DC Insights, Fall 2026

INSIGHTS AN OFFICIAL PUBLICATION OF PLAN SPONSOR COUNCIL OF AMERICA

For Defined Contribution Plan Sponsors

Fall 2026

Roth’s Rise From Niche to Necessary Nearly every defined contribution plan now offers a Roth option for participants, yet misconceptions about it persist.

ALSO

CYBERSECURITY MEETS ERISA COLLECTIVE INVESTMENT TRUSTS IN RETIREMENT PLANS IMPLEMENTING A NQDC PLAN

INSTITUTIONAL SERVICES

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1

CONTENTS

FALL 2026

COVER STORY

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16

16 Roth’s Rise: From Niche to Necessary Nearly every defined contribution plan now offers a Roth option for participants, yet misconceptions about it persist.

by Hattie Greenan

Virtual Investment Summit December 1, 2026 2027 National Conference May 3-5, 2027 Saint Louis, MO

FEATURE

Upcoming Webcasts:

22 PeopleImages / Shutterstock.com

UPCOMING DATES & EVENTS

Cybersecurity Meets ERISA This article is practical guide for HR and employee benefits professionals on ERISA fiduciary responsibilities regarding cybersecurity and data protection in retirement plans.

by Adam Greetis and Stephen McCaffrey

Onboarding New Committee Members: Setting Fiduciaries Up for Success September 18, 2026, 2PM Eastern Bringing Guaranteed Income Into Your Plan: Lessons from a Real-World Implementation September 23, 2026, 2PM Eastern 2026 HSA Trends & Innovations October 1, 2026, 2PM Eastern

PSCA.ORG

2

CONTENTS

FALL 2026

IN EVERY ISSUE

6 Editor’s Note From Access to Understanding

by Hattie Greenan

7 New Members

10 President’s Page Honored to Serve: Working Together

by Michelle McGovern

Pixelated 275 / Shutterstock.com

12 Leadership Letter Looking Ahead in 2026

by Will Hansen

40

28

Retirement Read(y) 20 Years Later, Did the PPA Really Change Everything?

by Nevin Adams

ARTICLES

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30

36

Member News Celebrating Excellence in Retirement Plan Leadership

NQDC Implementing a NQDC Plan

Financial Wellness A Beneficiary Designation Wellness Check

by Hattie Greenan

28 Education Reimagining the “Second Fifty”

by Maria Quitugua

by Nicole Cooper

32 Investments Collective Investment Trusts in Retirement Plans

by Eric Dyson, Melanie Lambie, and Matt Novak

42 Plan Sponsor Perspectives Roth’s Impact

by Hattie Greenan

by Jennifer Benford Seibert

44

38

Washington Watch Building SECURE 3.0’s Foundation, No Matter Who Wins in November

HSAs More Employees are Saving in Their HSA

by Hattie Greenan

PSCA.ORG

by Josh Oppenheimer

The participant journey doesn't end when employment does.

Supporting former employee retirement accounts after separation.

Former employee retirement accounts can create ongoing responsibilities for plan sponsors long after someone leaves the company. People move, contact information becomes outdated, and communications can become harder to deliver.

Inspira Financial supports plan sponsors with automatic rollover IRA services for eligible balances, participant communications support, participant search services, and account assistance for accountholders.

Explore automatic rollover IRA solutions

Employment ends.

Life moves forward.

Addresses change.

Contact information becomes outdated.

Participants may move.

Change jobs, or lose track of retirement savings.

Communications can be harder to deliver.

The retirement journey continues.

And so does your responsibility.

Inspira Financial Trust, LLC and its affiliates perform the duties of a directed custodian and/or an administrator of consumer-directed benefits and, as such, do not provide due diligence to third parties on prospective investments, platforms, sponsors, or service providers and do not offer or sell investments or provide investment, tax, or legal advice.

Inspira Financial and Inspira are registered trademarks of Inspira Financial Trust, LLC. Inspira Financial Trust, LLC does business as Inspira Associates, LLC in Arizona, California, Michigan, Nevada, Virginia, Washington, and Wisconsin. © 2026 Inspira Financial Trust, LLC. All rights reserved.

4

ADVOCACY, EDUCATION, AND INSIGHT FOR AMERICA’S RETIREMENT

FALL 2026 Insights is Published by

PSCA MEMBER BENEFITS AND RESOURCES Conferences and Training National and regional conferences designed for defined contribution plan administrators and sponsors.

Our must-attend events provide education from industry leaders and peer networking.

Signature Awards Peer and industry recognition for employee communication and education.

Recognizing outstanding defined contribution programs implemented by plan sponsors, administrators, and service providers.

Research and Benchmarking PSCA surveys: Most comprehensive and unbiased source of plan benchmarking data in the industry.

Annual surveys of profit sharing, 401(k), 403(b), and NQDC plans, as well as HSAs, created by and for members. Current trend and other surveys available throughout the year. Free to members that participate. Surveys currently available include: • 68th Annual Survey of Profit Sharing and 401(k) Plans • 2025 403(b) Plan Survey • 2025 NQDC Plan Survey • 2026 HSA Survey Executive Report A monthly electronic legislative newsletter.

Providing concise, current information on Washington’s most recent events and developments.

Media Outreach PSCA works to ensure fair coverage of the DC system in the media.

PSCA continually speaks to reporters to provide and promote accurate, concise, and balanced coverage DC plans and responds to negative press with editorials and letters to the editors. PSCA is also active on social media — follow us on twitter at @psca401k and on LinkedIn. Washington Representation Your direct connection to Washington DC events and developments affecting DC plans.

PSCA works in Washington to advocate in the best interests of our members and bring you the latest developments that will impact your plan. PSCA is a founding board member of the Save Our Savings Coalition that is currently working in Washington to preserve plan limits amongst tax reform.

Quarterly Magazine, Insights An award-winning and essential 401(k) and profit sharing plan resource.

Featuring nationally-respected columnists, case studies, the latest research, and more. Providing practical and constructive solutions for sponsors.

Professional Growth — Join a Committee!

For plan sponsors, administrators, and service providers.

Editor, Director of Research & Communications Hattie Greenan hgreenan@usaretirement.org Executive Director Will Hansen whansen@usaretirement.org PSCA Leadership Council OFFICERS President Michelle McGovern, American College of Surgeons Immediate Past President Brandon Diersch, Microsoft Directors Joyce Anderson, GE David Blieler. Vinings Corp.

Ann Brisk, HSA Bank Lisa Buffington, MMA Chris Dall, PNC Carissa Dunaway, Oak Ridge National Laboratory Yvette George, Henrico County Government Adam Greetis, Seyfarth Shaw LLP Lenora Hernandez, Don Roberto Jewelers Tiffany Herron, Flatiron Dragados Melanie Lambie, Vizo Financial Sheri Melvin, Union of Concerned Scientists Tom Moore, Thryv Rose Murtaugh, International Motors LLC Cynthia Obenland, Precision Medicine Group Greg Pesek, Panera Bread Company Maria Quintiguia, Public Employee Retirement System of Idaho Alexandra Richardson, Mercer Laura Stamps, Financial Finesse Tracy Tillery, GM

Many opportunities for PSCA members to serve on committees, speak at regional and national conferences, and write articles for Defined Contribution Insights.

PSCA Mission Statement The Plan Sponsor Council of America (PSCA) is a broadly based association of diverse businesses which believe that profit sharing, 401(k), and related savings and incentive programs strengthen the free-enterprise system, empower and motivate the workforce, improve domestic and international competitiveness, and provide a vital source of retirement income.

PSCA Competition Law Statement The Plan Sponsor Council of America (PSCA) is committed to fostering a best practices environment for profit sharing, 401(k), and other employer-sponsored defined contribution retirement programs. PSCA adheres to all applicable laws which regulate its activities. These laws include the anti-trust/competition laws which the United States has adopted to preserve the free enterprise system, promote competition, and protect the public from monopolistic and other restrictive trade practices.

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Insights is published by the Plan Sponsor Council of America, 4401 N. Fairfax Drive, Suite 600, Arlington, VA 22203. Subscriptions are part of PSCA membership. Opinions expressed are those of the authors. Nothing may be reprinted without the publisher’s permission. Information contained in Defined Contribution Insights is for general education purposes only and should not be relied upon as legal advice. Contact your legal advisor for advice specific to your plan.

Copyright ©2026 by the Plan Sponsor Council of America.

That's why we focus on a participant-first approach to retirement investing.

See why retirement is personal

©2026 MFS Investment Management 68440.2

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6

EDITOR’S NOTE

by Hattie Greenan

FALL 2026

From Access to Understanding Landmark legislation 20 years ago fundamentally reshaped the retirement plan landscape. As the system continues to bend and grow, we are increasingly moving from a focus on access and options, to a focus on how to best use those options to maximize retirement preparedness.

THIS YEAR MARKS THE 20TH ANNIVERSARY OF THE PENSION PROTECTION ACT (PPA), LEGISLATION THAT FUNDAMENTALLY RESHAPED THE RETIREMENT PLAN LANDSCAPE. From automatic enrollment and diversification protections to the continued growth of defined contribution plans, many of the features we now consider standard were accelerated by reforms put in motion two decades ago. In this issue’s Retirement Read(y) article, Nevin Adams answers the question he initially asked 20 years ago – did the PPA change everything?

SECURE Acts 1.0 and 2.0 (and a potential future SECURE 3.0) build on features established in the PPA, expanding access to plans and expanding options for participants to make saving in workplace plans more attractive and more effective. Several articles in this issue examine this expanding toolkit available to both plan sponsors and participants.

IN ADDITION TO THE 20TH ANNIVERSARY OF THE PPA, THIS YEAR MARKS ANOTHER MILESTONE – THE 30TH ANNIVERSARY OF THE PSCA-CREATED 401(K) DAY. Our cover story explores the rise of Roth contributions, which have gone from a niche feature to a near-universal component of defined contribution plans, creating an education issue along the way. As Roth options continue to expand through SECURE 2.0, sponsors increasingly find themselves balancing innovation with education, helping participants understand not only how these options work, but when they may be most beneficial. Our accompanying Plan Sponsor Perspectives articles highlights how sponsors have navigated the implementation of Roth catch-up contributions and participant communications.

Innovation extends well beyond Roth. This issue also explores the growing use of collective investment trusts, considerations for employers establishing nonqualified deferred compensation plans, and the latest findings from PSCA’s HSA survey. Together, these articles reflect the continued expansion of workplace benefits and savings opportunities designed to help employees meet a variety of financial goals.

In addition to the 20th anniversary of the PPA, this year marks another milestone – the 30th anniversary of the PSCA-created 401(k) Day. As the PPA and subsequent legislation worked to expand options for employers and participants, PSCA has continued to provided resources to explain, support, and educate both on the innovations as they came. As plans and regulations have evolved, so have the 30 years of educational resources PSCA has provided to help employers educate participants on the options. From game boards to comic strips, to infographics and videos … this year the campaign focuses on engagement in an automatic world and provides podcasts on key concepts.

Retirement plans also face new challenges not present 20 or 30 years ago. Our feature article walks through ERISA fiduciary duties as it relates to cybersecurity and examines how protecting participant Follow the Discussion:

@PSCA401k

Plan Sponsor Council of America PSCA.ORG

information and assets has become an essential part of prudent plan governance.

Finally, our Washington Watch column looks ahead, examining how policymakers may continue building the foundation for a future SECURE 3.0, regardless of the outcome of November’s elections. As the regulatory and legislative landscape continues to evolve, sponsors remain at the center of translating policy into meaningful retirement outcomes.

Taken together, the articles in this issue illustrate how far the retirement system has come over the past two decades, and the important role plan sponsors continue to play in shaping its future.

Hattie Greenan is the Director of Research and Communications for PSCA.

