Allen Steinberg : Perspectives

Employee benefit plans—especially retirement and health care—have become an increasingly important part of the employment relationship. For employers, these plans represent an important part of the total compensation package, a tool for retention and recruitment, and a growing financial and compliance burden. For employees, these plans represent a key part of their overall financial security and wellbeing, a financial burden, and a source of complexity and frustration. In effect, it’s complicated. Our firm is dedicated to helping employers manage these complexities and focus on the important things.

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Allen Steinberg

25.01.2019 06.47 CST

Notice 2018-95 offers relief to employers who have failed to properly administer the “once-in-always-in” rule for 403(b) plans. However, the Notice also serves as a reminder for potential plan design opportunities.

IRS Offers Relief for Certain 403(b) Eligibility Failures

Section 403(b) plans operate much like their cousins, 401(k) plans. But, there are some key differences.

403(b) Eligibility Relief

Notice 2018-95, issued by the IRs in December, provides very specific and targeted relief for retirement plans under Code Section 403(b). who failed to properly administer certain 403(b) eligibility rules. However, equally valuable to 403(b) sponsors, is the clarification contained in the Notice on how these eligibility rules are supposed to be administered.

Allen Steinberg

19.11.2018 08.31 CST

A number of long-term market trends are creating significant pressure on bundled recordkeepers’ revenues. The recordkeepers are responding to these revenue pressures through a variety of ways that impose additional costs on plans and participants.

Fee Compression: Fiduciaries Take Note

Retirement plan recordkeepers are seeing ongoing pressure on fees. Their approach to developing alternative revenue sources could have implications for plan fiduciaries.

fees Fiduciary recordkeeper

Revenue for “bundled” recordkeepers have been facing downward pressure for years--both on recordkeeping fees and asset management fees. Over the past decade recordkeeping fees have dropped 50 percent and investment fees paid by 401(k) plans have dropped by 38 percent over a similar period. These bundled recordkeepers are looking to fund managers, plans, and individual participants to compensate for this decline. The recordkeepers’ search for new revenue sources can create challenges for plan fiduciaries and sponsors and should be monitored closely.

Allen Steinberg

25.10.2018 09.34 CDT

Disclosure on health care costs can help reduce those costs. That is not always true.

Increased Health Care Disclosure: Will It Help?

The federal government has taken steps to increase the amount of information available to consumers about health care costs. Will it help?

Disclosure health care prescription drugs

In recent weeks the federal government has taken a number of steps to increase the information available to consumers. However, it is not clear whether these new disclosures represent breakthroughs in transparency or are simply window dressing.

Allen Steinberg

11.09.2018 03.20 CDT

A recent IRS private letter ruling approved an innovative approach that allows employees to balance student loan repayments with saving for retirement.

Combining Student Loan Repayments and Retirement Savings

By combining a 401(k) plan with student loan repayments, this approach may provide employers an opportunity to help employees meet student loan obligations without adding a costly new program.

401(k) college students graduate students innovative

The IRS recently approved a new plan design that allows employees to receive employer retirement contributions either by (i) making deferrals into the employer’s retirement plan, or (ii) making student loan repayments.

John Enyart

01.08.2018 09.08 CDT

A recent study provides strong evidence that the financial industry implicitly tolerates adviser misconduct and that certain firms have created a secondary market for advisers who engage in misconduct.

Patterns of How the Financial Industry Tolerates Misconduct

This paper helps demonstrate how it is not enough for plan fiduciaries to rely on regulatory rules to protect against predatory behavior; as in so many horror movies, the predator is already inside the house.

Advisers FINRA Misconduct

A recent paper raises some important - and troubling - issues about how the financial industry treats advisers who engage in serious misconduct. The paper demonstrates how investment adviser misconduct is tolerated and how advisers who engage in misconduct are likely to be concentrated in certain firms.