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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
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Engineering, analytical and operations. These are the three distinct and dynamic categories (“stacks”, perhaps?) of knowledge into which the lifetime income markets seem to be organizing itself-out of necessity, I would argue.
We’ve known for a very long time that transforming defined contribution plans into vehicles which facilitate the accumulation and distribution of income
Business Wire published a news release today announcing the new strategic relationship between Securian Financial and Custodia Financial regarding Custodia’s Retirement Loan Protection (RLP) program—”a first-of-its-kind, in-plan feature that helps safeguard employees’ retirement savings by automatically protecting 401(k) loans from default when job loss, disability or death occurs.” It is a program a number of
The DOL’s most recent advisory opinion, 2025-04, helpfully affirms two separate legal principles upon which many of the defined contribution lifetime income programs being offered in the market currently rely. The AO is also very useful in the manner in which DOL describes one very specific program, the LIS program offered by Alliance Bernstein, offering
403(b) plans and lifetime income programs suffer a similar malady: both sorts of arrangements operate in a sort of “exception” environment, where they rely upon atypical application of the standardized qualified plan rules in order to effectively work. This means that these programs are not typically amenable to broad and sweeping policy statements of the
As part of the DOL’s efforts under Executive Order 14192, titled Unleashing Prosperity Through Deregulation (90 FR 9065, Feb. 6, 2025), the Department undertook to withdraw two seemingly innocuous annuity regulations which, by any cursory review, appeared to have outlived their usefulness. I would suspect that most of us didn’t give those withdrawals a second