Consolidation Corner

Protecting benefits owed to a company’s current and former employees is the cornerstone of an employer’s fiduciary duty under ERISA, which celebrates its 50th anniversary this year.

So, it troubles me when I read about strategies for plan optimization that advocate for continued reliance upon “old-school” automatic rollovers. While I am all-in for plan optimization, old-school automatic rollovers put employee benefits at risk by generating massive amounts of cashout leakage, stranding millions of participants’ balances in safe harbor IRAs that charge excessive fees and earn paltry returns, while disproportionately impacting minorities, women, low-income and younger workers.

On May 16th, Robert L. (Bob) Johnson, Chairman of The RLJ Companies, Retirement Clearinghouse (RCH) and the Portability Services Network (PSN), delivered the keynote address to the 2024 EBRI Spring Policy Forum, co-hosted by the American Benefits Council.  

In Johnson’s address, entitled “Helping to narrow the nation’s lingering racial wealth gap” – the legendary Black American entrepreneur gave Forum attendees insight into the businessman’s long, purpose-driven journey to create entrepreneurial solutions to social problems. Johnson’s achievements began taking shape in the early 1980’s with his creation of Black Entertainment Television (BET) and have culminated in his current efforts in the retirement sector, where he’s become laser-focused on leveraging public/private sector solutions that narrow the wealth gap for minorities and women.

Consolidation is a powerful force in our world. Many of the world’s largest corporations are products of consolidation, and there are countless examples of the power of consolidation in our personal lives.

A new survey of American workers who would be eligible to receive a Saver’s Match federal matching contribution confirms the significant public policy benefits that the program could have in leveling the playing field for lower income savers – particularly for Black and Hispanic workers – while also finding that high levels of worker mobility could pose challenges in administering millions of annual matching contribution payments.

Missing participants, defined as individuals who have become disconnected from their retirement savings – often through their own inaction – are a significant challenge that has long plagued defined contribution plans.  Unfortunately, the responsibility for locating these persons falls squarely on the shoulders of plan sponsors.

On April 22, we will celebrate the 54^th annual Earth Day, which gives us the opportunity to celebrate our planet’s natural surroundings and contemplate how we can help preserve them. The advent, and ongoing expansion of recycling programs has enabled our society to reduce our waste—and although there is still quite a long way to go, we have evolved significantly from the post-World War II throwaway culture.

No retirement plan sponsor likes the idea of dealing with uncashed distribution checks, nor do they wish to draw unwanted regulatory attention or to become embroiled in costly litigation because of their uncashed check policies.

Unfortunately, many plan sponsors place themselves in precisely that spot, becoming unnecessarily over-burdened with unresolved uncashed checks, while inviting unwanted regulatory scrutiny and/or legal challenges by embracing flawed uncashed check policies.

A more-enlightened approach to managing the problem of uncashed checks seeks to minimize their numbers, while simultaneously steering clear of the “red flags” that could land them in hot water.

Policymakers and stakeholders in America’s defined contribution system have made important progress in advancing initiatives that could help to close the large racial wealth gap. While much of the groundwork has been laid, it will ultimately fall to retirement plan sponsors to make the difference by supporting four key retirement initiatives that will generate increased wealth and enhance retirement security for millions of America’s minority workers.

On the heels of the 11/7/23 announcement by the Portability Services Network that the industry-led consortium has launched its digital auto portability solution powered by Retirement Clearinghouse (RCH), RCH has made available the results from a new version of their Auto Portability Simulation (APS), a discrete event simulation that models the adoption of auto portability within America’s defined contribution system, over a 40-year period.

On the last day of 2023, a key provision of the SECURE 2.0 Act—increasing the limit on small 401(k) accounts subject to automatic rollovers into safe-harbor IRAs from $5,000 to $7,000—went into effect.