Reach out to the Mirador team to get started.