Editor

Plan Sponsor Council of America

WELCOME

NEW & RECENTLY CREDENTIALED MEMBERS

CERTIFIED PLAN SPONSOR PROFESSIONALS Oksana Abbott

Melanie Borges

William Corbin

Kristin Firestone

Christina Abney

Mara Bosch

Christiane Crabtrey

Denise Ford

Jennifer Abramis

Katie Bowers

Beth Craig

Erin Fox

Elizabeth Adams

Anelia Bran

Loretta Crawford

Amber Foy

Mardel Ahleong

Tony Brayton

Wendy Cullen

David Freedman

Roger Ahlfeld

Holly Brennan

Heather Cupp

Lana Frisch

Leslie Alexander

Cheri Brenton

Laura Curry

Sarah Fryover

Shawna Anderson

Antonio Briceno

Rachel De Bruin

Leticia Fuentes

Marcela Arenas

Moira Browning

Annie De Haven

Anita Gaddi

Sandra Armstrong

Heather Buchanan

Ethan Dean

Jessica Gann

Dana Baird

Nicolas Burnand

Vanessa Delgado

Paula Gant

Cara Baker

Janel Burnworth

Nakwai Deshields

Thurman Gardner

Omar Balaguer Ramos

Claudette Burrell-Richards

Heidi Dolan

Rhonda Gearlds

Kaberlin Ballard

Brian Burrows

Tracey Dolezal

DeMaris Gee

Madison Beckham

Kelly Caleb

Kaye Downey

Rachel Gent

Rashonda Bell

Liz Canavan

Jaime Dozier

Rhonda George

Brandon Belote

Erika Cano

Emmett Drea

Bryar Gibler

Jennifer Benites

Alisha Cantwell

Megan Dudley

Giselle Gillis

Shamiso Beta

Elizabeth Carrillo-Bejarano

Sydney DuEst

Nicole Goebel

Alex Bickell

Shelly Carter

Jennifer Duffy

Mark Gohlke

Karen Blake

Rebecca Cashman

Priscilla Edwards

Yolanda Gonzalez

Crystal Blanco

Jessica Castillo

Doron Elad

Janet Goris

Jennifer Blume

Deborah Cataldo

Mark Elliott

Olga Gorkovenko

Joseph Boateng

Susan Catanoso

Renee Elliott

Hanem Goubrial

Amanda Boge

Megan Chase

Jennifer Emmons

Karen Graves

Irvin Bohac

Lisa Chavez

Brandi Epps

Shawn Griffith

Shelby Boldt

Louise Chikigak

Kristi Esche

Connor Groh

Dawn Bollinger

Joanna Cline

Jo Michelle Fantanza

Hanxiao Gu

Kathleen Bollingmo

Robert Congdon

Carlos Febus

Kimberly Guasca

David Bond

Trina Cook

Jackey Filipski

Katie Guerdan

Ernestine Booth-Henry

Kimberly Cooper

Brenda Finke

Crystal Gurney

Learn More at psca.org

WELCOME

NEW & RECENTLY CREDENTIALED MEMBERS

CERTIFIED PLAN SPONSOR PROFESSIONALS Gisela Guzman

Christi Jacobs

Michelle Lahti

Andrea Mcgarrah

Mark Hall

Paulina Jacobs

Erika Lanceskes

Patrick McGary

Richard Hall

Semone James

Shirley Laney

Michelle McGuire

Daniel Halle

Daniela Janceski

Amelie Lanza

Austin Mead

Eric Hansen

Caroline Jernigan

John Lanzetta

Katherine Mead

Robyn Harris

Jennifer Johns

Donna Laughlin

Mike Merrill

Amanda Harrison Scott

Leslie Johnson

Tiffany Leathers

Seth Mertz

Wesley Hatcher

Ciera Jones

Wendy Lecleir

Jacqueline Meskinis

Jessica Hayden

Felisha Jones

Ross Lederer

William Milano

Eboni Hayes

Mallory Jones

Yujin Lee

Sarah Milliman

Laura Haynes

Pamela Jones

Trisha Lehenbauer

Carlin Milner

Graham Hays

Robert Julius

Christina Lewis

Michelle Mirshak

Matthew Henton

Michael Kalbach

Amy Liebenson

Tiffany Montalto

Jill Hermann

Amina Kanwar

Stephanie Liuzza

Alexia Montavon

Rochelle Herrera

Alayna Kaplan

Deanna Locklair

Marla Moore

Keith Hildibrand

Julie Kastner

Alicia Long

Kristin Morrison

Kittie Hill

Connie Keating

Cassandra Long

Jennifer Moser

Taryn Hinkle

Debbra Keener

Dana Lord Younts

Amanda Mouser

Phuong Hoa

Caitlin Kelley

Andrea Lubbers

Christine Mueller

Joni Hoff

Monica Kennedy

Angelique Lucas

Jeffrey Naftal

Debs Hollands

Courtney Kieba

Zoey Lynch

Shannon Nelson

Jamesia Hollins

Namkyu Kim

Jeremy Maclaughlin

Chelsea Newton

Whittney Hood

Bridget Kingsbury

Annamaria Marciano

Vietlong Nguyen

Aaron Hoosier

Gary Kinser

Greg Martin

Osa Ngwa

Denise Hoskinson

Angela Klaas

Diana Martinez

Janelle Nichols

Lisa Houston

Kinsey Klasnich

Johanna Mastroti

Hanna Nielson

Kelly Howes

Robert Kline

Kaylyn Matthys

Karen Niethe

Elie Ishac

David Knapp

Patricia Mcbride

Mhyrynde Noa

Courtney Jackson

Elizabeth Korduba

Ruth McCabe

Kita Oats

Crystal Jackson

Mary Elise Kozemchak

Jessica McDavid

Amanda O’Brien

Kristen Jacob

Kayla Ladson

Kristen McGaffin

Amanda Olson

Learn More at psca.org

WELCOME

NEW & RECENTLY CREDENTIALED MEMBERS

CERTIFIED PLAN SPONSOR PROFESSIONALS Lanny Olson

Terri Roseberry

Becca Smolenski

Cristina Vidal

Michelle Olson

Devon Ross

Mary Songer

Lindsay Vlaming

Levi Olvitt

Kathy Russell

Ewan Souza

Kevin Wade

Greyson Orellana

Melissa Russell

Amanda Stevens

Kristine Wagner

Dawn Ortega

Barry Sacks

Mckenzie Stewart

Jenny Wang

Giselle Ortiz

Leah Saenz

Melissa Stewart

Riley Warren

Cember Oxley

Sherill Sampson Kirksey

Nicole Stewart

Diane Waters

Wendy Page

Deanna Sanders

Emma Stuart

Jenni Weldon

Anna Liza Palmiery

Amanda Sapier

Sam Stubbs

Vern Whaley

Jennifer Parrott

Patrick Savage

Shakena Suggs

Jill White

Kelly Peterson

Mario Scherhaufer

Matthew Sullivan

CJ Whiteaker

Meghan Pfenninger

Kyle Schierer

Ashleigh Swain

Steven Whited

Gayle Phillips

Alysha Schoedel

Stefanie Swallows

Tyler Wiese

Christian Pineda

Katherine Schold

Dawn Swaninger

Shane Williamson

Mario Pintor

Ashley Schongar

Ashley Swanson

Dana Willis

Joseph Posner

Stephanie Sconce

Juliana Swisher

Kaneisha Wilson

Kim Price

Denise Scott

Kimberley Tallent

Mindy Wilson

Anita Prouty

Heather Seeley

Meagan Theiss

Dan Woodard

Katri Rantanen

Rob Sihto

Borodine Themistocle

Jaclyn Woodard

Lynn Redd-Kipper

David Silva

Amalie Thibodeaux

Aimee Woodhall

Evelyn Reed

Alisha Simmons

Alyssa Thomas

Claudia Yanez

Linda Ressinger

Tiffany Sinclair

Dannielle Thrall

Alyssa Yin

Michelle Reyes

Gregory Siqueiros

Loretta Trotter

Nona Yocheva

Tobie Richey

Janet Skelton

Chinghao Tseng

Mitch Zaloudek

Katie Rigby

Carrie Skoll

Brandi Turner

Raquel Zapata

Kelsee Roberson

Rebecca Sledge

Josey Van Weelden

Jada Zeck

Karen Roberts

Brandi Smith

Andrea Varela

Marcie Zurek

Sally Rochotte

Brittany Smith

Anthony Vargo

Jessica Rogers

Juanita Smith

Marnie Vaughan

John Rohal

Kieana Smith

Kelly Vaughn

Selena Rojas

Shanna Smith

Sarah Venuti Yates

Learn More at psca.org

10 FALL 2026

PRESIDENT’S PAGE

by Michelle McGovern

Honored to Serve: Working Together It is an incredible honor to begin my term as President of the Plan Sponsor Council of America (PSCA).

I AM GRATEFUL FOR THE TRUST PLACED IN ME BY THIS OUTSTANDING ORGANIZATION AND THE OPPORTUNITY TO SERVE alongside so many dedicated professionals who are committed to strengthening retirement security for millions of American workers.

Before looking ahead, I want to recognize the remarkable leadership that has brought us to this moment. Our immediate past president, Brandon Diersch, Leadership Council, committee chairs, volunteers, and the exceptional PSCA staff have invested countless hours advancing our mission. Their commitment has strengthened our profession, expanded educational opportunities, elevated the voice of plan sponsors, and ensured that PSCA remains a trusted resource for our members. I am sincerely thankful for the strong foundation they have built.

Today, the work of plan sponsors has never been more important—or more complex.

Benefit professionals are balancing increasing regulatory requirements, evolving fiduciary responsibilities, rising participant expectations, new technologies, workforce demographic shifts, litigation management and the ongoing challenge of engaging employees in their preparation for retirement. At the same time, we are asked to be strategic business partners, advocates for our employees, and responsible stewards of our organizations’ retirement programs.

These responsibilities are significant, but they also present tremendous opportunities.

Across the country, benefit managers and retirement professionals demonstrate remarkable resilience, creativity, and dedication. Every day, they navigate difficult decisions while remaining focused on one common purpose: helping employees achieve greater financial security and confidence in retirement. It is work that often happens behind the scenes, yet it has a lasting impact on individuals, families, and communities.

As President, my commitment is simple: to listen, collaborate, and help move our work forward together.

PSCA has always been strongest when our members share ideas and resources, learn from one another, and work collectively to solve challenges facing our profession. I look forward to building on that tradition by fostering meaningful conversations, expanding opportunities for professional development, and ensuring our members continue to have a strong voice on the issues that matter most.

I am also excited about the opportunities to strengthen collaboration across the American Retirement Association’s sister organizations. While each organization serves a unique audience, we share a common mission: promoting a strong, sustainable private retirement system that benefits participants, employers, and the retirement industry as a whole.

By working more closely with our sister organizations, we can leverage our collective expertise, advocate more effectively, and develop innovative solutions that benefit the entire retirement community. Together, our voices are stronger, our perspectives broader, and our impact greater.

Beyond our professional responsibilities, I also believe we have an opportunity to make an even greater difference in the communities we serve. Whether through education, volunteerism, mentorship, or advocacy, we can extend our influence beyond the workplace and help improve financial well-being for individuals across the country. Retirement readiness is not simply a workplace issue—it is a community issue, and one where we can all play an important role.

As I begin this journey, I do so with optimism and humility. I know that the challenges ahead will continue to evolve, but I also know that our membership is filled with talented, passionate professionals who care deeply about improving outcomes for American workers.

PSCA.ORG

I look forward to learning from each of you, celebrating our successes together, and addressing our challenges with collaboration, innovation, and purpose. Thank you for the opportunity to serve.

As we begin this next chapter, I invite each of you to be part of the conversation. Whether you are a longtime member, recently credentialed CPSP, a first-time conference attendee, a committee volunteer, or someone looking for new ways to engage, your experiences and perspectives matter. The strength of PSCA has always come from the willingness of its members to share ideas, support one another, and work toward common goals. I encourage you to get involved, ask questions, volunteer your expertise, and connect with fellow professionals. Together, we can continue advancing our profession, strengthening retirement security, and making a meaningful impact for the millions of Americans who depend on the plans we help steward every day.

I am excited for what lies ahead—and even more excited to work alongside all of you as we write the next chapter of PSCA’s story.

Michelle R. McGovern, CPSP, is the Chief Human Resource Officer for the American College of Surgeons and PSCA’s current President.

2026 HSA Survey Results Now Available The only source of HSA benchmarking data

12 FALL 2026

LEADERSHIP LETTER

by Will Hanson

Looking Ahead in 2026 PSCA is working hard to meet members where they are with the resources they need, and in the formats they want.

