In 2019, the Setting Every Community Up for Retirement act (SECURE) became law and represents one of the most sweeping benefits legislative bills since the Pension Protection Act of 2006. Contained are law are provisions that attempt to address certain shortcomings within the existing laws, some of which are:

• Required Minimum Distribution Age,
• Inherited IRA
• Expanded Eligibility to include Long-term Part-term Employment
• Birth or Adoption Withdrawals
• Qualified Automatic Contribution Arrangements
• In-plan Annuity Options

Choose on any one of these topics and indicate what you suspect is the main issue and shortcoming that theSECUREAct is trying to address.

Also, how does the Secure Act correct this defect?

Will these changes be good or bad for your clients and for your profession as a financial planner?

Key provisions of the SECURE Act The Setting Every Community Up for Retirement Enhancement (SECURE) Act Will have a meaningful impact on employersponsored retirement plans. We've compiled a list of key provisions to help plan sponsors better understand how their plans will be affected. Mandatory provisions are being implemented in accordance With the effective dates and no sponsor action is required at this time. Optional provisrons Will require plan sponsor adoption Mandatory provisions Required minimum distribution age Inherited IRAS ("Stretch RMDs") Expanded eligibility for long-term part- time employees Lifetime income disclosure for defined contribution plans Summary: Most indiViduals are now required to begin taking required minimum distributions (RMDs) after they turn 72, rather than 701/2. This change applies to both IRAs and qualified employer plans. (Participants who turned 701/2 before December 31, 2019, may still be required to take an RIVID.) In addition, indiViduals can now continue to make traditional IRA contributions after 701/2. Implementation: Vanguard has put into place processes and procedures to manage the change to the RMD age. Participants who are no longer required to take an RIVID due to the change in law have been notified accordingly. Work is currently undenrvay to update our systems and RIVID paperwork to reflect the change in RIVID age. In the meantime, Vanguard has implemented alternate procedures for assisting participants Who may need to process an RIVID. Further information Will be provided once our systems and papenrvork have been updated. Effective date: Effective for distributions required after December 31, 2019. Summary: Limits the time in which beneficiaries may Withdraw benefits inherited from qualified plans and IRAs. In the past, these distributions could be taken out over a beneficiary's lifetime. Now, for many nonspouse beneficiaries, the accounts must be depleted within ten years of the original account owner's death. Implementation: If a participant passed away in 2019 or earlier, the RMD calculation is \"grandfathered" and not impacted by the changes (Le, a beneficrary may still deplete the benefit over their lifetime). If a participant passes away in 2020 or after, the RIVID calculation is done in accordance with the new rules and the benefit may need to be depleted within ten years. Vanguard has procedures in place to manage the changes to beneficiary RMDs Effective date: Effective for distributions required after December 31, 2019. Summary: In addition to employees who work 1,000 hours per year, 401(k) plans would be required to include employees Who work 500 hours per year for three consecutive years. Employer match and nonelective contributions would not be required In addition, longeterm partitime employees must be credited with one year of vesting service for each year with 500 hours of service. Service before January 1, 2021, does not need to be counted for purposes of this rule. Implementation: Vanguard is in the process of updating our systems to accommodate this provision Further details Will be provided when available. Effective date: Effective for plan years beginning on or after December 31, 2020 (is, January 1,2021, for calendarryear plans). Summary: Requires lifetime income disclosure to participants at least once every 12 months. The methodology for calculating lifetime income will need to be determined by the Department of Labor IDOL) Additional disclosures and information on assumptions used would have to be provided to participants The DOL is directed to develop a model disclosure Implementation: We are awaiting guidance from the DOL on methodology and model disclosures and Will provide further detail once received. Effective date: Disclosure would be required on benefit statements furnished more than 12 months after the DOL's issuance of regulations and the model disclosure. For institutional use only Not for distribution to retail investors Nonelective safe Summary: Eliminates the safe harbor notice requirement if a plan satisfies the safe harbor using harbor plans a nonelective contribution Allows a plan to be amended to become a nonelective safe harbor plan midyear if certain requirements are met. Implementation: Vanguard is ready to accommodate these changes. Effective date: Effective for plan years beginning after December 31, 2019 (i.e., January 1, 2020, for calendareyear plans). Optional provisions Birth or adoption Summary: PartiCIpants could withdraw as much as $5,000 from their retirement plan account or IRA withdrawal in the year following the birth or adoption of a child without incurring a 10% early withdrawal tax or being subject to mandatory 20% Withholding. Repayment of the distribution must also be available. Implementation: Vanguard is awaiting additional guidance from the Internal Revenue Sewice regarding the documentation required to verify the birth/adoption, tax reporting, and repayment processing. We are in the process of updating our systems to accommodate this withdrawal as soon as posSIble after the guidance is issued. Plan sponsors Will need to elect to offer this withdrawal and amend the plan accordingly. Further details Will be provided when this withdrawal is available from retirement plan accounts. In the meantime, this Withdrawal is currently available from Vanguard IRAs. Effective date: This optional distribution is effective for distributions after December 31, 2019. Qualified automatic Summary: Increases the automatic escalation cap for qualified automatic contribution arrangements contribution (QACA) safe harbor plans from 10% to 15%. Most QACA plans will require sponsor election to increase arrangements the cap unless the plan document incorporates the cap by reference to the statute and/or regulations. Implementation: All of the QACA plans currently recordkept by Vanguard will require sponsor election to increase the cap. Plans that elect to increase the cap for defaulted participants Will need to amend the plan document to reflect the new amount (between 6% and 15%). Vanguard is able to accommodate this change at any time. Effective date: Effective for plan years beginning after December 31, 2019 (i.e., January 1, 2020, for calendareyear plans). Increase in-plan Summary: Provides a statutory safe harbor for the selection of annuity providers When offering an annuity options ineplan annuity distribution option. The SECURE Act also allows lifetime income investments to be transferred among retirement plans when the option is no longer authorized by the original plan. Implementation: At this time, ineplan annuities are not available for Vanguarderecordkept plans. Effective date: As of the date of enactmentDecember 20, 2019. If you still have questions about the SECURE Act and what actions Vanguard is taking, please contact your Vanguard representative. Vanguard Research P O Box 2900 Valley Forge. PA 1948272900 Connect with Vanguard > institutional.vanguard.com > research@vanguard.com _ _ _ _ _ _ _ 2020 TheVanguard Group, Inc. We recommend that you consult a tax or financial adVIsor about your specific Situation. All rights reserved. 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