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A S P P A

PLANCONSULTANT WINTER 2027

The TPA of

Tomorrow

STARTS

TODAY The next decade won’t wait. TPAs need to invest in the talent, processes, and technology that will keep them competitive— and make sure they’re pricing their expertise for the value it delivers.

BEYOND PSYCHOLOGICAL SAFETY: NEW PERSPECTIVE ON LEADERSHIP IN PLAN OPERATIONS THE CYCLE 4 BUSINESS GROWTH OPPORTUNITY MAXIMUM LUMP SUMS AT PLAN TERMINATION: A DC VS. DB COMPARISON

Ready for what’s next? PROTECT YOUR LEGACY. SUPPORT YOUR CLIENTS. EXPAND WHAT’S POSSIBLE. For today’s retirement plan professionals, standing still isn’t an option. For TPA owners considering a transition, partnering with Definiti can mean preserving the relationships you’ve built while gaining access to the expertise, technology and operational resources needed for the next chapter.

LET’S TALK ABOUT WHAT’S NEXT AT ASPPA ANNUAL. Scan to learn how to connect.

01|PLANCONSULTANT WINTER2027

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INSIDETHISISSUE

24 COVERSTORY

24|THE TPA OF THE FUTURE: PREPARING FOR THE NEXT DECADE

They need to price their expertise appropriately by investing today in the people, processes, and systems now to help them adapt. By Theresa Conti

FEATURES 30| CYCLE 4 IS YOUR GROWTH OPPORTUNITY All your staff members are in sales because each one helps clients experience your value. Cycle 4 gives you a wonderful opportunity to make that value visible. By Rebecca Hourihan

34| THE RISK, RECOVERY, AND REWARD Beyond Psychological Safety: A New Perspective on Leadership in Retirement Plan Operations By Jennifer Manatt

02|PLANCONSULTANT WINTER2027

ASPPA IN ACTION 08|FROM THE PRESIDENT

So Much to Celebrate, So Many People to Thank By Shannon Edwards

11|NEWLY AND RECENTLY CREDENTIALED MEMBERS 56|INSIDE ASPPA

We’ll See You in San Antonio! By Plan Consultant Staff

COLUMNS 06|LETTER FROM THE EDITOR

AI, Retirement, and the Question of Trust By John Sullivan

10|REGULATORY / LEGISLATIVE UPDATE

401(k) Tax Benefits Work for the Working Class

40|RECORDKEEPING

TECHNICAL ARTICLES

From Operational Error to Opportunity

12|ACTUARIAL / DB

42|STATE-RUN PLANS

Maximum Lump Sums at Plan Termination: A DC vs. DB Comparison By Huihui Jiang

16|AUTO IRAS

Taking the Temperature of the Big Three State Auto IRAs By John Iekel

19|BUSINESS PRACTICES

By Scott Pounds

Partnering for ‘Retirement Dignity’: Common Cause for a Growing State Network By John Iekel

46|LITIGATION UPDATE

Benchmarks, Standing, and the Difference a Few Facts Can Make By Nevin E. Adams, JD, and Bonnie Treichel, JD

22|COMPLIANCE & ADMINISTRATION

When Business Ownership Changes, Retirement Plan Rules Can Too By Shannon Edwards

Meet Your (Saver’s) Match By Kevin Gaston

58|SUCCESS STORIES

Strategies for Successful Remote Onboarding and Team Building By Jenn Taylor

PRACTICE MANAGEMENT ARTICLES 52|TECHNOLOGY

Is Your TPA Firm Built for What Comes Next? By Lisa Kottler

Client Feedback: How to Adjust Your Practice By Jessica Maxwell

50|LEGISLATIVE ISSUES

QR Code to Digital Version* Use your phone to link directly to the Online Version!

54|WORKING WITH PLAN SPONSORS

When Institutional Knowledge Walks Out the Door By Patrick J. Griffin

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By Brian H. Graff

Virtual • May 12-13, 2027

SAVE THE DATE

04|CONTRIBUTORS WINTER2027

Plan Consultant is Published by

EDITOR IN CHIEF

CONTI

JIANG

EDWARDS

KOTTLER

GRIFFIN

MANATT

HOURIHAN

MAXWELL

IEKEL

TAYLOR

Brian H. Graff, Esq., APM

PLAN CONSULTANT COMMITTEE

Mary Patch, QKA, CPFA, Co-chair; David J. Witz, Co-chair; Lee Bachu; Gary D. Blachman; Katie Boyer-Maloy; Jason D. Brown; Linda Chadbourne, QKA; Theresa Conti; Megan Crawford; Shannon Edwards, ERPA; John A. Feldt, CPC, QPA; Amy Garman; Emily Halbach; Tiffany Hanks; John Iekel; Travis Jack; Chad Johansen; Olivia Schwartz; Kerry Smith; Rickie Taylor; Colleen Windham; Manny Marques; Heidi Salati

EDITOR

Theresa Conti, QKA, APR, ERPA, CBFA is

a Retirement Industry Consultant, Author, Speaker/Coach for Women in Financial Services, and Executive Director of The Cerrado Group. She has been involved in the retirement plan industry for more than 35 years, she started her firm Sunwest Pensions in 1998 and sold it to July Business Services in 2023.

Shannon M. Edwards, ERPA, QPA, QKC, QKA, is the President of TriStar Pension Consulting. She is a member of the ASPPA Leadership Council and the Plan Consultant Committee.

Patrick Griffin, CPA, is a Partner at Caron

Bletzer, PLLC, with more than 15 years of experience specializing in employee benefit plan audits and ERISA compliance. He also leads the development of Atlura, the firm’s practice management platform, helping firms improve audit efficiency, workflow automation, client readiness, and resource planning.