I HOPE EVERYONE HAD A SAFE AND HAPPY SUMMER. AS WE HEAD INTO THE FALL, IT’S TIME TO SHIFT GEARS, AND FOR PLAN SPONSORS, THAT MEANS ONE THING: open enrollment season is right around the corner. It’s a busy stretch, and PSCA is here to help you make the most of it.

Before we get into what’s ahead, I want to take a moment to talk about how we’re delivering it to you. We’re living in a digital age, and the way our members want to consume content is changing fast, so we’ve been investing in new formats all year long. The biggest addition is our new podcast, Will U Retire (yes, I know). Our first guest was Michelle McGovern, current President of PSCA, and that set the tone for what this show is all about. We’re not interested in another podcast full of talking heads reciting statistics. Our guests are plan sponsors, in the trenches every day, sharing the real stories behind running a plan: what’s working, what’s not, and what they wish someone had told them sooner.

Alongside the podcast, we’ve ramped up our presence on LinkedIn to share timely insights where you’re already spending time, and we’re just getting started on short-form video, so keep an eye out for more of that in the coming months. Our goal is simple: meet you where you are, with content that actually fits into your day.

On the compliance side, we kicked off our quarterly fiduciary webinar series earlier this year and it’s been a great way to keep plan sponsors current on the issues that matter most. Our next session in mid-September will focus on onboarding new committee members, a topic that comes up constantly in our conversations with sponsors. Committee turnover is inevitable, and getting new members up to speed quickly matters for good governance, so this one is worth your time whether you’re new to a committee or bringing someone else up the curve.

Looking further ahead, we’ll be rolling out more information on the Saver’s Match to help you and your participants get ready for 2027. Adding it to your plan is optional, but it stands to make a real difference for your low to moderate income workers, giving them an added incentive to save that wasn’t there before. We want to make sure you understand the mechanics and have the resources you need well before it takes effect, so expect to see a lot more from us on this topic in the months ahead.

I’m also excited to share that our NQDC Certificate Program is officially in development, with a launch planned for next year. This has been a member request for a while now, and we’re working hard to bring it to life.

As always, PSCA is here for you. Let us know what you need and how you need it, and we’ll do everything we can to make it happen.

Will Hansen is PSCA’s Executive Director and Chief Government Affairs Officer for the American Retirement Association.

PSCA.ORG

WE’RE LIVING IN A DIGITAL AGE, AND THE WAY OUR MEMBERS WANT TO CONSUME CONTENT IS CHANGING FAST, SO WE’VE BEEN INVESTING IN NEW FORMATS ALL YEAR LONG.

FOR PLAN SPONSORS CERTIFICATE

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Sponsored by

14

MEMBER NEWS

FALL 2026

Celebrating Excellence in Retirement Plan Leadership PSCA Honors the 2026 CPSP Members and Plan Advisor of the Year winners.

CPSP MEMBERS OF THE YEAR: ADVANCING EXCELLENCE IN PLAN SPONSORSHIP

EACH YEAR, PSCA RECOGNIZES PROFESSIONALS WHO EXEMPLIFY LEADERSHIP, INNOVATION, AND DEDICATION TO IMPROVING RETIREMENT OUTCOMES FOR AMERICAN WORKERS. The recipients of the 2026 Plan Advisor of the Year Award and the Certified Plan Sponsor Professional (CPSP) Member of the Year awards represent the very best of the retirement plan community, demonstrating a commitment to excellence that extends well beyond their organizations and into the lives of the participants they serve.

The CPSP Member of the Year awards recognize individuals who have leveraged the Certified Plan Sponsor Professional credential to strengthen retirement plans, improve participant outcomes, and elevate the role of plan sponsors within their organizations. This year’s honorees showcase the diverse ways retirement plan professionals can drive meaningful change.

2026 Plan Advisor of the Year: Christopher M. Dall, CFA Christopher M. Dall, CFA, is the Head of Defined Contribution Retirement Solutions at PNC Institutional Asset Management.

Throughout his career, Dall has been a passionate advocate for helping plan sponsors create stronger retirement programs and improve financial outcomes for employees. In his role at PNC, he leads teams responsible for investment advisory, investment management, financial wellness, and employee education services for defined contribution retirement plans. His work has helped employers strengthen workplace retirement programs while improving participant retirement readiness.

Dall’s influence extends well beyond his organization. Since joining PNC in 2015, he has become a respected voice in the retirement industry through research, commentary, conference presentations, and thought leadership initiatives.

His contributions to PSCA have been equally significant. Dall currently serves on PSCA’s Leadership Committee and previously chaired the Thought Leadership Council, helping guide research, educational programming, and industry discussions that support plan sponsors nationwide.

Dall’s recognition reflects not only professional achievement but also a longstanding commitment to advancing best practices and helping plan sponsors navigate an increasingly complex retirement landscape.

David Clark: Turning Knowledge into Action David Clark, Senior Manager of HR Operations at Arcus Biosciences, earned recognition for transforming CPSP knowledge into tangible improvements for participants and retirement plan operations. As the organization’s primary retirement plan contact, Clark oversees plan administration and works closely with leadership to deliver benefits that support employee financial well-being.

After earning his CPSP credential in 2025, Clark helped implement a series of participant-focused enhancements, including increased employer matching contributions, automatic escalation features, expanded Roth savings opportunities, greater flexibility for deferral changes, enhanced educational programming, and an onsite benefits fair.

Beyond plan design improvements, Clark applied his fiduciary and operational expertise to identify and correct administrative issues, helping protect both participants and plan integrity. His commitment to making retirement benefits easy to understand and accessible to employees has had a measurable impact on retirement readiness across the organization.

PSCA.ORG

MEMBER NEWS

15 FALL 2026

Brittany Wieringa: Championing Retirement Readiness Brittany Wieringa, Retirement Benefits Specialist at Upper Peninsula Power Company, represents a new generation of retirement plan leaders who are leveraging professional education to make an immediate impact. With more than a decade of employee benefits experience, Wieringa earned her CPSP credential in 2025 and quickly applied that knowledge to enhance plan operations and participant engagement.

Working closely with advisors and recordkeepers, Wieringa has implemented process improvements and expanded financial wellness programming designed to help employees prepare for retirement. Her talent for simplifying complex retirement concepts has strengthened participant education efforts through webinars and targeted communications.

Wieringa’s commitment to participant advocacy, governance excellence, and continuous professional development embodies the purpose of the CPSP program and demonstrates the powerful impact credentialed professionals can have on retirement outcomes.

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Stephanie Reece Griffin: Excellence in Governance and Participant Outcomes Stephanie Reece Griffin, Director of Employee Benefits for The Coca-Cola Bottlers’ Association, was recognized for her outstanding stewardship of a large multiple employer plan serving more than 14,000 participants and managing approximately $1 billion in assets.

With more than 15 years of experience in employee benefits and retirement plan oversight, Griffin has successfully applied CPSP principles to governance, investment oversight, risk management, and plan design. Her disciplined fiduciary approach contributed to a three percent increase in plan participation over the past year, demonstrating the real-world impact of thoughtful retirement plan leadership.

Griffin is also deeply committed to participant education.

Through clear communication and meaningful educational initiatives, she has helped employees make more informed retirement decisions while fostering strong partnerships with participating bottlers. Her collaborative leadership and strategic vision continue to strengthen both plan governance and participant success.

RECOGNIZING LEADERSHIP THAT MAKES A DIFFERENCE

The retirement industry continues to evolve, presenting new opportunities and challenges for plan sponsors, advisors, and benefits professionals. This year’s honorees have distinguished themselves through their dedication to improving retirement readiness, strengthening plan governance, and helping participants achieve better financial outcomes.

Whether through innovative plan design, exceptional fiduciary stewardship, participant-focused education, or industry leadership, Christopher M. Dall, David Clark, Stephanie Reece Griffin, and Brittany Wieringa exemplify the professionalism and commitment that drive success across the retirement plan community. Their achievements serve as a reminder of the important role retirement professionals play in helping millions of Americans build a more secure financial future.

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16 FALL 2026

COVER STORY

by Hattie Greenan

E RIS Roth’s

From Niche to Necessary Nearly every defined contribution plan now offers a Roth option for participants, yet misconceptions about it persist.

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COVER STORY

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T

o decades after Roth entered the workplace w retirement system through its addition in the Pension Protection Act of 2006 (PPA), plan sponsors are expanding Roth offerings, participants are embracing tax diversification, and SECURE 2.0 is creating new opportunities.

And yet, misconceptions about Roth persist.

At a recent SHRM conference, PSCA Executive Director Will Hansen was speaking to attendees about their plans, and more than one stated they have a 401(k) plan … and a Roth plan. There is no separate Roth plan – the employer offered a 401(k) plan with a Roth feature, as 95 percent of employers now do. The exchange was a reminder that even after two decades of Roth in 401(k)s, confusion remains widespread.

(particularly 403(b) plans) and some plan sponsor respondents indicate they have always allowed them, even prior to SECURE 2.0. In other words, some sponsors may have answered the

Availability of Roth Over Time

Percentage of Plans

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

59.9%

63.1%

69.6%

69.1%

75.1%

86.3%

87.8%

89.1%

92.5%

95.6%

That confusion persists despite Roth’s remarkable rise, or maybe because of its rapid rise – increasing dramatically in availability from 60 percent of plans (slightly more common among large plans) a decade ago to its current near universality (thanks in part to SECURE 2.0 provisions).

As Roth availability in retirement plans expands, it is moving beyond elective deferrals in part due to industry enthusiasm for tax diversification, and in part due to regulations that expand their access (often used to pay for other tax breaks).

SECURE 2.0 included the mandatory tax treatment of catchups contributions for some employees, as well as the option for Roth treatment of employer contributions, which is gaining in popularity. According PSCA’s most recent survey of 401(k) plans, 19.7 percent of plans either already offer or expect to offer Roth employer contributions, up from 13 percent a year earlier. Last year 22 percent of 403(b) plans sponsors indicated they allow it as well.

However, those figures may overstate actual adoption. In discussions with advisors, many state none of their clients have adopted Roth treatment of employer contributions yet

survey incorrectly, based on a misunderstanding of the provision itself or the applicability of Roth in retirement plans in general. This further begs the question of how much confusion remains around Roth-related concepts, despite its widespread availability.

As availability of Roth increases across contribution types and vehicles, it is important that we ensure everyone understands how it works and the implications of it now, and in retirement.

As Roth becomes a core

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component of retirement plan design, plan sponsors face the challenge of helping participants understand the growing menu of Roth options and make informed decisions about how to use them.

A BRIEF HISTORY OF ROTH

The Roth concept first entered the retirement landscape with the Taxpayer Relief Act of 1997, which created the Roth IRA. The idea was simple but powerful: instead of receiving a tax deduction today, savers would contribute after-tax dollars and potentially enjoy tax-free withdrawals in retirement.

The concept expanded into workplace retirement plans in 2006, when Roth 401(k) contributions became available through the PPA. Adoption was initially slow.

Many employers questioned whether participants would embrace the feature, recordkeepers needed to adapt systems, and workers often struggled to understand why they

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would voluntarily give up an immediate tax deduction.

Over time, however, Roth gained traction.

Participants became increasingly concerned about future tax rates.

Advisors emphasized the value of tax diversification.

Younger workers entering the workforce saw value in paying taxes on contributions while their earnings and tax rates were relatively low.

Today, Roth has evolved from a niche offering to an expected part of a well-designed defined contribution plan.

UNDERSTANDING THE GROWING ROTH MENU

As Roth originally began with IRAs (individual

retirement accounts), some still think IRA when they hear Roth. Confusion persists as “Roth” no longer refers to a single thing, rather it describes the tax treatment allowed in several different modalities.

Roth Employee Contributions Roth deferrals are the most common approach, allowable in plans for 20 years now. Participants contribute after-tax dollars through payroll deduction.

While no immediate tax deduction is received, qualified withdrawals, including associated investment earnings, can be taken tax-free in retirement.

Though the availability of Roth contributions is widespread, only 22

percent of participants made them in 2024 when offered the opportunity, which has only increased two percent in the last 10 years.

Roth Employer Contributions SECURE 2.0 introduced another Roth variation by allowing participants to elect Roth treatment of employer contributions (matching or nonmatching).

