The DOL’s proposed prudence safe harbor regulations have pretty much made it “table stakes” for some responsible person somewhere to read and understand any annuity contracts on behalf of the plan which are provided as part of any DC lifetime income program. This means, of course, you have to first know where those annuities are
This topic has never been one that has much concerned either analysts or operators of programs which involve the purchase by a DC plan of an annuity contract. This one has always been in the purview of the engineer-those insurance legal and compliance folks who have well established procedures to deal with each state’s insurance
One of the key fiduciary roles in the assessment of any DC lifetime income program process necessarily involves whether, and how, the plan or the vendor accommodates any required spousal consent rules related to the payout of annuities.
The vast majority of the defined contribution plans comply with ERISA and the Code’s spousal consent rules
Often overlooked in a fiduciary analysis of any DC Lifetime Income Program are the impacts arising from the method in which any accumulated lifetime income guarantee is being distributed from any particular program. There are substantial differences between any of the available methods, and the impact of each of them on any participant. They really
We have all been well attuned over the decades since mutual funds became available to be daily traded under DC plans to a very particular view of an investment funds’ cost. ERISA’s participant investment disclosure rules have successfully established what I best described as a certain “language,” which permits any participant or fiduciary to assess
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AI’s limitations became pretty apparent after yet another delightful and “robust,” shall we say, conversation with an old friend, an economist, about intriguing ideas on how to universally effectuate, accumulate and port lifetime income guarantees derived from employment. That conversation got granular, as it often does, with voices raising over details of certain innovative infrastructure
“No Duh!”was my favorite response by a colleague to the DOL’s alt asset proposed regulation, which is replete with references to the need of the fiduciary adviser to “read and critically review” the core documents of any of a plan’s investments. That proposed reg does grant plan sponsors some grace, only requiring that they (who
An important and separate “tool,” if you will, in the professional’s portfolio for use in assessing and understanding the manner in which any lifetime income program will fit into any particular DC plan is simply recognizing that annuities (1) are a necessary element of providing lifetime guarantees under DC plans; (2) are normal; (3) have
SECURE and 2.0’s efforts to open up the availability of defined contribution plan balances for personal emergencies, including the establishment of those goofy PLESA accounts, really have their roots in what was-at the time- a pair of thoughtless changes made to the Code under Tax Reform Act of 1986 (the “86 Act). Even then, those particular