Section 343 of SECURE 2.0 revised certain disclosures on the annual funding notice (AFN) for single-employer and multiemployer DB plans starting with the 2024 plan year notices distributed in 2025. We expect that the U.S. Department of Labor (DOL) will issue guidance or new model notices to assist plan sponsors and professionals in implementing these changes. However, no such guidance has been issued yet. A couple of the key changes that require additional guidance are mentioned below.

• All plans must disclose the counts of active, terminated vested, and retired participants as of the end of the notice year plus the two prior plan years. For calendar year plans, collecting data as of December 31, 2024, by April 2025 could be challenging. This may require providing the data to the actuary sooner or identifying an alternative method to gather these counts. Additional guidance is needed to help plan professionals understand their options for complying with this requirement.
• Single-employer plans must disclose the plan’s funded percentage, assets, and liabilities as of the end of the notice year, rather than as of the beginning of the year. Additional guidance is needed to clarify how these changes should be implemented and whether supplement to the AFN will still be required.