Traditionally, employer contributions have been made on a pre-tax basis, even when deferrals were made on a Roth basis. Under the new rules, participants can choose to treat those contributions as Roth contributions, recognizing the amount as taxable income in the year the contribution is made, if the employer amends the plan to allow it. This is a voluntary provision of SECURE 2.0 that some employers are offering, though it is not yet widely available.

In-Plan Roth Conversions Another Roth option available in many retirement plans is the in-plan Roth conversion. This feature allows participants to move assets from pre-tax to Roth within the plan, triggering income taxes on the amount converted in the year of the transaction.

Unlike ongoing Roth contributions, which apply only to new deferrals, an in-plan conversion gives participants the opportunity to change the tax treatment of existing retirement

THOUGH THE AVAILABILITY OF ROTH CONTRIBUTIONS IS WIDESPREAD, ONLY 22 PERCENT OF PARTICIPANTS MADE THEM IN 2024 WHEN OFFERED THE OPPORTUNITY, WHICH HAS ONLY INCREASED TWO PERCENT IN THE LAST 10 YEARS.

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savings. While conversions can be attractive to participants who expect higher tax rates in the future or who want to build a larger pool of tax-free retirement assets, the immediate tax consequences require careful consideration.

For plan sponsors, the feature represents another way to provide participants with flexibility and greater control over their long-term tax planning strategy. Sixty percent of plans now allow in-plan Roth conversions (PSCA’s 68th Annual Survey).

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Roth Treatment of Catch-Up Contributions Roth catch-up contributions have become one of the most discussed retirement plan provisions of SECURE 2.0 and this mandatory provision is responsible for the steep increase in availability the last two years (though it was already getting there on its own), particularly among 403(b) plans that had historically lagged 401(k) plans in adoption.

Beginning in 2026, participants whose prior-year wages from the employer exceed the IRS highly compensated threshold must make any catch-up contributions on a Roth basis if their plan offers catch-up contributions. The provision was originally scheduled

to take effect in 2024 but was delayed by the IRS to give plans, payroll providers, and recordkeepers additional time to prepare.

While implementation has required significant operational changes, PSCA survey data suggest sponsors remain committed to preserving catch-up opportunities for older workers. According to PSCA’s 68th Annual Survey, just 0.5% of plans eliminated catch-up contributions rather than adapt to the Roth requirement. The provision reflects a broader trend in retirement policy: using

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Roth taxation to generate near-term tax revenue while expanding participants’ access to tax-free income in retirement.

WHY ROTH CONTINUES TO GAIN GROUND

The appeal of Roth largely comes down to one concept: tax diversification. Just as investors diversify among asset classes, many advisors encourage participants to diversify among sources of retirement income. Retirees who have access to taxable accounts, tax-deferred accounts, and tax-free Roth assets may have greater flexibility when managing income and taxes throughout retirement.

For plan sponsors, Roth options also align well with changing workforce demographics. Younger employees often appreciate the opportunity to pay taxes now and potentially receive tax-free income later. Midcareer workers may value having both traditional and Roth options available. Higher earners frequently use Roth contributions as part of a broader tax-diversification strategy.

Importantly, the growth of Roth does not mean traditional pre-tax contributions have become obsolete. Rather, many participants benefit from having access to both.

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THE PARTICIPANT DECISION: ROTH OR TRADITIONAL?

For many participants, the biggest misconception is that they must determine which option is universally better when the reality is that the decision comes down to timing: when would you rather pay taxes?

With traditional contributions, participants receive a tax deduction today and pay taxes when the money is withdrawn in retirement.

With Roth contributions, participants pay taxes now and potentially receive qualified distributions tax-free later.

Because no one knows what future tax rates or retirement circumstances will look like, the decision is often less straightforward than it appears.

Participants should consider several factors: Current Tax Bracket Employees in lower tax brackets may find Roth contributions attractive because they are paying taxes at a relatively low rate today. And this doesn’t just apply to early-career or lower-income employees – employees who pay lower effective taxes due to deductions (such as dependents) may benefit.

Expected Future Earnings Workers early in their careers frequently expect their income to increase

IMPORTANTLY, THE GROWTH OF ROTH DOES NOT MEAN TRADITIONAL PRE-TAX CONTRIBUTIONS HAVE BECOME OBSOLETE. RATHER, MANY PARTICIPANTS BENEFIT FROM HAVING ACCESS TO BOTH.

over time. If future tax rates are likely to be higher, Roth contributions may become more appealing.

In many cases, the best answer may not be traditional or Roth.

It may be both.

THE NEXT CHAPTER FOR ROTH

Time Horizon The longer assets remain invested, the greater the potential benefit of tax-free growth. This is one reason Roth is frequently promoted to younger workers.

Retirement Income Sources Participants expecting income from pensions, substantial retirement savings, or other sources may appreciate having a source of tax-free retirement income available.

Tax Diversification Increasingly, advisors are moving away from an either-or approach and toward a diversification mindset. Many plans allow participants to split contributions between traditional and Roth sources.

For some workers, maintaining both types of accounts can provide flexibility regardless of future tax policy changes.

With nearly 96 percent of 401(k) plans and 80 percent of 403(b) plans offering Roth for employee deferrals, plan sponsors have overwhelmingly embraced the feature, even if regulations forced the issue to some degree. The story of Roth is still one of growth though as participants begin to understand its benefits and employers continue to add opportunities to make Roth contributions.

And as the availability of Roth continues to diversify across contribution types, the next chapter will focus on education.

As Will Hansen’s SHRM conference conversations illustrate, confusion remains common even among benefits professionals.

For years we have said that the low use of Roth by participants was not due to access or applicability, but due to a lack of understanding. But tax treatment of contributions is not the easiest topic to explain to participants who are also learning about investment options, compounding, and time horizons.

Roth education was just not a priority for plan sponsors juggling multiple competing ones. Now participants have more options to navigate - traditional contributions, Roth contributions, Roth employer contributions, conversions, and even conversations about backdoor Roth strategies.

As plan sponsors provide education about the mandatory Roth treatment of catchups, and Roth employer contributions, general participant understanding of Roth will increase, and so will its use.

The industry has largely solved the access problem. Now the challenge is helping participants understand when, why, and how to use the growing array of Roth options available to them.

Hattie Greenan is PSCA’s Director of Research and Communications.

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22 FALL 2026

FEATURE

by Adam Greetis and Stephen McCaffrey

CYBERSECURITY MEETS ERISA This article is practical guide for HR and employee benefits professionals on ERISA fiduciary responsibilities regarding cybersecurity and data protection in retirement plans.

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FEATURE

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As retirement plans have become increasingly digital – relying on online administrative platforms and participant portals hovering in the cloud – cybersecurity and data protection have moved to the forefront of fiduciary responsibility. For plan sponsors, these issues are no longer just concerns for information technology professionals, they are critical plan sponsor concerns carrying with them fiduciary responsibilities imposed by the Employee Retirement Income Security Act of 1974 (ERISA).

The U.S. Department of Labor (DOL) has made clear that these duties require a fiduciary to protect a plan and its participants from cyber threats.

Why it matters.

Cyber incidents can lead to: •T heft of participant assets • Exposure of sensitive personal data (e.g., Social Security numbers) which can lead to the theft of other assets • Operational disruption of plan administration

THE DOL’S CYBERSECURITY GUIDANCE

This article summarizes how ERISA’s fiduciary requirements apply to cybersecurity and data protection for retirement plans and what practical steps plan sponsors and plan fiduciaries can take to meet their obligations.

THE ERISA FIDUCIARY FRAMEWORK

ERISA imposes strict duties on retirement plan fiduciaries. The three core duties most relevant to plan sponsors with respect to cybersecurity are: • Duty of Prudence: Fiduciaries must act with the care, skill, prudence, and diligence of a knowledgeable expert.

• Duty of Loyalty: Fiduciaries must act solely in the interests of plan participants and beneficiaries.

• Duty to Follow Plan Documents: Fiduciaries must follow the plan’s terms.

In April 2021, the DOL published its first comprehensive cybersecurity guidance for retirement plan fiduciaries. The guidance consists of three core pieces.

Tips for Hiring a Service Provider Fiduciaries must prudently select and monitor outside benefit service providers.

In the guidance, the DOL recommends: • A ssessing providers’ cybersecurity practices, including audit history and processes and data security certifications •R eviewing past security incidents involving the service provider and their responses to such incidents

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•E nsuring appropriate contractual commitments between the provider and the plan sponsor •A sking the service provider about insurance coverage for cyberrelated losses Tips for Cybersecurity Program Best Practices The guidance also identifies elements of a strong cybersecurity program, including: • F ormal governance and risk assessment processes •E ncryption of sensitive data •M ultifactor authentication (MFA) •A ccess controls and system monitoring • I ncident response planning

FIDUCIARY DUTY OF PRUDENCE AND CYBERSECURITY

ERISA’s duty of prudence is the most critical lens through which cybersecurity responsibilities are evaluated.

What “prudence” means in this context.

To meet ERISA’s duty of prudence, plan fiduciaries should: •U nderstand cybersecurity risks to the plan • I nvite cybersecurity experts to help assess

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risks if the plan fiduciaries can’t make the assessment themselves • I mplement reasonable safeguards • Continuously monitor and update protections as threats evolve Importantly, prudence is a process-based standard, not a standard that measures any outcome.

So, even if a cyberattack occurs, the fiduciary needs to demonstrate that they followed a prudent decisionmaking process in developing and assessing the cyber protections that seems to have failed.

Practical applications HR and benefits professionals should ensure that they have: •D ocumented their service provider selection processes, including the providers’ cybersecurity processes •R egularly reviewed the service providers’ SOC reports (e.g., SOC 2 Type II) •P eriodically reviewed cybersecurity protections and process (with internal IT or outside experts as needed) to plan committees and other plan fiduciaries • I ntegrated their review and analysis with enterprise IT risk management

FIDUCIARY DUTY OF LOYALTY AND DATA PROTECTION

The duty of loyalty requires fiduciaries to act primarily in participants’ interests.

Cybersecurity intersects with this duty in several ways: •M aking sure the chosen benefit service provider adequately protects participant data from misuse or unauthorized disclosure •E nsuring that vendors do not exploit data for non-plan purposes in exchange for benefiting the plan sponsor •R equiring that plan fiduciaries avoid conflicts of interest in vendor selection Example If a plan sponsor chooses a retirement plan recordkeeper because the recordkeeper primarily offers the plan sponsor benefits, such as discounted services to the plan sponsor which are unrelated to the retirement plan, but the provider has weaker cybersecurity controls, that decision could raise fiduciary concerns.

VENDOR OVERSIGHT: A CRITICAL RISK AREA

Because so much of a retirement plan’s cybersecurity risk rests heavily on the outside recordkeeper, overseeing the outside recordkeeper is a central fiduciary responsibility.

Key Expectations Fiduciaries should: •C onduct due diligence before hiring •E valuate cybersecurity policies and procedures •R eview independent audits and testing results •N egotiate protective contract terms •D ata ownership and use restrictions •B reach notification timelines • I ndemnification for losses •M inimum security standards •M onitor vendors on an ongoing basis •R eview recordkeeper cybersecurity controls •H ave internal IT professionals or outside cybersecurity experts help the fiduciary assess risk and overall cybersecurity compliance •S olicit updates on emerging threats and mitigation efforts from the recordkeeper Common Pitfalls •A ssuming vendors “have it covered” without regular confirmation •F ailing to revisit cybersecurity issues after initially selecting the service provider •F ailing to document oversight efforts

PARTICIPANT-LEVEL RISKS AND CONTROLS

Cybersecurity risk is not limited to administrative platforms and recordkeeper activities; participant behavior is a major vulnerability.

Common Threats •P hishing attacks targeting participants •C redential theft •S ocial engineering Fiduciary Considerations Fiduciaries are not expected to control participant behavior but they should implement reasonable protections and educate their plan participants on the basics of data protection.

Practical Steps •E nable or require multifactor authentication (MFA) •E ducate participants on cybersecurity best practices •E nsure processes exist for secure identity verification for plan transactions

INCIDENT RESPONSE AND BREACH MANAGEMENT

Even with strong preventive controls, breaches can occur.

Fiduciaries must be prepared to respond effectively if and when the breaches occur.

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Key elements of a prudent response plan.

•E veryone needs to know their incident response roles •E stablish a process for containing the breach and investigating its cause •D eveloping protocols for communicating the breach to the applicable parties (participants, regulators, law enforcement) •D ocumenting the actions taken Why this matters.

