June 5, 2023

Ms. Carol Weiser
Benefits Tax Counsel
U.S. Department of the Treasury
1500 Pennsylvania Ave., NW
Washington, DC 20220

Ms. Rachel Levy
Associate Chief Counsel
Internal Revenue Service
1111 Constitution Ave., NW
Washington, DC 20224

Re: SECURE 2.0 Provisions

Dear Ms. Weiser and Ms. Levy:

The Securities Industry Financial Markets Association (“SIFMA”)1 would like to request guidance and share its members’ perspectives relating to several provisions of the SECURE 2.0 Act of 20222. This letter is in addition to our letter dated May 9, 2023, which focused on the SECURE 2.0 changes to Section 529 of the Internal Revenue Code.

SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. SIFMA’s members include broker-dealer firms with a total of more than $96 billion in more than 1.7 million SIMPLE IRA accounts sponsored by more than 300,000 sponsoring employers, so we offer a unique perspective on SIMPLE IRAs in particular. SIFMA’s members also provide other retirement accounts and related services to their customers.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.

2 The Consolidated Appropriations Act, 2023, Division T- SECURE 2.0 Act of 2022.