Staff counsel warns commission a 60‑year normal retirement age will require data to justify it under federal rules

Aug 18, 2025

Staff counsel told the commission Internal Revenue Code safe harbors favor retirement ages 62 and older; selecting age 60 will require the commission to document that the age is reasonably representative of the covered workforce or fit within a public‑safety safe harbor, so staff recommended collecting state and national retirement timing data.

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Susan, staff counsel to the commission, briefed members on federal requirements for defining a plan’s normal retirement age. She explained Internal Revenue Code rules and safe harbors: choosing age 62 or older generally satisfies the safe harbor, but selecting an age under 62 requires proof that the chosen age is reasonably representative of the typical retirement age for the covered workforce.

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