A poorly handled cybersecurity breach can significantly increase fiduciary liability even if the initial cybersecurity attack was unavoidable.

DOCUMENTATION: THE FIDUCIARY’S BEST DEFENSE

When managing ERISA’s fiduciary requirements, documentation is critical. Fiduciaries must be able to demonstrate their process in seeking to comply with ERISA’s fiduciary requirements.

What to Document •V endor selection and review processes •C ybersecurity policies and risk assessments • I dentity of internal IT or external cybersecurity experts who supported the fiduciary’s assessment •F iduciary meeting processes reflecting cybersecurity discussions • I ncident response actions Tip: If cybersecurity is not reflected in fiduciary meeting minutes, there is no good proof that the committee considered the issue.

CYBER INSURANCE AND FINANCIAL RISK MANAGEMENT

While insurance does not replace fiduciary responsibility, it can be an important risk management tool.

Considerations •D oes the plan or sponsor’s existing coverage protect against cybersecurity related losses?

•D oes coverage extend to participant account losses?

•D o vendors maintain adequate insurance?

Fiduciaries should understand coverage limitations and ensure that the coverage limitations align with the potential risks.

EVOLVING EXPECTATIONS AND BEST PRACTICES

Cybersecurity responsibilities continue to evolve because of: • I ncreasingly sophisticated cyber threats •T he focus of applicable administrative agencies (e.g., DOL) •C ontinued fiduciary litigation

PRACTICAL ACTION PLAN FOR HR AND BENEFITS PROFESSIONALS

To translate fiduciary principles into action, consider the following checklist: Governance •E nsure cybersecurity is a standing agenda item for retirement plan fiduciaries •A ssign clear responsibility for overseeing cybersecurity risks Vendor Management •C onduct comprehensive due diligence •R eview SOC reports and certifications annually • I nclude strong contractual protections Technical Controls •C onfirm use of MFA, encryption, access controls and other data protection steps that stay ahead of developing threats •A lign with enterprise IT security where appropriate Participant Protection •E ducate participants and provide educational resources •S trengthen authentication and transaction safeguards Incident Preparedness •E stablish and test response plans •C oordinate with benefit service providers on cybersecurity risk management responsibilities

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Documentation •M aintain detailed records of decisions and reviews

CONCLUSION

Managing cybersecurity risks is now an integral part of ERISA’s fiduciary responsibilities. For retirement plan sponsors and fiduciaries, this means moving beyond a relying on IT departments or recordkeepers and actively overseeing these risks.

ERISA does not require fiduciaries to eliminate all cyber risk. Instead, ERISA requires fiduciaries to develop and demonstrate a prudent, well-documented process for identifying, mitigating, and responding to those risks.

By incorporating cybersecurity into fiduciary governance processes, strengthening benefit service provider oversight, and maintaining rigorous documentation processes, retirement plan sponsors can both protect participants and fulfill their ERISA fiduciary obligations in an increasingly digital landscape.

Adam Greetis is a Partner with Seyfarth Shaw LLP and chair of PSCA’s Government Affairs Committee.

Stephen McCaffrey is Sr. Counsel for National Grid.

VIRTUAL INVESTMENT SUMMIT December 1, 2026

SAVE THE DATE

28 FALL 2026

EDUCATION

by Maria Quitugua

Reimagining the “Second Fifty” When we think about modern retirement design, we need to look past the standard asset-accumulation metrics. Our real goal? Preparing people to navigate a retirement that can easily last 30 years or more.

PSCA has new resources to help you help your participants get there.

5. Plan for Healthcare Early: Research long-term care options ahead of time to avoid sudden financial stress.

I RECENTLY LISTENED TO THE PREMIERE EPISODE OF THE NATIONAL INSTITUTE ON RETIREMENT SECURITY (NIRS) PODCAST, Retirement in America, and it completely shifted my perspective on aging. Hosted by NIRS Executive Director Dan Doonan, the episode features Debra Whitman, Chief Public Policy Officer at AARP and author of the book The Second Fifty: Answers to the 7 Big Questions of Midlife and Beyond. Her main takeaway is powerful: retirement isn’t a passive end-state. It is a vibrant, decades-long second half of life that requires early, strategic planning. I wanted to share some key takeaways and resources with our plan sponsor community to help bring this framework to life.

DOUBLE THE CELEBRATION: 30 YEARS OF 401(K) DAY

THE CORE SHIFT: PLANNING FOR A LONGER “HEALTHSPAN”

Since traditional pensions have mostly faded away, individual choices now dictate long-term security. NIRS data shows that living past age 80 or 90 is the new normal. But a long life requires a healthy “healthspan”—the years spent in good physical, mental, and financial shape.

Today’s older adults are healthier, more educated, and more productive than previous generations. To help them capitalize on this, plan sponsors need to offer structured tools that replace retirement anxiety with proactive health and asset management.

FIVE ACTIONS TO SHARE WITH YOUR PARTICIPANTS

To secure a fulfilling, multi-decade retirement, participants need to align their money with their personal longevity goals. You can share these five pillars with your teams to get them thinking: 1. B oost the Financial Base: Bump up contributions today so savings outpace future inflation.

2. F ocus on Physical Health: Use workplace wellness benefits; staying fit is a massive retirement asset.

3. F ind a Post-Career Purpose: Figure out what will drive your days, whether it is part-time work, volunteering, or learning a new skill.

4. S tay Connected: Build strong social networks to protect cognitive health and mental well-being.

This fresh perspective arrives at a major milestone. The Plan Sponsor Council of America (PSCA) created National 401(k) Day back in 1996, making this year its 30th anniversary.

Scheduled annually for the Friday after Labor Day (but moved to Thursday this year in recognition of September 11th), the original idea was simple: employees could “start the week with Labor and end the week with Retirement.” For three decades, this day has been all about participant education. Employers can honor this milestone by moving past basic “save more” messaging and helping employees build a comprehensive roadmap for a much longer lifespan.

The 2026 401(k) Day Campaign: It is Never Too Little, Never Too Late PSCA’s 2026 campaign focuses on encouraging participants to become more engaged with their retirement plans by taking a few simple actions that can have a lasting impact on their long-term financial security.

As automatic enrollment has become more widespread, more workers are saving for retirement than ever before. But having an account is only the first step. This year’s campaign is designed to help participants understand their plans, access their accounts, and build habits that support stronger retirement outcomes over time.

The campaign theme addresses two of the most common barriers to retirement saving: the belief that there is not enough money to save and the misconception that it is too late to make a difference. Through practical resources and easy-to-follow guidance, “Never Too Little, Never Too Late” demonstrates how small actions taken consistently over time can help improve retirement preparedness.

Materials include: • A Five Steps to Get on Track flyer and infographic • Beneficiary designation education materials

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• Investment basics presentation slides • Compounding-focused infographics •A three-part podcast series featuring members of PSCA’s Education Committee with sample customizable employee communications PSCA’s three-part podcast series provides concise, approximately 10-minute discussions covering retirement planning fundamentals, maximizing savings opportunities, and understanding investment options. Employers can distribute the over time or share them all at once as part of their 401(k) Day activities.

All materials are available on PSCA’s website at www.psca. org/401kday.

YOU ARE THE CHOICE ARCHITECT

As an employer, you are the primary architect of your employees’ retirement success. By setting up features like autoenrollment, auto-escalation, and longevity calculators, you remove the mental hurdles that keep people from saving.

The 30th anniversary of 401(k) Day is the perfect time to change the conversation around retirement. By using these free tools, you can act as a guide—helping your employees fully fund and enjoy their “second fifty.”

Maria Quitugua is the Member Education Supervisor for the Public Employer Retirement System of Idaho and Chair of PSCA’s Education committee.

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30 FALL 2026

NQDC

by Nicole Cooper

Implementing a NQDC Plan A member of PSCA’s NQDC committee shares lessons learned from implementing a new NQDC plan.

IMPLEMENTING A NONQUALIFIED DEFERRED COMPENSATION (NQDC) PLAN IS A COMPLEX, STRATEGIC INITIATIVE THAT EXTENDS WELL BEYOND ADDING AN EXECUTIVE BENEFIT. While the end result can be highly valuable for both the organization and eligible leadership, the process requires deliberate coordination, technical depth, and disciplined governance. Based on a recent implementation experience, the following lessons are intended for benefits, compensation, legal, finance, and consulting professionals who work in the NQDC space and may be evaluating, designing, or operationalizing a similar arrangement.

1. TREAT PLAN IMPLEMENTATION AS A STRATEGIC, NOT TACTICAL, EXERCISE

One of the most important lessons is to treat an NQDC plan as more than an executive compensation vehicle. In practice, it can become a broader retirement strategy component with meaningful implications for coordination with the qualified plans. Benefits professionals should be engaged early enough in the design process to evaluate how the NQDC design interacts with existing qualified plans, including restoration features and supplemental match formulas, whether discretionary or non-discretionary.

Benefits teams bring an important perspective on plan coordination, compliance, payroll integration, and administration.

Early involvement helps surface design considerations that may otherwise be missed and supports a more integrated approach across the organization’s retirement programs.

2. DON’T RELY SOLELY ON VENDORS AND LEGAL COUNSEL FOR GUIDANCE

Vendors and legal counsel are essential partners, but they do not always fill the role of an independent implementation or strategy consultant. Each advisor often operates within a defined scope, such as legal compliance, recordkeeping, funding strategy, or administration. As a result, no single party may be accountable for connecting the design, sequencing, operational requirements, and stakeholder decisions into one cohesive implementation roadmap.

An experienced independent consultant can help bridge that gap by providing end-to-end guidance, challenging assumptions, aligning stakeholders, and identifying where competing

recommendations may create operational or compliance risk. This role becomes especially important when multiple advisors are involved and guidance is fragmented across workstreams.

Consultants can also provide a critical perspective on how qualified and nonqualified plans work together and whether design changes are needed so the plans collectively support the organization’s broader compensation and retirement objectives.

3. ESTABLISH CLEAR GOVERNANCE AND SEQUENCING EARLY

Proper sequencing of decisions and approvals is critical. For example, board or committee approval may be needed before vendor implementation work begins, and additional approvals may be required as design, funding, documentation, and administrative decisions are finalized. The designation of authority should be mapped early so decision rights are clear and implementation teams are not forced to revisit foundational issues midstream.

Implementation is not limited to plan design. It also includes document drafting, vendor configuration, payroll and data integration, participant communication, and coordination with existing qualified plan documents, which may require amendments. Defining the full scope of work, aligning it to the approval framework, and assigning ownership up front can reduce delays, rework, and governance gaps.

4. ANTICIPATE ADMINISTRATIVE AND COMPLIANCE COMPLEXITIES NQDC plans introduce unique administrative challenges that differ from qualified plans. These include: • Complex deferral and re-deferral rules • Payroll hierarchy decisions • Timing requirements (e.g., elections must be made before compensation is earned) • Differences in payroll timing and plan operations compared to qualified plans Mid-year implementation can also limit the types of compensation that may be deferred, particularly amounts already earned during the year. These nuances should be identified and communicated early so stakeholders understand the practical constraints and participants receive clear, accurate guidance.

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5. BALANCE CONFIDENTIALITY WITH OPERATIONAL NECESSITY

Executive compensation arrangements are highly confidential by nature. At the same time, effective administration requires that the appropriate benefits, payroll, finance, legal, and vendor teams have access to the plan provisions, participant data, and operational rules they need to administer the plan correctly.

A well-defined “need-to-know” framework should protect confidentiality without excluding the functions that are essential to compliance and administration, particularly when other executive compensation arrangements may affect NQDC eligibility, contributions, or distributions.

6. INVEST EARLY IN COMMUNICATION AND EDUCATION

Communication planning should begin earlier than many teams expect. Vendor timelines, review cycles, and the development of meaningful participant education materials can take longer than anticipated, especially when eligible participants are being introduced to an NQDC plan for the first time.

A strong communication strategy can influence participation and improve participant confidence. Effective campaigns often include:

• Clear comparison tools between qualified and non-qualified plans • Access to education consultants and financial advisors • Multi-channel communication campaigns, including email, webinars, and in-person presentations where available These efforts can support stronger initial enrollment and reinforce the value of thoughtful participant engagement, particularly for a plan that may be unfamiliar to even sophisticated executives.