Rebecca Hourihan is the Chief Marketing Officer with 401(k) Marketing. The firm believes in helping successful retirement plan advisors grow their business through an intelligent marketing strategy. It partners with retirement plan advisor offices to develop a customized showflow that will connect them with more plan sponsors and bring target market awareness of what they do and why they are passionate about the retirement plan space.

John Iekel is a writer and editor with the

American Society of Pension Professionals and Actuaries (ASPPA), a division of the American Retirement Association. .

Huihui Jiang, FSA, EA, FCA, is Chief Actuary,

COO and President of ERISA Pension Systems and has more than 18 years of experience in retirement plan consulting and administration. She advises business owners and retirement plan professionals on defined benefit, cash balance and qualified retirement plans, with a focus on complex funding, compliance and operational issues.

Lisa Kottler is founder and principal of Kottler

Advisory Group, a consultancy focused on the retirement industry. Named one of 401kWire’s 100 Most Influential People in Defined Contribution three years running, she is a former senior executive at NFP, where she led a major technology acquisition and cross-selling initiative.

Jennifer Manatt is the founder of NeuroHaven

Coaching & Consulting LLC, where she works with professionals, managers, and executives using a unique neuroscience-informed coaching approach that integrates executive coaching strategies with the Regenerating Images in Memory (RIM®) process. She developed the Leadership Recovery & Empowerment framework, which explores how chronic workplace stress and psychological safety influence leadership effectiveness, decisionmaking, professional growth, and organizational return on investment.

Jessica Maxwell, QPA, QKC, QKA is the Vice

President of Client Services at July Business Services. With more than 20 years in the retirement plan industry, she is passionate about building strong relationships, developing highperforming teams and creating exceptional client experiences.

Jenn Taylor, QKA, QKC, TGPC, is a Senior

Account Manager at Corebridge Financial. She also serves on the ARA Women In Retirement Third Thursday and ASPPA Focus Committees.

John Sullivan jsullivan@usaretirement.org

SENIOR WRITERS

Ted Godbout, John Iekel

ADVERTISING SALES

Tashawna Rodwell trodwell@usaretirement.org

TECHNICAL REVIEW BOARD

Rose Bethel-Chacko, CPC, QPA, QKA; Marianna Christofil; Michael CohenGreenberg ; Sheri Fitts; Drew Forgrave, MSPA; Grant Halvorsen, CPC, QPA, QKA; Jennifer Lancelot, CPC, QPA, QKA; Robert Richter, APM

COVER

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2026 ASPPA OFFICERS PRESIDENT

Shannon M. Edwards, ERPA, QPA, QKC, QKA

PRESIDENT-ELECT

Manny Marques, CPC. QPA, QPFC, AIF®

VICE PRESIDENT

Genelle Brakefield, QKA, TGPC

IMMEDIATE PAST PRESIDENT

JJ McKinney IV, CPC, QPA, QKA Plan Consultant is published quarterly by the American Society of Pension Professionals & Actuaries, 4401 N. Fairfax Dr., Ste 600, Arlington, VA 22203. For subscription information, advertising, and customer service contact ASPPA at the address above or 800.308.6714, customerservice@USAretirement.org. Copyright 2026. All rights reserved. This magazine may not be reproduced in whole or in part without written permission of the publisher. Opinions expressed in signed articles are those of the authors and do not necessarily reflect the official policy of ASPPA.

Learn More

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06|EDITOR’SLETTER WINTER2027

AI, RETIREMENT, AND THE QUESTION OF TRUST From cars to electricity, to mobile phones and now AI, (most) people initially reject innovation. Here’s what it means for retirement saving. By John Sullivan

Is it rent-seeking, regulatory capture, or legitimate risk?

Politico recently reported that top AI CEOs are reacting to public fears of a Skynet-style apocalyptic hellscape if innovation proceeds unchecked. When someone as brilliant as the late Stephen Hawking warns that artificial intelligence could eventually destroy humanity, people take notice. Their proposed “solution,” of course, is to self-regulate, an oxymoron if there ever was one (with deference to FINRA). Skeptics rightly note the power and privilege that AI companies currently enjoy and see self-regulation not only as a way to ensure light-handed oversight but also as a scheme to cement favorable terms and a competitive advantage. They’re not wrong. Conversely, The Wall Street Journal’s Andy Kessler argued that AI opposition and calls for strict regulation are little more than a return to the Luddites and their visceral reaction to innovation. Vandalized Waymo cars and destroyed autonomous food-delivery devices bear a depressing resemblance to smashed stocking frames centuries earlier. Put simply, (most) people — at least initially — reject innovation. Cars were evil, electricity sorcery; even indoor plumbing faced stiff resistance.

SO, HOW DOES THIS TRANSLATE TO THEIR VIEWS OF RETIREMENT AND AI? Seamlessly, as two reports in August illustrate. The first, from the National Institute on Retirement Security, a major pension proponent, found that although AI use is “widespread,” Americans are not using it for financial decisions. Nearly two-thirds have used an AI tool, but 61% have not used AI to answer questions about their finances, investments, or retirement, it noted. Nearly half are uncomfortable with AI playing a role in delivering financial advice, and there are “significant generational differences,” with younger Americans, unsurprisingly, more comfortable than older generations. “Despite their caution, Americans see potential uses for AI in personal finance,” it further noted. “Americans express interest in using AI for budgeting, investing, retirement planning, paying down debt, and tax planning, suggesting consumers may be more comfortable using AI as a financial resource than relying on it for financial advice.” However, a second report from WTW found that while employees might be wary, employers are more open. Its 2026 Defined Contribution Survey found nearly four in five employers are willing to use AI for plan analytics, 73% to automate routine processes, and 72% to personalize employee communications. However, “willingness wanes as stakes rise,” meaning only 37% would use it for compliance and risk management, 33% for recordkeeper oversight, and 29% for fiduciary governance, with data privacy and security the most common reservation at 74%. “Employers are most comfortable using AI where it can make retirement programs more responsive, efficient, and insight-driven,” said Chris West, WTW’s Senior Managing Director and Defined Contribution Strategy Leader. “The opportunity is to use these tools to better engage participants, streamline administration, and help sponsors understand where plan design, investment strategy, and participant support can have the greatest impact.” Interesting stuff — not only for what it reveals about retirement planning, but also about participant behavior overall — and it will only get more so from here. PC

