Treasury/IRS Notice 2026-48 Intent to Issue Regulations with Respect to Saver’s Match Contributions

Summary

SIFMA provided comments to the IRS on the implementation of the Saver’s Match program, offering recommendations to support an efficient and workable framework for delivering matching contributions to eligible individuals.

Excerpt

The Securities Industry Financial Markets Association (“SIFMA”) ¹ strongly supports the goal of the Saver’s Match program and Treasury’s efforts to develop a framework that enables eligible individuals to receive matching contributions efficiently and securely. Helping Americans build long-term savings, including for retirement, is among the most important roles of the U.S. capital markets.

As Treasury works to implement the Saver’s Match, we support feasible solutions for operationalizing the mechanisms required for federal payments to individuals’ plans and welcome working with Treasury and other stakeholders toward achieving this goal.

I. Recommend Use of a Conduit IRA for All Saver’s Match Contributions

We recommend that Treasury and the IRS adopt a uniform approach for all Saver’s Match contributions directed to an IRA. This would mean utilizing the conduit IRA program for all contributions going to IRAs, regardless of whether the contribution ultimately ends up in a traditional or a Roth IRA (and therefore, not limiting conduit IRA use for only Roth IRA destinations). Based on our understanding of the proposal described in Treasury/IRS Notice 2026-48, we support the Saver’s Match going from Treasury to the conduit IRA, then immediately transferring to the eligible chosen traditional or Roth IRA. Under this approach, an eligible individual claiming a Saver’s Match contribution would identify the IRA custodian using Treasury’s IRA tracking number. We recognize that each IRA custodian will need to seek a tracking number from Treasury to be able to in turn provide that number to clients who are eligible for the Saver’s Match. We ask Treasury to confirm that custodians only need the IRA tracking number to accept Saver’s Match contributions from the conduit IRA and that there will be no additional verification process with Treasury or clients. If our understanding is accurate and reflects the intended proposal, this conduit IRA approach would significantly simplify administration, reduce operational complexity, and improve the taxpayer’s experience.

A conduit IRA framework would allow Treasury, the IRS, IRA custodians, and eligible individuals to operate under a single, standardized process for receiving Saver’s Match contributions to IRAs. By contrast, requiring separate direction and payment processes depending on whether the taxpayer designates a traditional IRA or a Roth IRA would introduce unnecessary complexity into Treasury payment processing, since there would need to be some back-and-forth between Treasury and the IRA custodian, as well as the individual investor to determine which type of account it is. By directing all Saver’s Match contributions to a conduit IRA, that will become unnecessary. A single conduit IRA process would create a consistent operational model regardless of the ultimate IRA destination selected by the taxpayer.

A conduit IRA framework would also reduce burdens on IRA custodians. Notice 2026-48 contemplates that IRA custodians accepting Saver’s Match contributions will need to establish operational procedures to receive and process those amounts. Requiring separate receipt mechanisms for traditional and Roth IRAs would increase implementation costs and introduce additional opportunities for operational errors. A conduit IRA model utilizing existing ACAT transfer protocols would minimize systems development for current IRA custodians and facilitate broader participation in the Saver’s Match program.