FINAL THOUGHTS

Implementing an NQDC plan is a multidisciplinary effort that requires strategic planning, cross-functional collaboration, and careful execution. For professionals working in this space, the key takeaway is that successful implementation depends as much on governance, sequencing, and operational readiness as it does on plan design. By engaging the right stakeholders early, using the right advisory support, establishing clear decision rights, and investing in both technical understanding and participant education, organizations can avoid common pitfalls and deliver a more effective program.

Nicole Cooper is the Manager, Retirement Plans for Carrix, Inc. and a member of PSCA’s NQDC committee.

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INVESTMENTS

by Eric Dyson, Melanie Lambie, and Matt Novak

Collective Investment Trusts in Retirement Plans PSCA investment committee members share what every retirement plan committee should know about CITs. FOR MANY YEARS, COLLECTIVE INVESTMENT TRUSTS (CITS) WERE VIEWED AS INVESTMENT VEHICLES RESERVED PRIMARILY FOR THE NATION’S LARGEST RETIREMENT PLANS. TODAY, THAT HAS CHANGED DRAMATICALLY. Through advances in recordkeeping technology, institutional pricing, and pooled investment structures, CITs have become increasingly available to retirement plans of all sizes.

As a result, plan fiduciaries are hearing more discussions about replacing traditional mutual funds with CITs. In many cases, those conversations involve investment options that appear virtually identical from a participant’s perspective. The portfolio manager may be the same. The underlying securities may be the same. The investment objective and benchmark may be the same. Yet the investment is offered through a different legal structure, often at a lower cost.

For many committee members, however, Collective Investment Trusts remain unfamiliar territory. What exactly is a CIT? How does it differ from a mutual fund? Why are so many advisors recommending them? And what questions should fiduciaries ask before making a change?

This article provides a practical introduction to CITs and outlines the fiduciary considerations every retirement plan committee should understand.

UNDERSTANDING THE BASICS

A Collective Investment Trust is a pooled investment vehicle maintained by a bank or trust company for qualified retirement plans and certain other eligible institutional investors. Unlike mutual funds, which are regulated under the Investment Company Act of 1940, CITs are generally regulated through banking laws, trust law, and oversight by federal or state banking authorities.

Although the regulatory framework differs, the investment experience often does not.

Today’s marketplace is dominated by daily valued CITs designed specifically for defined contribution retirement plans. Participants typically purchase and redeem units daily, receive daily account values, and experience little or no operational difference compared with owning a mutual fund.

In fact, many participants never realize their plan has replaced a mutual fund with a Collective Investment Trust because their

day-to-day investment experience changes very little. Participants continue to receive daily account values, make transactions through the plan’s recordkeeper, and access investment information using the same retirement plan website they have always used.

One difference is that information about a CIT may not be as readily available on public investment websites as it is for a mutual fund. Instead, participants typically obtain information through their retirement plan’s website, fund fact sheets, or materials provided by the investment manager. Although the source of the information may differ, ERISA’s participant disclosure requirements help ensure plan participants receive meaningful information about their investment options. For most plans and participants, the differences between a mutual fund and a Collective Investment Trust are largely behind the scenes.

It is also important to recognize what a CIT is not. A CIT is not a guaranteed investment product like a traditional guaranteed investment contract (GIC) or a general account guaranteed value product. Most CITs invest in stocks, bonds, or diversified portfolios and fluctuate in value just as comparable mutual funds do. They simply represent a different legal structure for accessing professional investment management.

Another important distinction is that Collective Investment Trusts were designed for institutional retirement plans rather than individual investors. Unlike mutual funds, which are available to the general public and must support millions of individual shareholder accounts of varying sizes, CITs are offered exclusively to qualified retirement plans and certain other eligible institutional investors.

By serving large institutional plans rather than individual retail investors, CITs often benefit from significant economies of scale.

Many of the marketing, distribution, and administrative costs associated with retail mutual funds can therefore be spread across much larger pools of assets, contributing to lower expense ratios for comparable CIT investment strategies.

WHY ARE CITS BECOMING SO POPULAR?

The growth of CITs has been driven by several factors, but one stands above the rest: cost efficiency.

Because CITs generally are not subject to many of the registration, marketing, distribution, and shareholder servicing

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requirements applicable to mutual funds, they can often be offered at lower expense ratios. Those savings may be passed along to retirement plan participants. Importantly, the different legal and regulatory frameworks do not, by themselves, make a CIT a more or less risky investment. The level of investment risk depends on the underlying investment strategy—not on whether it is offered through a mutual fund or a Collective Investment Trust. Likewise, participants generally do not need to monitor a CIT differently than they would a comparable mutual fund.

For fiduciaries, this matters because investment fees remain one of the most closely scrutinized aspects of retirement plan governance. Lower expenses alone do not make one investment superior to another, nor should a committee assume a lower-cost investment involves greater risk simply because it is structured as a CIT. Rather, fiduciaries should evaluate whether a CIT offers an investment strategy, management team, and participant experience comparable to available alternatives while potentially reducing participant costs. When those factors align, lower expenses can improve participant outcomes over time.

Another reason for CIT growth is the increasing availability of institutional pricing. Historically, many institutional investment

strategies were available only to the largest retirement plans with significant assets. Today, advisors, consultants, recordkeepers, and CIT providers frequently aggregate assets across many plans, allowing smaller employers to access pricing that previously would have been reserved for much larger plans.

The result is a marketplace where institutional investment options are no longer limited to Fortune 500 companies.

THE CIT MOST COMMITTEES ENCOUNTER

When many fiduciaries hear the term “Collective Investment Trust,” they imagine an entirely different investment strategy.

In reality, the opposite is often true.

The vast majority of CIT discussions today involve investment strategies that mirror well-known mutual funds. The same investment management firm frequently serves as portfolio manager. The investment objective is the same. The benchmark is the same. The holdings are substantially similar.

The primary differences are the legal wrapper and the fee structure.

For example, a committee currently using a mutual fund may discover that the asset manager offers a CIT version managed by

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the same investment team using essentially the same investment philosophy, but with lower operating expenses.

That does not mean the CIT should automatically replace the mutual fund. Rather, it means fiduciaries have another option worthy of evaluation through a prudent decision-making process.

The committee’s responsibility is not to assume that one structure is better than another, but to determine which option best serves the interests of the plan and its participants.

More sophisticated structures also exist, including custom CITs, multi-manager portfolios, and white-label investment options.

These can provide additional flexibility for large plans but are beyond the scope of this introductory discussion.

For participants, the transition from a mutual fund to a comparable CIT often involves little noticeable change beyond a different investment name appearing on account statements.

IMPORTANT CONSIDERATIONS

Collective Investment Trusts have existed for decades, but for much of their history they were largely confined to very large institutional retirement plans.

High investment minimums, operational complexity, and limited recordkeeper support made CITs impractical for many employers.

Over the past decade, however, the marketplace has evolved considerably.

Recordkeepers expanded their platforms. Trust companies developed broader CIT offerings. Advisors increasingly aggregated assets across multiple plans. Competition among investment providers intensified. As these changes occurred, minimum investment thresholds declined and access expanded.

Today, many retirement plans that would not have qualified for institutional investment pricing only a few years ago may now have access to comparable CIT options.

Although CITs offer many advantages, they also present considerations that committees should understand.

First, transparency can differ. Mutual funds generally publish extensive information through widely available public websites and research platforms. CIT information is more commonly provided through the plan recordkeeper, investment manager, trust company, or fund fact sheets. Some CITs provide information comparable to mutual funds, while others disclose portfolio holdings less frequently. Plan sponsors should therefore understand what information will be available to both the committee and participants before adopting a CIT. Second, benchmarking may require additional effort. Because many retail investment databases focus on mutual funds, committees may rely more heavily on advisors and institutional research resources when evaluating CIT performance.

Third, availability varies by recordkeeper. Some CITs are available only on certain platforms, which can create additional considerations if a plan changes recordkeepers in the future.

Finally, participant communication remains important. Although participants frequently experience little operational difference, unfamiliar terminology can create unnecessary confusion if changes are not explained clearly. Committees should ensure participants understand that a new investment name does not necessarily represent a change in investment philosophy or risk.

ADVANTAGES FOR RETIREMENT PLAN COMMITTEES

CITS AND 403(B) PLANS

A BRIEF LOOK AT HOW WE GOT HERE

For many committees, the most significant potential advantage is lower participant costs.

Even modest reductions in investment expenses can compound over long periods, leaving more assets invested on behalf of participants. While fees should never be evaluated in isolation, they remain an important component of fiduciary oversight.

CITs may also simplify investment lineups. Rather than navigating numerous retail and institutional mutual fund share classes, committees may find CIT pricing structures more straightforward and easier to evaluate.

Equally important, committees should recognize that ERISA does not favor one investment vehicle over another.

ERISA’s fiduciary standard focuses on the prudence of the decision-making process—not whether a committee selected a mutual fund, a CIT, or another appropriate investment vehicle.

The relevant question is whether fiduciaries gathered appropriate information, evaluated reasonable alternatives, considered participant interests, and documented a thoughtful process.

Historically, CIT adoption within many 403(b) plans lagged behind the defined contribution marketplace because of statutory and operational limitations.

Recent legislative developments, including provisions contained in SECURE 2.0, have expanded opportunities for broader CIT use in certain 403(b) arrangements. However, implementation continues to evolve as recordkeepers, custodians, regulators, and service providers address operational considerations.

Sponsors of 403(b) plans should monitor these developments closely, as additional CIT opportunities are expected to become available over time.

QUESTIONS EVERY COMMITTEE SHOULD ASK

Whether a committee ultimately adopts a CIT is less important than ensuring the decision results from a thoughtful fiduciary process.

Before evaluating any specific Collective Investment Trust, committee members should develop a practical understanding of

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35 FALL 2026

THE GOAL IS NOT TO BECOME EXPERTS IN THE LEGAL OR REGULATORY FRAMEWORK, BUT TO UNDERSTAND ENOUGH TO ASK INFORMED QUESTIONS, EVALUATE THE RECOMMENDATIONS OF THEIR INVESTMENT ADVISOR, AND MAKE A PRUDENT FIDUCIARY DECISION ON BEHALF OF PLAN PARTICIPANTS. how CITs differ from mutual funds and why they are increasingly being offered in retirement plans. The goal is not to become experts in the legal or regulatory framework, but to understand enough to ask informed questions, evaluate the recommendations of their investment advisor, and make a prudent fiduciary decision on behalf of plan participants.

Committee members are not expected to be experts in every aspect of investment management or retirement plan regulation.

When evaluating Collective Investment Trusts—or any significant investment decision—committees should seek guidance from qualified fiduciary professionals when additional expertise is needed. A knowledgeable ERISA Section 3(21) investment advisor can help educate the committee, evaluate available alternatives, and support a prudent decision-making process, while an ERISA Section 3(38) investment manager may assume discretionary responsibility for investment selection and monitoring when appropriate.

As part of their ongoing investment review, committees should consider asking: • Does a comparable CIT exist for any of our current mutual funds?

• If so, how similar are the investment strategy, portfolio management team, objectives, and benchmark?

• What differences exist in fees, operational features, transparency, and reporting?

• Are there any recordkeeping or portability limitations?

• What due diligence has our investment advisor performed?

• How would participants experience the transition, and what participant communication strategy should the committee adopt?

• How should the committee document its evaluation and decision?

These questions help shift the discussion away from product labels and toward participant outcomes, which is precisely where fiduciary attention belongs.

at competitive costs while providing participants with an experience that may be nearly indistinguishable from traditional mutual funds.

That does not mean every mutual fund should be replaced with a CIT. Nor does it mean lower fees alone justify making a change.

Rather, CITs represent another investment structure that deserves careful consideration within a prudent fiduciary process. By understanding how these vehicles work, asking informed questions, seeking qualified advice when appropriate, and documenting a disciplined decision-making process, retirement plan committees can confidently evaluate whether a Collective Investment Trust is the right choice for their plan and participants.

FINAL THOUGHTS

Eric Dyson is the Executive Director of 90 North Consulting.

Melanie Lambie is a Senior Human Resources Generalist for Vizo Financial Corporate CU and chair of PSCA’s Investment committee.