John Sullivan Editor-in-Chief

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08|PRESIDENT’SLETTER WINTER2027

SO MUCH TO CELEBRATE, SO MANY PEOPLE TO THANK Thank you for allowing me to serve as your president. My year in this role may be ending, but I’m not going anywhere. By Shannon Edwards

I have absolutely loved being your ASPPA president. I am sad to

see this year come to an end, but I have so much to be grateful for. Serving an organization that has given me so much has been an incredible honor, and I have a lot of people to thank. First, I want to thank my husband, Corey, and my children. You have supported me all these years as I built TriStar and volunteered for ASPPA, from committee work to the Leadership Council and, finally, as president. Thank you for understanding how much my career and this organization mean to me and for supporting the time they require. I could not have done this without your love and encouragement. One of this year’s greatest gifts has been working so closely with the ARA staff. They are amazing. Our volunteers give generously of their time, knowledge, and passion, and the ARA team supports that work while keeping the organization running. The effort it takes to support our leadership and volunteer committees and accomplish everything else on the agenda is tremendous. I could not have asked for a better team. Brian Graff, our chief executive officer, has been the backbone of this organization and an amazing advocate for our members and the retirement industry. Working alongside him and learning from him has been a privilege. Brian, thank you for your leadership, your mentorship, and for putting together a team that takes such good care of this organization and its members. I also owe a huge thank you to my team at TriStar, especially my practice manager, Allyson Rentsch, and my Director of Plan Administration, Henna Patel. Allyson and Henna manage our entire team, and together with our amazing team members, they have held down the fort and kept the work moving forward while I shared my time with ASPPA this year. Knowing TriStar was in such good hands allowed me to give this role the time and attention it deserved. Thank you all for supporting me and making it possible for me to serve an organization I love so much. Just look at what that work made possible this year. We launched the Qualified Pooled Plan Professional (QP3) credential, introduced a more user-friendly online ERISA Outline Book, and released Ask ERISA, an AI tool built on the EOB that could save our members hours when researching complex retirement plan questions. Meanwhile, we moved our entire database to a new technology platform without disrupting service to members. Anyone who has been through a technology conversion knows that is no small accomplishment! We also introduced the first-ever ASPPA Accolade, recognizing the record-keeping wholesalers and TPA relationship managers who are truly dedicated to supporting and growing the unbundled TPA service model.

We also established the first Women’s Retirement Security Day. Seeing our members share resources on social media and help carry that message far beyond our own industry made me so proud. You helped bring important conversations about women’s financial futures to people we might not otherwise have reached. Please keep having those conversations. By the time you read this, the ARA will have celebrated TPA Day by recognizing the value that ASPPA members bring to the retirement plan services community. We will also have celebrated ASPPA’s 60th birthday in grand style in San Antonio and welcomed our first group of NextGen Conference Scholarship attendees at ASPPA Annual. Our generous sponsors made that scholarship opportunity possible: FinServ Foundation, The Cerrado Group, Pentegra, Metz CPA, Inspira Financial, and Vestwell. Thank you for helping new people experience this organization and begin building their own connections here.

09|PRESIDENT’SLETTER WINTER2027

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“OUR VOLUNTEERS GIVE GENEROUSLY OF THEIR TIME, KNOWLEDGE, AND PASSION, AND THE ARA TEAM SUPPORTS THAT WORK WHILE KEEPING THE ORGANIZATION RUNNING. THE EFFORT IT TAKES TO SUPPORT OUR LEADERSHIP AND VOLUNTEER COMMITTEES AND ACCOMPLISH EVERYTHING ELSE ON THE AGENDA IS TREMENDOUS. I COULD NOT HAVE ASKED FOR A BETTER TEAM.” I know how much that first opportunity can mean, and I especially want to thank two people for the opportunities they gave me. Lynn Young, thank you for taking me under your wing, mentoring me, and talking me into my first volunteer position. You started something! That experience sparked the love and passion I have for ASPPA today and began the journey that brought me to this role. Robert Richter, thank you for your friendship and for the years you have spent educating me and so many others in our industry. Thank you, too, for believing in me and nominating me to serve on the ARA Board many years ago. That

experience taught me so much about the larger organization and all of our sister organizations. I became passionate about finding ways for us to work better together, support one another, and help each of our sister organizations accomplish its goals. I carried that knowledge and passion into my work on the ASPPA Leadership Council, and it has continued to shape how I serve. I hope each of us will take a moment to encourage someone else to get involved. A little encouragement can lead to something pretty special. Lynn and Robert certainly did that for me. And please keep showing up! Don’t forget to register for ASPPA’s Winter Symposium and ARA RISE: The Women in Retirement Leadership Forum. I look forward to continuing to learn, volunteer, and spend time with so many of you. As I turn the reins over to next year’s president, Manny Marques, I know ASPPA is in wonderful hands. With Manny, our leadership team, and the ARA team Brian has assembled, there is so much to look forward to. I will be cheering them on and helping wherever I can. Thank you for allowing me to serve as your president. My year in this role may be ending, but I’m not going anywhere. There is still plenty of work to do, and I’m grateful I get to keep doing it with you. PC

10|REGULATORYLEGISLATIVEUPDATE WINTER2027

401(K) TAX BENEFITS WORK FOR THE WORKING CLASS The data clearly shows that working-class Americans benefit most from the tax-advantaged status of their employer-sponsored defined contribution plans. By Brian H. Graff

I want to call attention to an incorrect talking point often deployed in the consumer press by defined-contribution critics: that the benefits workplace plans provide favor the wealthy.

