A title like this one was bound to happen; and I was tempted to publish it on April Fool’s Day-except that its really not a joke.
Where it comes from is the simple fact that any DC Lifetime Income Program
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The Key Role of the Quirky 403(b) “Master Custodial Agreement”
Many practitioners will point to the 2007 403(b) regs (the “new regs” as many of us often still call them, 16 years later…) as being a real seminal moment in the market, and probably rightfully so. However, an even more
The 403(b) CIT and the 12 Month Put
One of the inevitable results of Congress’s failure to cobble together some sort of compromise on what the most suitable “Securities Fix” would be for the 403(b) CIT is a flurry of activity to find some way to craft a
Secure 2.0’s New QDRO Rules: The Mainstreaming of the QLAC?
202(b) actually does not make any statutory change to any of the Code’s or ERISA rules governing the distribution of a plan’s assets pursuant to divorce or separation orders. Instead, it instructs Treasury to amend its QLAC rules, which are
Secure 2.0’s Unresolved 403(b) CIT Securities Law Issue
One of the more curious circumstances under SECURE 2.0 arises from Act Section 128, which purports to permit 403(b) plan custodial accounts to invest in interests in Collective Investment Trusts (CITs), referred to as “81-100” group trusts in the Act.
“Engineering” the Use of Individual Annuities In DC Lifetime Income Programs
Most of the commonly available individual annuities sold to consumers are not suitable for the purchase by plans as part of their DC Lifetime Income program without changes being made to the design, administration and compensation (it is also worthwhile
Resetting the Mindset: DC Lifetime Income “Decumulation Accumulation” and their Risk-Related Restrictions
The “Entity” Difference Between 403(b) and 401(a) Plans
When we assess how to implement the tremendous changes that we see on the horizon, whether it be implementing unique lifetime income vehicles, PEPs, collective trusts, or any other of the sort of the innovative programs being develop which are
Avoiding Studebaker
“Decumulation” of retirement benefits has shifted from defined benefit plans to defined contribution plans. I had written in 2009 that the demise of the DB plan was inevitable because of the rise and fall of plan sponsors. It is one
SECURE 2.0’s 403(b) PEP Rules Will Be, Well, Different…..
Congress is taking a well crafted, though pretty unusual, approach to the manner in which it has chosen to allow 403(b) plans to participate in PEPs. It is doing so in a way which seems to be a recognition of