Matt Novak is the associate Director of Defined Contribution for Marquette Associates, Inc.

Collective Investment Trusts have evolved from niche institutional products into mainstream retirement plan investment vehicles. For many plans, they offer access to institutional investment management

ADDITIONAL RESOURCES

Retirement plan fiduciaries who would like to continue learning about Collective Investment Trusts may find the following resources especially valuable. These organizations have published educational materials that explain how CITs work, their role in defined contribution plans, and the considerations fiduciaries should evaluate.

Great Gray Trust Company One of the nation’s largest independent providers of Collective Investment Trusts, Great Gray offers a robust library of educational content designed specifically for plan sponsors, advisors, and fiduciaries.

Recommended reading: Why Collective Investment Trusts? (CIT 101 Resource Center) Morningstar Morningstar has published several excellent educational articles explaining why CITs have grown so rapidly and how they compare with traditional mutual funds.

Recommended reading: Don’t Know About CITs? You Probably Should Another excellent background article: Collective Investment Trusts: The Invisible Giant

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36 FALL 2026

FINANCIAL WELLNESS

by Jennifer Benford Seibert

A Beneficiary Designation Wellness Check Making beneficiary designations part of your organization’s financial wellness program can help ensure participants keep them up-to-date, especially after big life events.

Employees commonly overlook beneficiary updates after major life events such as marriage, divorce, birth or adoption of a child, death of a family member, or a change in household circumstances.

Others assume their estate plan automatically covers their 401(k) or other workplace retirement accounts.

Beneficiary designations determine who receives retirement plan assets after a participant’s death. They may also control the outcome even when an employee’s will or other estate planning documents say something different. That makes outdated or missing beneficiary information more than an administrative detail; it can lead to delays, family disputes, unintended recipients, and difficult claims decisions for the plan sponsor.

Turn strategies into action!

Your role in 3 easy steps

Plan sponsors can: 1. Integrate beneficiary education into moments when employees are already thinking about benefits: new-hire onboarding, annual enrollment, retirement readiness campaigns, lifeevent communications, and year-end financial checkups.

Messaging should be simple and action-oriented: confirm that a beneficiary is on file, review whether the named beneficiary still reflects current wishes, and update the designation when life changes occur.

2. Work with recordkeepers, advisors, and benefits partners to send reminders in participant portals, targeted emails to employees with no beneficiary on file, annual “beneficiary checkup” campaigns, and clear instructions in plan materials. If paper forms are still used, review them

Pavel L Photo and Vide / Shutterstock.com

FINANCIAL WELLNESS PROGRAMS OFTEN FOCUS ON BUDGETING, DEBT MANAGEMENT, EMERGENCY SAVINGS, RETIREMENT READINESS, AND INVESTMENT EDUCATION. Yet one simple step can have an outsized impact on employees’ financial lives: keeping beneficiary designations current. For retirement plan sponsors and employers, making beneficiary reviews part of financial wellness is a practical way to help employees protect the savings they have worked hard to build.

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EMPLOYEES COMMONLY OVERLOOK BENEFICIARY UPDATES AFTER MAJOR LIFE EVENTS SUCH AS MARRIAGE, DIVORCE, BIRTH OR ADOPTION OF A CHILD, DEATH OF A FAMILY MEMBER, OR A CHANGE IN HOUSEHOLD CIRCUMSTANCES.

for basic completeness, including legibility, identifying information, and allocation percentages that total 100%.

3. Remind participants that beneficiary designations determine who receives retirement plan assets after a participant’s death. A simple beneficiary designation or review can avoid • delays, family disputes, • unintended recipients, and • difficult claims decisions for the plan sponsor.

Framing beneficiary designations as part of financial wellness also supports a broader culture of preparedness. Employees may not see estate planning as relevant or urgent, but they often respond to practical prompts that connect benefits decisions to family protection.

A beneficiary review takes only a few minutes, but it can help ensure retirement assets transfer according to the participant’s wishes.

Jennifer Benford Seibert is a Senior Outreach Coordinator for Regional Government Service JPA.

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HSA

by Hattie Greenan

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More Employees are Saving in Their HSA PSCA’s annual survey of health savings account shows increased utilization by employees and an opportunity for employers to help employees see HSAs as a part of a long term savings strategy.

PSCA’S EIGHTH ANNUAL HSA SURVEY, SPONSORED BY HSA BANK, WAS CONDUCTED IN THE SPRING OF 2026 AND RECEIVED RESPONSES FROM 726 U.S. EMPLOYERS THAT SPONSOR A HEALTH SAVINGS ACCOUNT PROGRAM FOR EMPLOYEES. The results show an increase in participation year-over-year with balances reaching nearly $6,500 on average. At the same time, employers are expanding support through contributions, automatic enrollment, investment options, and decision-support tools.

HSA ACCOUNTS OVER TIME 2021

2022

2023

2024

2025

Average Participant Contribution

$2,483

$2,323

$2,609

$2,802

$2,829

Average Account Balance

$4,924

$6,130

$6,165

$6,489

$6,477

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Although HSAs are functionally evolving from a healthcare spending vehicle into a long-term savings vehicle, many employees don’t yet see them that way. There remains an opportunity for employers to help participants better understand the unique role HSAs can play in preparing for healthcare expenses in retirement.

The survey found that only one-quarter of employers position HSAs as part of a retirement savings strategy,

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EMPLOYEES ARE INCREASINGLY CONTRIBUTING TO HSAS, BUT MANY VIEW THEM AS SPENDING ACCOUNTS FOR NEAR-TERM EXPENSES RATHER THAN AS TOOLS THAT CAN HELP PREPARE THEM FOR RETIREMENT. ONE ITEM THAT CAN HELP WITH THIS REFRAMING IS OFFERING INVESTMENT OPTIONS TO PROMOTE LONG TERM GROWTH OF ASSETS. which has been relatively consistent over time. Nearly two-thirds (65.5 percent) of employers cite employee education as the most common HSA concern while half provide HSA education only during open enrollment.

Employees are increasingly contributing to HSAs, but many view them as spending accounts for near-term expenses rather than as tools that can help prepare them for retirement.

One item that can help with this reframing is offering investment options to promote long term growth of assets. More than two-thirds of employers (68.5 percent) now allow employees to invest their HSA accounts, and nearly a quarter of participants (22 percent) are doing so.

Notable survey findings include: • Increased Participation: Eighty-three percent of employees with an HSA contributed to their account in 2025, up from 73.4 percent in 2024. Average participant contributions reached $2,829 in 2025.

• Account Balances: The average account balance at the end of 2025 was $6,477.

• Employer Contributions: More than three-quarters (77.2 percent) of employers surveyed contribute to employee HSAs. Among employers that contribute, 61.3 percent provide a set contribution based on coverage level, up from 54.9 percent in the prior year.

• Investments: Nearly 70 percent of organizations offer investment options for HSA contributions. The percentage of participants investing increased from 20 percent in 2024 and 18 percent in 2023 to 22 percent in 2025, accounting

for 27.5 percent of all HSA assets.

• Automatic Enrollment: Nearly 46 percent of all organizations surveyed automatically enroll employees in an HSA when they enroll in an HSA-qualified health plan, up from 43.1 percent in 2024 and up from 35.1 percent five years ago.

• HSA Rewards: Thirtyfive percent of organizations reward employees for health and wellness program participation, up from 32.0 percent the year before.

REFRAMING HSAS

commonly found in retirement plan design such as automatic enrollment, investment options, and matching contributions.

Though the use of a matching formula is still low, coupling that with automatic enrollment, and investment options can help reframe HSAs as long term savings accounts to pay for healthcare expenses in retirement. Including HSA education as part of a financial wellness program can also go a long way to helping employees see the value of savings in an HSA as part of a long term strategy.

Hattie Greenan is the Director of Research and Communications for PSCA.

We have seen an increase in recent years of features

ORGANIZATIONS THAT OFFER INVESTMENT OPTIONS AND PARTICIPANTS WHO USE THEM OVER TIME 2022

2023

2024

2025

Percentage of Organizations Offer Investments

60%

65%

66.8%

68.5%

Participants Who Invested Assets

18.7%

18.9%

20.3%

22.3%

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by Nevin Adams

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RETIREMENT READ(Y)

20 Years Later, Did the PPA Really Change Everything?

Yes…and No. TWENTY YEARS AGO, I AUTHORED A COVER STORY ABOUT THE THEN-NEWLY ENACTED PENSION PROTECTION ACT OF 2006 WITH AN AMBITIOUS HEADLINE: “The Pension Protection Act: This Changes Everything.”

Twenty years later, it seems like a reasonable time to ask:

DID IT?

The short answer, I think, is yes – though probably not quite in the ways we expected in 2006.

The PPA was a sweeping piece of bipartisan legislation, addressing among other things, defined benefit funding,

pension accounting, and cash balance plans — it was titled the PENSION Protection Act, after all. And it was, for the benefits promised by those plans, an important defensive measure.

However, to my eyes then — and now — the most lasting influence of the PPA was on the defined contribution side, where it helped change not just plan design, but the industry’s thinking about participant behavior.

TO APPRECIATE 2006, GO BACK TO 1986

Twenty years earlier, the Tax Reform Act of 1986 had significantly tightened contribution and nondiscrimination rules for defined contribution plans — some may remember things like a $7,000 cap on pre-tax savings, among other limits designed to “pay for” tax reductions elsewhere. Some will surely also remember that the 401(k) of the 1980s and 1990s was largely a participant-directed proposition. Employees were

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expected to enroll themselves (on paper), decide how much to contribute, pick investments, and — in theory, anyway — periodically revisit those decisions.

The industry’s response was largely to give participants more information and more choices. Unfortunately, participants didn’t always make good choices — or make any choices at all.

By 2006, the industry was increasingly recognizing that asking people to take responsibility for their retirement savings

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THE BIGGER CHANGE WAS PHILOSOPHICAL. THE PPA GAVE US A PLAN DESIGN TEMPLATE ARCHITECTED TO LEVERAGE PARTICIPANT BEHAVIOR TOWARDS BETTER OUTCOMES. NOT SO MUCH AN “IF YOU BUILD IT, THEY WILL COME” PRESUMPTION, AS A “LET US DO IT FOR YOU” ACKNOWLEDGEMENT. decisions didn’t necessarily mean they would do so effectively. Procrastination, inertia, inadequate savings rates, overly conservative investments, and poorly diversified portfolios were not simply educational problems.

They were behavioral ones.

THE PPA CHANGED THE QUESTION

Of course, the PPA didn’t invent automatic enrollment, target-date funds, or professional investment management. What it did was provide a framework that made it much easier — and arguably “safer” — for employers and fiduciaries to embrace them.

Let me start by reminding us of an unappreciated aspect of the PPA. It made permanent significant retirement enhancements we now take for granted. In 2001, the Economic Growth and Tax Relief Reconciliation Act (EGTRRA) had restored some of what the 1986 act took away — but it not only raised contribution and compensation limits, it created age-50 catch-up contributions, expanded portability, created the Saver’s Credit, and authorized Roth contributions in 401(k) and 403(b) plans. But those

provisions were scheduled to “sunset” after 2010. The PPA made those retirement provisions permanent.

But it didn’t stop there.

Automatic enrollment received important protections in the PPA — and more importantly, a safe harbor design template.

Automatic escalation became a practical plan design feature. And Qualified Default Investment Alternatives (QDIAs) gave fiduciaries a framework for defaulting participants into diversified investment strategies, rather than the stable value or money market “vaults” that had long been chosen to preserve, rather than grow accounts.

The bigger change was philosophical. The PPA gave us a plan design template architected to leverage participant behavior towards better outcomes. Not so much an “if you build it, they will come” presumption, as a “let us do it for you” acknowledgement.

AND THE NUMBERS MOVED

Twenty years later, the evidence of that shift is hard to miss.

Automatic enrollment is now commonplace — and nearly ubiquitous among large employer plans, while

participation rates have reached historically high levels. Automatic escalation has helped push those default savings rates higher, with industry data now regularly showing average participant savings rates around 12% when employee and employer contributions are combined.

Target-date funds provide perhaps the clearest illustration of the change. In 2006, they were still a developing concept.

Today, they are a central part of the defined contribution investment landscape and the default investment for millions of participants. Participants, it’s worth noting, who would otherwise have been left to their own devises in choosing — and maintaining — those portfolios.