It’s simply incorrect, and as a new report from the American Retirement Association proves, the assertion overlooks critical components of the system: employer contributions and the compounding benefits of tax-deferred investment growth. When you factor these in, the data tell a different story: working-class Americans are the primary beneficiaries of retirement tax incentives. The report’s key findings are crucial to preserving the savings incentives inherent in 401(k) and similarly styled employer-based plans and the future of the country’s private retirement system as a whole, including: Working-class savers receive the most significant benefits relative to their tax burden. Moderate-income earners ($50,000–$100,000 annual AGI) pay only 9.1% of federal income taxes but receive 30.1% of retirement tax benefits. Low-income workers receive nearly eight times more in tax benefits compared to their tax burden. High-income earners receive proportionally less in tax benefits despite paying more in taxes. High-income earners (over $200,000 annual AGI) pay 71.4% of all federal income taxes but receive just 16.7% of retirement tax benefits. Tax benefits are concentrated among working-class households. Americans earning under $100,000 annually receive nearly 53% of all tax advantages from defined contribution plans. Moderate-income earners ($50,000–$100,000 annual AGI) account for the single largest share of the tax benefits. Working-class Americans have the highest retirement account ownership. Over 60% of defined contribution accounts are held by people who make under $100,000 annually. Only 11% are held by those making over $200,000 annually. Modest earners turn tax advantages into real wealth-building opportunities. Nurses, restaurant managers, technicians, and other working-class savers use tax incentives and employer matches to build meaningful retirement wealth. The results of this comprehensive study underscore the need for retirement policy analysis to move beyond surface-level metrics. When employer contributions and long-term tax deferral are properly included, the data make clear that defined contribution plans are one of the most effective, progressive, and pro-worker wealth-building tools in the United States. These findings have important implications for policy development. As policymakers consider proposals related to the tax treatment of defined contribution plans, our analysis conclusively demonstrates that the assertion that defined contribution plans primarily benefit the wealthy is false. The data clearly shows that working-class Americans benefit most from the tax-advantaged status of their 401(k) plans and other employer-sponsored defined contribution plans.

Brian H. Graff, Esq., APM, is the Executive Director of ASPPA and the CEO of the American Retirement Association.

Legislation that impacts the employer-sponsored defined contribution model should protect and preserve a framework that demonstrably benefits workingclass savers. Any reforms should be carefully evaluated to ensure they maintain or enhance the current incentives to provide access to retirement savings programs. The evidence presented in the paper should give policymakers confidence that the current system of retirement tax incentives represents sound progressive tax policy. These incentives not only encourage responsible long-term financial behavior but also provide proportionally greater assistance to those with greater need. As we look toward the continuing evolution of retirement policy, maintaining and building upon this progressive framework should remain a central priority. We encourage you to read more about the findings here. PC

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12|ACTUARIAL / DB WINTER2027

MAXIMUM LUMP SUMS AT PLAN TERMINATION: A DC VS. DB COMPARISON I often explain the difference between defined contribution and defined benefit limits to clients this way: a DC plan has an annual contribution

limit, but it does not have a lifetime account balance limit. A DB plan is different. Section 415 ultimately limits the benefit that can be paid. That difference is easy to miss in a cash balance plan because the participant sees an account style benefit. But when a mature DB or cash balance plan approaches termination, the distinction becomes very practical. An owner may assume that waiting longer always means a larger lump sum. Under Section 415, that is not necessarily true. Even for a participant with maximum compensation and at least 10 years of participation and service, the maximum permissible DB lump sum can rise to a peak and then decline. Two Different Section 415 Limits For a DC plan, Section 415(c) generally limits annual additions for 2026 to the lesser of $72,000 or 100% of the participant’s compensation, before permitted catch-up contributions. The important point is that Section 415(c)

limits annual additions, not the ultimate size of the account. Contributions made within the annual limits remain in the account and participate in investment gains and losses. Investment earnings are not annual additions merely because they increase the account value. Over time, a DC account can therefore grow well beyond any single year’s Section 415(c) limit. Section 415 does not impose a separate lifetime ceiling on the accumulated account balance. A DB plan starts from a different place. Section 415(b) limits the benefit. For 2026, the Section 415(b)(1)(A) dollar limit is $290,000. The participant is also subject to the compensation limit under Section 415(b)(1)(B), generally 100% of the participant’s average of highest three consecutive years’ compensation. The lower applicable amount establishes the maximum annual straight life annuity, after taking into account any required adjustments. Age matters. The Section 415(b)(1)(A) dollar limit is adjusted for commencement before age 62 and after age 65

AI Generator / Shutterstock.com

When an owner is approaching retirement or a possible plan termination, I like to look beyond the next minimum and maximum contribution calculation. By Huihui Jiang

