I have finally been putting together the pieces on how all of these new DOL transparency rules will affect 403(b) plans. It is, in many ways, surprising. I’m not quite sure its even possible for many 403(b) plans to actually comply with key elements of the new rules, but at east we have some time
The REAL Problem With the New 12b-1 Rule: SEC’s Treatment of 401(k) Participants as 403(b) Participants
Much has been written about the SEC’s proposed changes to the mutual fund 12b-1 rules. The proposed rules have caused quite a stir in the retirement plan world, as so much of the costs of plan administration and distribution are funded by these arrangements.
What is being overlooked, however, is a much more disturbing
Prudence, not Prescience: A Suggestion for a Fiduciary Standard for DC Annuity Purchases
The question of what the appropriate fiduciary standard should be in assessing the insurer insolvency risk when purchasing annuities by defined contribution plans continues to be a tough one.
It is also one of the critical issues to be resolved if the efforts to encourage lifetime income from these plans is to be successful. The
The 403(b) Unfair Labor Practice
“Unfair Labor Practice” 403(b)
Continue Reading The 403(b) Unfair Labor Practice
DC Annuity Portability and Asimov’s “M.N.C.”: What Is Old Is New Again
How, one may legitimately ask, can anyone possibly write anything that makes any sense with a title like the one I’ve given this blog?
Easily, is my answer, as as long as one accepts the fact that our world of retirement plans and rules is not so limited as it seems at first glance, and
Insurance Company General Account DC Investments and the 408(b)(2) Conundrum: Balancing Capital, Liquidity and Transparency
One of the most maligned and misunderstood, yet one of the most valuable, DC plan investments is the the insurance company general account investment-typically referred to as the “fixed fund,” the “guaranteed fund,” or even sometimes the “stable value fund”(in some of its iterations). These funds guarantee principal and a certain rate of return over a stated period of time. These funds usually (except in an inverted yield environment) provide a much higher rate of return over money market funds, while providing a measure of security of which money market funds can only dream. if the insurance company properly balances liquidity with the rate of return, it is an invaluable offering.
Continue Reading Insurance Company General Account DC Investments and the 408(b)(2) Conundrum: Balancing Capital, Liquidity and Transparency
ERISA Plans’ Ultimate-and Criminal-“Prohibited Transaction” Rule of 18 USC 1954
Lurking darkly in the background behind all the recent discussions of fee disclosure and how the prohibited transaction rules apply under 408(b)(2), is something most of us in the benefits world typically pay little attention to: the U.S. Criminal Code.
We all have a general knowledge that kickbacks and racketeering schemes of any sort are
Plan Distributed Annuities, 403(b) Contracts and the Mandatory Cash-Out Rules: The Saga of Relevant Minutiae Continues….
It had to happen if we kept at this long enough. We have written often over the past few years on the minutiae of 403(b), particularly where they demonstrate the often goofy differences between 401(k) plans and 403(b) plans. We have also written some on the finer technical rules which apply to plan distributed annuities
The Insurance and Mutual Fund Industries’ Curious Spittin’ Match Over Annuities
ASPPA, AARP and WISER are taking the bull by the horns and, rather courageously, are putting representatives from the mutual fund industry and the annuity industry together on panels in the "Lifetime Income Summit" to be held on May 21.
The agenda promises to be an interesting one. An insurance industry representative will chair the
The 403(b) Church Plan Labyrinth
Roger Siske, dear friend, mentor and traveling companion had taught me much about the art of travel, about enjoying myself well while on the road for what seems at times like far too many hours. One of the places to which we had traveled several times together was San Francisco, home of the two labyrinths