SO, DID IT CHANGE EVERYTHING?

Not quite.

It didn’t solve all of America’s retirement savings issues. Coverage gaps remain.

Too many participants still save too little. Turning retirement savings into reliable retirement income remains a challenge.

But 20 years ago, the conversation was more likely to focus on whether a plan offered a broad investment menu and provided participants with enough

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information to make good decisions — assuming they would — and could.

Today, we ask not only whether workers are participating, but at what level, whether the default investment is appropriate, whether the plan’s design encourages better behavior, and increasingly, whether accumulated savings will actually translate into sustainable retirement income.

That’s a very different conversation.

LOOKING BACK—AND AHEAD

Ok, so the PPA didn’t change everything. But it helped change something fundamental: the assumption that retirement security should depend primarily on participants making a long series of good decisions…on their own.

In that sense, the PPA didn’t merely change retirement plans in 2006. It established a direction — and provided a foundation — that plan design has followed for the last 20 years — and that SECURE 2.0 is still following today.

Nevin E. Adams, JD is the former Chief Content Officer for the American Retirement Association.

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PLAN SPOSNOR PERSPECTIVES

FALL 2026

by Hattie Greenan

Roth’s Impact Plan sponsors share their experience offering Roth to employees and their implementation of the new Roth treatment of catchup contributions.

FOR THIS ISSUE’S PLAN SPONSOR PERSPECTIVES, AS A COMPANION TO THE COVER STORY ON ROTH, WE ASKED PLAN SPONSORS HOW THE IMPLEMENTATION OF ROTH TREATMENT OF CATCHUPS WENT, IF THEY HAVE HAD ANY ISSUE WITH CORRECTIONS, AND IF THEY FEEL THEIR PARTICIPANTS UNDERSTAND ROTH. Most respondents now have the Roth treatment of catchups working properly, but many had some implementation issues in the beginning with classifying contributions correctly. Some members feel like employees have a good grasp of Roth, while others feel like employees do not fully understand it. This is going to vary widely based on employee base and industry. Comments follow.

Mid-Size Financial Services Company With much preparation, we did not have many issues at all with the new Roth treatment of Catchups. We sent an email to all associates who were impacted by the change asking them to make a new Roth election. We had already eliminated their pretax contributions elections.

We then checked everyone who received the email to see if they made the new elections and if they did not, another

contact was made. Yes, our participants understand Roth and many choose Roth as their preferred contribution.

Mid-Size Real Estate Company We did not have any issues with the new Roth Catch Up requirements. Our Payroll company created a report to help identify the employees affected by this requirement.

We communicated to them and most opted to add Roth to their regular contributions.

For those who chose not to, the payroll company automatically changes it from traditional to Roth when they reach the threshold. I have been tracking it manually as well, just to be sure that the automatic change was happening when needed, and it did. So I think I will be comfortable enough in 2027 to eliminate the additional manual tracking. We have not had to make any corrections yet and hope to continue with the same level of accuracy.

We do offer annual learning opportunities with our 401(k) advisors who talk about the difference between traditional and Roth. We also include it in our newsletter at least annually. Additionally, our 401(k) recordkeeper offers educational webinars throughout the year. So generally speaking, I believe our participants understand Roth, and we do have quite a few who choose Roth for a portion or all of their contributions.

I believe Roth is an important option to offer, which allows participants some flexibility when they retire. Personally, I put half into traditional and half into Roth so I can enjoy reducing my taxable income now, while also giving my future self the option to take some non-taxable distributions.

Non-Profit Healthcare System We’ve offered the Roth since 2020. The programming of the mandatory Roth in Workday was challenging but was eventually resolved.

Although we offered much education and notification, some employees are still surprised when the Roth shows on their paystub. There are an increasing number of

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employees who are choosing the Roth voluntarily based on their particular situation. We continue to educate so they can make informed decisions.

Mid-Size Insurance Company Our DC Plan has Roth, PreTax and After-tax contribution options. Participants like having Roth, many use the in-plan Roth conversion available. The treatment of Catchups was difficult, having three HRIS to setup in, ADP, Paylocity and Workday. Initially it was not working correctly in Workday and we had to catch up in February for the highincome earners.

The onus is on participants to shut off their deferral election if they do not want to contribute to Roth CU, which a few have missed communications on, and we continue to communicate out to the masses. I see younger generations making higher Roth contributions, while older generations stay with Pre-tax, although there are many who do a combination.

Large Food Retail Company Roth treatment of catch up deferrals has gone okay to date. With a solid start we

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PLAN SPOSNOR PERSPECTIVES

I SEE YOUNGER GENERATIONS MAKING HIGHER ROTH CONTRIBUTIONS, WHILE OLDER GENERATIONS STAY WITH PRE-TAX, ALTHOUGH THERE ARE MANY WHO DO A COMBINATION.

moved well through the first half of the year with no issues.

However, in July we found that those who hit the 402(g) limit were not going in the catch-up bucket. After researching we realized we didn’t have catch-up buckets set up to send to the recordkeeper on the payroll files...this was the

result of only needing two buckets (pre-tax and Roth) for the other company. As the recordkeeper acquired the other, they stated we didn’t make any changes to the payroll file layout. So, we worked internally to set up the two catch-up buckets and tested, and now every bucket

is flowing correctly. We’re now reclassifying those who had incorrect deferrals in the regular buckets, and the recordkeeper is moving these to the catch-up buckets as expected.

We believe our participants only partially understand Roth contributions in their 401(k),

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though many identify Roth as an IRA only. We’ve hosted financial wellness sessions to explain, and those who have attended now better understand, but there are still many who do not.

Hattie Greenan is PSCA’s Director of Research and Communications.

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WASHINGTON WATCH

FALL 2026

by Josh Oppenheimer

Building SECURE 3.0’s Foundation, No Matter Who Wins in November Why ARA has spent 2026 pairing Republicans and Democrats on every major retirement bill AS I WRITE THIS, BOTH POLITICAL PARTIES ARE DEEP INTO THE FINAL SPRINT TOWARD THE NOVEMBER 3 MIDTERM ELECTIONS, and Washington is doing what Washington does best in an election year: holding its breath. Committee calendars are lighter, leadership is more cautious, and nearly every vote is viewed through the lens of the midterms.

The stakes for control of Congress are real. Republicans currently hold the House by a narrow 218213 margin, and the Senate 53-47, but neither majority is safe. Political pundits rate roughly a quarter of House seats as genuinely competitive, and most forecasting models now show Democrats favored to retake the House, while the Senate remains close enough that either party could end up in control.

Whatever happens on Election Day, the Congress that returns in January will look at least somewhat different from the one in place today: new committee chairs, a different freshman class, and possibly a change in which party holds the gavel in one or both chambers.

For an industry that has spent the better part of two years building toward the next comprehensive retirement package – what we have taken to calling SECURE 3.0 – that kind of uncertainty could easily be cause for concern. Instead, your ARA Government Affairs team has treated it as a planning problem with a clear answer: make sure that as many of our priority bills as possible already have real, working bipartisan, bicameral support before a single vote is cast in November.

A DELIBERATE BLUEPRINT, NOT AN ACCIDENT

Look closely at the retirement bills ARA has helped shepherd onto Capitol Hill this year, and a pattern emerges. None of them have a lead sponsor from only one party, and almost none exist in only one chamber.

The Retirement Investment in Small Employers (RISE) Act, which would expand the small-employer startup tax credit and allow the service provider to claim the credit on behalf of the employer, was reintroduced in May with House leads spanning both parties and both coasts – Claudia Tenney (R-N.Y.), Brad Schneider (D-Ill.), Linda Sánchez (D-Calif.), and Adrian Smith (R-Neb.) – alongside Senate leads Maggie Hassan (D-N.H.) and Ted Budd (R-N.C.).

The Charity Parity Act, which would let savers make qualified charitable distributions directly from 401(k)s and 403(b)s the way they already can from IRAs, carries House leads Mike Kelly (R-Pa.) and Don Beyer (D-Va.), with a four-member Senate team split evenly between the parties.

The Small Nonprofit Retirement Security Act, extending start-up and auto-enrollment credits to tax-exempt employers, pairs Vern Buchanan (R-Fla.) and Jimmy Panetta (D-Calif.) in the House with Catherine Cortez Masto (D-Nev.) and James Lankford (R-Okla.) in the Senate.

The Retirement Rollover Flexibility Act, permitting Roth IRA assets to roll into workplace plans, has already cleared its second introduction with Darin LaHood (R-Ill.) and Linda Sánchez (D-Calif.) in the House and John Barrasso (R-Wyo.) and Michael Bennet (D-Colo.) in the Senate.

And the Form 5500 Filing Simplification Act – a more technical fix that nonetheless matters enormously to plan sponsors – cleared the House Education and Workforce Committee in May on a bipartisan vote led by Glenn Grothman (R-Wis.) and Donald Norcross (D-N.J.). It has subsequently

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been introduced in the Senate

by Jim Banks (R-Ind.) and Cory Booker (D-N.J.).

None of that is accidental.

It reflects a conscious choice

by ARA to insist on bipartisan, bicameral partnership as the price of admission for a bill to be a top priority. It is slower, and it means some good ideas move at a more deliberate pace than they otherwise might. But it also means that regardless of which party ends up chairing Ways and Means, Education and Workforce, Finance, or HELP next year, the building blocks for SECURE 3.0 will already have supporters in place on both sides of the aisle.

INSURANCE AGAINST A CHANGE IN CONTROL

Think of it as an insurance policy. If Republicans hold both chambers, these bills already have Republican leads ready to press forward. If Democrats retake the House, the Senate, or both, the same bills already have Democratic leads with equal ownership and equal incentive to keep moving them. Either way, nobody has to start from scratch rebuilding a coalition in a new Congress, and nobody can credibly dismiss these ideas as

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FALL 2026

belonging to the other party.

That matters because both prior comprehensive retirement packages – the original SECURE Act in 2019 and SECURE 2.0 in 2022 – took years of quiet, staff-level relationship building before they came together into single bills. We don’t have the luxury of waiting to start that process until we know who has the gavel. Some of our sponsors will not be back next year regardless of the election outcome – Rep. Buchanan, for example, is retiring – which is exactly why we are already working to add Rep. Blake Moore (R-Utah) as a future lead on the Small Nonprofit Retirement Security Act. Succession planning is part of the job now, not an afterthought.

It is also worth being candid about what a change in control would and would

not mean for retirement policy specifically. A Democratic House would likely put the Ways and Means gavel in the hands of Richard Neal (D-Mass.), a longtime retirement champion who helped author both the original SECURE Act and SECURE 2.0 – a frankly favorable development for this agenda, and a reminder of how much continuity exists on these issues regardless of which party is in charge.

Even so, it would not change the underlying math: any retirement package still needs 60 votes in the Senate and a signature from a Republican president, which means it still has to be truly bipartisan to move at all. A Republican Congress, for its part, would still need Democratic votes in the Senate for the same reason. In an unusually polarized Washington, retirement policy remains one of the few areas where that math consistently works in both directions – which is precisely why it is worth the extra effort to build it that way from the start.

WHAT PLANS SPONSORS AND ADVISORS SHOULD WATCH FOR

Expect the pace of new bill introductions to slow through the fall as Members of Congress focus on their campaigns, then pick back up quickly after November 3, regardless of outcome. The lame-duck session and the opening months of the new Congress will be an important window – not necessarily for passing SECURE 3.0 itself, but for reintroducing and building cosponsor lists on the bills described above, so they are positioned to be rolled into a larger package when the opportunity arises.

For plan sponsors and advisors, the message is the same one we have carried through each edition of Washington Watch this year: engagement matters more, not less, in a Congress that could look meaningfully different come January. Members who hear directly from the professionals who help their constituents save for retirement are more likely to sign on as cosponsors and more likely to keep these bills moving after the election, whichever party they represent.

We built this year’s advocacy strategy on the assumption that we would not know the outcome of the midterms until it was too late to react to it. That is exactly why the strategy does not depend on knowing it. ARA will keep working both sides of the aisle and both chambers so that whenever the window for SECURE 3.0 opens, the groundwork is already in place.

Josh Oppenheimer is the American Retirement Association’s Senior Director of Federal Legislative Affairs.

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