13|ACTUARIAL / DB WINTER2027

under Treas. Reg. Section 1.415(b)-1(d) and (e). Years of participation and service can matter as well: fewer than 10 years of participation can reduce the dollar limit, while fewer than 10 years of service can reduce the compensation limit. From the Annual Limit to the Lump Sum Once the maximum annual straight life annuity is determined, a lump sum must also satisfy the optional form rules in Treas. Reg. Section 1.415(b)-1(c)(3). • The plan’s actuarial equivalence basis. • 5.5% interest and the applicable mortality table. • The applicable Section 417(e) interest rate and mortality table, including the 1.05 adjustment prescribed by the regulation. When solving for the maximum permissible lump sum, the practical equivalent is to calculate the lump sum supported under each basis and use the lowest of the three amounts. For the illustration below, the 5.5%/applicable mortality basis is assumed to be the controlling lump sum limit after comparison with the other two bases. The applicable mortality assumption is the 2026 Section 417(e) modified unisex mortality table published in Notice 2025-40. A 2026 Age Only Illustration To isolate the effect of age, the following illustration holds the 2026 statutory limits and actuarial assumptions constant at each age. It is not a projection of one participant over future calendar years; actual future limits and Section 417(e) assumptions will change and must be recalculated at the time of distribution. Assume the participant has at least 10 years of participation and service and compensation sufficient to reach the maximum applicable compensation limit. Using 2026 limits, the comparison is shown in Table 1 (at right): At age 62, the participant is limited by the $290,000 Section 415(b)(1)(A) dollar limit. After age 65, the dollar limit is actuarially increased under the regulation. In this example, that allows the maximum annual benefit to increase until the compensation limitation becomes the limiting factor. At age 68, the maximum annual straight life annuity has reached approximately $351,667, and the maximum permissible lump sum is approximately $3.93 million. That happens to be the peak in this illustration. At age 73, the maximum annual benefit is still approximately $351,667. The compensation limitation is already the limiting factor, so additional age does not increase the annual benefit. The lump sum value of that same annual benefit, however, is lower at the older age. The illustrated maximum falls to approximately $3.38 million - about $555,000, or 14%, below the age 68 amount. The peak will not always occur at age 68. It depends on compensation, age, years of participation and service, plan provisions, statutory limits and applicable actuarial assumptions. The important point is that there can be a peak at all. Once the compensation limitation becomes the limiting factor, additional age can reduce the maximum permissible lump sum.

Age

Maximum Annual Straight Life Annuity

Illustrated Maximum Section 415 Lump Sum

$290,000

$3,720,000

$290,000

$3,645,000

$290,000

$3,570,000

$290,000

$3,490,000

$312,086

$3,670,000

$336,242

$3,855,000

$351,667

$3,930,000

$351,667

$3,825,000

$351,667

$3,715,000

$351,667

$3,605,000

$351,667

$3,490,000

$351,667

$3,375,000

$351,667

$3,255,000

$351,667

$3,140,000

Illustration note: For the age-adjusted annual benefit limit after age 65, the illustration uses the statutory 5% interest assumption and the 2026 applicable mortality table under Treas. Reg. §1.415(b)-1(e), and assumes that the required comparison with the plan’s post-age-65 actuarial factors does not produce a lower limit. For the separate lump-sum adjustment under Treas. Reg. §1.415(b)-1(c)(3), the 5.5% interest assumption and applicable mortality table are assumed to produce the controlling limit after comparison with the plan’s actuarial-equivalence basis and the applicable Section 417(e) basis. Actual results depend on the plan provisions and assumptions applicable at distribution.

COMPARE THAT WITH THE DC ACCOUNT

The contrast with a DC account makes the point easier to see. Suppose, solely for illustration, a DC account starts with the same $3.72 million balance at age 62. If the account earns 5% annually and receives a $72,000 year-end annual addition each year, holding the 2026 Section 415(c) dollar limit constant, the account would grow to approximately $5.48 million at age 68 and $7.39 million at age 73.

14|ACTUARIAL / DB WINTER2027

Figure 1. Illustrative comparison only. DC account assumes a $3.72 million starting balance at age 62, 5% annual return and $72,000 year end annual additions. The 2026 Section 415(c) dollar limit and the DB 2026 statutory/actuarial assumptions are held constant solely to show the different structure of the limits.

That is not an investment projection, and actual future contribution limits and returns will differ. It simply illustrates the different structure of the two limits. The DC account continues to reflect contributions and market experience. There is no Section 415 lifetime account balance ceiling that reduces the existing balance as the participant ages. A cash balance plan may look like a DC plan on a participant statement, but it is still a defined benefit plan. The hypothetical account is a way of expressing the promised benefit. At distribution, the benefit remains subject to the DB Section 415 limits. That distinction is especially important near plan termination.

FUNDING CAPACITY IS NOT BENEFIT CAPACITY

Another place I see confusion is when a sponsor reviews an actuarial valuation and sees a substantial maximum deductible contribution. The natural question is: if the company can make another large deductible contribution, why wouldn’t that increase the owner’s eventual lump sum? Near the Section 415 maximum, those concepts can separate. A plan may still have funding or deduction capacity while the owner has little or no additional benefit capacity under Section 415. Additional contributions may improve the plan’s funded position without producing an equal increase in the maximum benefit payable to that participant. For a mature DB or cash balance plan, several numbers therefore need to be kept separate: the cash balance hypothetical account, the accrued benefit, plan assets, the minimum and maximum contribution range, and the participant’s maximum permissible Section 415 benefit. They are related, but they are not interchangeable.

If the plan is approaching termination, this is where the actuary, TPA and advisor should coordinate before the final contribution and termination date are set.

LOOK BEYOND THE NEXT CONTRIBUTION

When an owner is approaching retirement or a possible plan termination, I like to look beyond the next minimum and maximum contribution calculation. A few additional questions can be more important: • Which Section 415 limit is expected to control at the distribution age? • Has the participant reached the point where the maximum permissible lump sum may begin to decline? • How does the expected termination date interact with the plan’s funded position and asset level? • If the owner still wants to make substantial retirement contributions, should the DB or cash balance arrangement continue, be frozen or terminate while the DC plan continues? The answers depend on the facts, and the maximum lump sum should always be recalculated using the limits and actuarial assumptions applicable at the actual distribution date. But the broader planning point is simple. With a DC plan, Section 415 principally limits what can be added each year, while the accumulated account continues to reflect actual investment experience. With a DB plan, Section 415 ultimately limits the benefit that can be paid. For a plan approaching termination, “How much can we contribute?” may therefore be only half of the conversation. The other half is: How much can ultimately be paid, and when? PC

October 18-21, 2026

San Antonio, TX

16|AUTO IRAS WINTER2027

TAKING THE TEMPERATURE OF THE BIG THREE STATE AUTO IRAS It reveals more than just their performance; it predicts how their younger counterparts in other states may do when they’ve been around for a while, too. By John Iekel

The big three state auto IRAs run by California, Oregon, and Illinois are a bellwether. They’re the first state-run auto IRAs

launched and the largest (so far, anyway). They’re laboratories, in a way — they’re breaking ground concerning what a program looks like, what happens when the procedures and regulations governing them are put in place and into operation, how employers and employees respond, how the funds accumulate, how well they fulfill the reasons they were created in the first place. So, taking their temperature reveals more than just how they’re doing; it suggests how their younger counterparts in other states may do when they’ve been around a while, too. And THAT offers a look at how well the reason they all exist — namely, retirement plan coverage for people who otherwise may not have it — is being achieved. So how are the Big Three doing? Let’s start with the first half of 2026.

STEADY AMID TUMULT

The first half of 2026 was a rollercoaster in some ways — market fluctuations, floods in some places, and parching drought in others. But the oldest and biggest state autoIRAs stood in marked contrast to that instability. CalSavers, My Illinois Savings, and OregonSaves continued to grow resolutely and consistently through the first half of 2026. By June 30, all three had more assets, more employers registered, more funded accounts, and more payrollcontributing accounts. The only differences among CalSavers, My Illinois Savings, and OregonSaves were how much each grew. Dollars and cents. During the period that began with the Rose Parade in Pasadena and ended less than a week before the nation celebrated its 250th birthday, all three grew at a healthy clip. In the Land of Lincoln, My Illinois Savings assets grew 12%; in dollar terms, that was just over $39 million, resulting in a June 30 balance of 360,351,505.

In the Evergreen State, OregonSaves’ assets grew by 11% from Jan. 1 to May 31; by that date it had $510,548,521 in the bank. CalSavers, the Golden State’s program, grew even more robustly. Assets were 14% higher by the end of the first half of the year; that translated to an additional $233 million and then some, for a total of $1,876,883,894 on June 30. Employers registered. All three programs registered more employers in the first half of 2026. OregonSaves and CalSavers each grew by 3%; by May 31, Oregon’s program had 34,713 and California’s numbered 282,254. The Prairie State was fertile ground for program growth, and it was especially robust. On Jan. 1, My Illinois Savings had 25,825 employers enrolled; on June 30, 27,555. That’s 1,730 more, growth of 7%. Funded accounts. All three counted more funded accounts by the end of the period than they did on New Year’s; however, the growth rate was not uniform. The number of funded accounts in My Illinois Savings grew by 1% in the first half of 2026. There were 167,391 on Jan. 1 and 170,054 on June 30, an increase of 2,263. OregonSaves had a higher growth rate, 3%. CalSavers outperformed both of them. On Jan. 1, it had 605,211 funded accounts; by June 30, it had 652,929. That’s 47,718 more, an 8% increase. Payroll contributing accounts. As with funded accounts, so too are accounts to which contributions from employees’ payroll are added — My Illinois Savings’ growth was the most modest. At the offices in Springfield, the Illinois government counted 3% more payroll contributing accounts in My Illinois Savings; on Jan. 1 there were 195,430 and on June 30, 200,849 — a difference of 5,419. The Salem offices showed stronger growth for OregonSaves. On Jan. 1, there were 192,874 payroll-contributing accounts, and on May 31, there were 201,822. So OregonSaves had an additional 8,948 accounts, a growth of 5%. Officials in Sacramento reported an even higher growth rate for CalSavers’ payroll-contributing accounts. On Jan. 1,

17|AUTO IRAS WINTER2027

there were 721,900; on June 30, 778,179. That’s 56,279 more, an 8% growth rate.

Adam DR / Shutterstock.com

IN THE GOOD OL’ SUMMERTIME

The uniformity that marked the growth of the big three state auto IRAs in the first half of the year did not fully hold in summer. Some of those measures had fits and starts in early summer; however, by late summer the positive trajectory was stronger. Assets. As spring melted into summer, the ledgers of all three — My Illinois Savings, OregonSaves, and CalSavers — showed strong growth from Memorial Day to the end of June. To wit: Illinois’ program assets grew by just under $1 million from May 31 to June 30; OregonSaves’ assets jumped by $ 4,407,914; and from the end of May to the end of June, CalSavers’ assets grew by a noteworthy $19,236,950.

But in July, the mercury may have soared, yet growth in those state auto-IRAs’ assets cooled. From the end of June to the end of July, CalSavers’ assets grew by $8,590,424, more than $10 million less than it had from May to June. OregonSaves grew too, but its growth was only one-quarter of May to June; in July, its assets increased by just under $1 million, $939,567. But the program serving the Land of Lincoln cooled so much that from June 30 to July 31, My Illinois Savings lost revenue and had $243,014 less in assets than it had just before the fireworks lit the sky for America’s 250th. Then the thermometer rose again in August, and asset growth was explosive. My Illinois Savings went from losing money in July to gaining $11,874,650 in assets—stronger growth than it had from May 31 to June 30. CalSavers went from a June growth rate much lower than May’s to exploding by $65,094,523 in August.

18|AUTO IRAS WINTER2027

Program

June 30 Balance

July 31 Balance

August 31 Balance

My Illinois Savings

$360,351,505

$360,108,491

$371,983,141

OregonSaves

$514,956,435

$515,896,002

N/A

CalSavers

$1,876,883,894

$1,885,374,318

$1,950,268,841

These rates of growth are translated to these balances: Employers’ registrations. Employer registrations for the big three were more indeterminate throughout the summer than their asset figures. My Illinois Savings was all over the map. By June 30, it had 106 fewer employers registered than at the end of May. It reversed course and grew by 216 by July 31, but growth slowed in August; it added 112 employers, for a total of 27,883 employers registered as kids headed back to school. OregonSaves and CalSavers had a more positive trajectory. OregonSaves had 320 more employer registrations on June 30 than on May 31, and another 1,103 by the end of July, for a total of 36,136. Like its Illinois counterpart, CalSavers lost employer registrants in June, with 827 fewer than it had on May 31. It lost 57 more in July, but August was different: Things more than turned around, and 379 more employers registered, bringing the total to 282,576 by month’s end. A caveat: A drop in employer registrations may, on its face, look like bad news and auger less coverage for those who need it. It may mean that an employer closed its doors. Still, it also could mean (1) that an employer merged with another employer that has a plan or (2) that an employer has begun offering a plan of its own and no longer needs to participate in the state program for its employees to have retirement plan coverage. Funded accounts. The number of funded accounts in each program showed rather anemic growth early in the summer, but it accelerated as the season wore on. The number of funded accounts in My Illinois Savings fell; by June 30, there were 1,740 fewer than at the end of May. By July 31, there were 739 more, and growth was almost 10 times as strong in August — there were 7,054 more by August 31, for a total of 177,847. The number of funded accounts in OregonSaves and CalSavers did not shrink in June — quite the opposite. OregonSaves added 2,805 funded accounts in June, and CalSavers added 8,170 by June 30. In July, both grew at only one-quarter of June’s pace: OregonSaves added 789

funded accounts, and CalSavers added 2,452. Growth accelerated in August for CalSavers; by August 31, it had 7,380 more funded accounts, for a total of 662,734. Payroll contributing accounts. As with program assets and funded accounts, growth in payroll contributing accounts was weaker early in the summer and stronger as the calendar moved closer to Labor Day — at least for OregonSaves and CalSavers. In Oregon, the number of payroll contributing accounts grew by 3,155 in June; the pace slackened in July to 2,801. Similarly, CalSavers added 9,092 more by June 30, but the number of payroll-contributing accounts grew by fewer in July — 8,802. The pace of growth was even slower for the Golden State’s program in August, with 7,992 new payroll-contributing accounts by Aug. 31. Still, by the end of summer its total number of payroll-contributing accounts stood at almost 800,000. CalSavers and OregonSaves may have had consistently shrinking growth rates in the number of payroll contributing accounts, but not so for My Illinois Savings. In June, the Prairie State’s program had 672 new ones, and it added 918 in July. Growth accelerated further in August: 6,951 more payroll-contributing accounts were added, bringing the total to 208,718.

THE BIG PICTURE

The big three state auto IRAs have matured sufficiently that they have moved beyond the initial onrush of registrations, number of accounts, and assets that necessarily take place with the sudden infusion of new participating employers and employees as they race to meet registration deadlines. CalSavers, My Illinois Savings, and OregonSaves therefore show what a more mature state-run program looks like and suggest to those running and participating in newer programs what they may expect further down the road. The results for California, Oregon, and Illinois also show that state auto IRAs have a staying power that is affected by the vagaries of external factors but not endangered by them. And ultimately, that’s good news for the real people they exist to serve. PC

19|BUSINESSPRACTICES WINTER2027

CLIENT FEEDBACK: HOW TO ADJUST YOUR PRACTICE Your clients are already telling you how to improve your organization. Are you listening? By Shannon Edwards

Bangkok Click Studio / Shutterstock.com

Feedback is happening every day, whether you have a formal process to collect it or not. It comes through conversations,

emails, service calls, client meetings, complaints, compliments, advisory councils, and referrals. For organizations that use client experience surveys, those responses provide another valuable source of insight. However you receive it, clients are telling you what it is like to work with your organization. They

show you where you make their lives easier, where you create unnecessary friction, what they value, and where their expectations are changing. I am passionate about building strong relationships and creating great client experiences because I have seen the impact both can have. Client feedback allows us to understand those relationships from the client’s perspective. It can validate what is working, challenge our assumptions, and identify

opportunities to improve. Collecting feedback is only the beginning. What we do with it determines its value. Listen. Understand. Respond. Adjust. Measure.

LISTEN BEYOND THE SURVEY

A client experience survey can effectively gather consistent feedback across a broad client base, identify trends over time, and uncover issues clients have not raised directly.

20|BUSINESSPRACTICES WINTER2027

Surveys, however, are only one way to listen. Consider what your organization hears every day. What questions are clients repeatedly asking? What generates complaints or escalations? What do clients praise? Which processes cause confusion? Why do clients leave? Just as importantly, why do they stay and refer others? The real insight often comes when we stop looking at those interactions individually and start connecting them. One team member hears the same concern several times. Another regularly receives questions about a confusing process. A relationship manager notices clients increasingly want more proactive guidance. Together, those observations may reveal an important trend. For organizations that use surveys, combining those results with what your teams hear directly from clients provides a more complete picture of the experience you are creating. The first step is not necessarily launching a survey. It is making sure you are listening to the feedback already around you.

MAKE SURE THE FEEDBACK IS USEFUL

If you formally ask clients for feedback, be intentional about what you want to learn. A high Net Promoter Score may feel reassuring, but it does not necessarily tell you what is driving the experience or what you could do differently. Focus on feedback that can inform how you operate, including responsiveness, communication, proactive guidance, ease of doing business, technical expertise, or issue resolution. A simple question can keep you focused: If we receive this information, how could we use it? Open-ended feedback is especially

valuable. Survey scores can reveal a trend, while client comments often reveal what is behind it. The goal is not more data. It is better insight that helps you make more informed decisions about the client experience.

UNDERSTAND BEFORE YOU ADJUST

Feedback can tell you something needs attention without necessarily telling you what needs to change. One negative comment may reflect an isolated experience. The same concern expressed repeatedly may point to something larger. The client who takes the time to tell you something may also not be the only one experiencing it. They may be the one willing to say it. Look for patterns, then ask why. A responsiveness concern may be related to capacity. A communication issue may stem from unclear ownership. Repeated questions may indicate that instructions are too technical. Frustration with a process may point to unnecessary steps, a technology limitation, or a handoff creating friction. It can be tempting to react to a comment before fully understanding what caused it. Feedback often points us in the right direction, but it does not always give us the answer. We still have to understand what is happening behind it before deciding what to change.

RESPOND WHILE IT STILL MATTERS

Some feedback requires further review. Other feedback calls for a timely response. Consider which types warrant client outreach, who is best positioned to make that connection, and how quickly it should happen. I learned this through experience. When we began formally

surveying clients, we sent surveys, compiled responses, calculated our Net Promoter Score, and shared the results company-wide. We collected valuable information, but we hadn’t built a scalable process for what came next. We didn’t have a consistent way to review feedback, decide which responses needed followup, recognize positive comments, identify trends, assign ownership for improvements, or measure whether our changes worked. We had the Listen part. We were missing much of the Understand, Respond, Adjust, and Measure that makes feedback valuable. That experience changed how I viewed client feedback. Collecting it was not the finish line. It was the starting point. When clients take the time to tell us about their experience, we need to be prepared to show them that we were listening.

LEARN FROM WHAT IS GOING RIGHT

When we talk about client feedback, our attention naturally goes to the negative. What went wrong? Who is unhappy? What needs to be fixed? Those questions matter, but we cannot overlook what our biggest advocates are telling us we are doing right. When a client recognizes a team member by name, praises a department, or acknowledges a process improvement, celebrate it. Individual praise can be powerful when shared publicly and privately. It recognizes high-performing team members while providing real examples of behaviors that create exceptional client experiences. Those examples can become best practices and challenge others to strive for that same level of excellence.

21|BUSINESSPRACTICES WINTER2027

“NEARLY TEN YEARS OF WORKING WITH CLIENT FEEDBACK HAS REINFORCED FOR ME THAT THE GREATEST VALUE COMES FROM BEING INTENTIONAL ABOUT WHAT WE DO WITH WHAT WE LEARN.”

Positive feedback may also recognize a department or a process your team has worked hard to improve. Those wins deserve recognition too. Positive feedback is more than a compliment. It is insight into what your clients value most. We should learn just as intentionally from what clients tell us we are doing right as we do from what needs to improve.

ADJUST HOW YOU OPERATE

Once you understand what clients are telling you, ask: What could we do differently because of what we learned? The answer doesn’t always require new technology, a major initiative, or a complete process redesign. If clients struggle to navigate your portal, short training webinars may help. If they struggle to understand reports, consider an educational session or reference guide. If the same questions repeatedly reach your service teams, proactive communication may answer them before clients need to ask. Do not overlook simple solutions while searching for complex ones. One of our most valuable examples did not come from a survey. Our Client Advisory Council gave us candid feedback about the tone of some of our client emails. From our perspective, the communications explained important deadlines and the consequences of missing

them. We work in an industry filled with regulatory requirements, and accuracy matters. Our clients experienced those communications differently. They told us some of the language felt harsh and even threatening. Industry terminology and warnings about missed deadlines were overshadowing the message we were trying to communicate. That feedback prompted us to review our client communications and make them clearer, warmer, and more client-friendly without sacrificing the important information clients need. The lesson went beyond the emails: Intent and experience are not always the same. We knew what we intended to communicate, and technically, the information was accurate. Our clients helped us see that accuracy alone didn’t make it great client communication.

MEASURE THE IMPACT

After adjusting, go back to the feedback that prompted it and ask: Did it make a difference? Measuring impact does not necessarily mean sending another survey. Are fewer clients asking the same question? Have complaints or escalations decreased? Are relationship managers hearing something different? Has a process become easier to navigate? The measure should fit the adjustment.

If it worked, reinforce it and build on it. If it did not, keep listening.

TURN LISTENING INTO ACTION

Nearly ten years of working with client feedback has reinforced for me that the greatest value comes from being intentional about what we do with what we learn. That means having a process to understand the feedback, determine what needs attention, respond when appropriate, recognize what is working, make meaningful adjustments, and measure whether those changes made a difference. It has also reinforced something I have always believed: strong client relationships do not happen by accident. When clients take the time to share feedback, especially constructive feedback, we have an opportunity to understand their experience better, strengthen the relationship, and make changes that matter. Sometimes that means thanking a client for recognizing a team member who made a difference. Other times, it means thanking a client whose constructive feedback led to meaningful change. Both are opportunities to show clients that what they share matters. The value of client feedback is not in collecting it. It is in listening to understand, responding with intention, making meaningful adjustments, and measuring whether we made a difference. Listen. Understand. Respond. Adjust. Measure. PC

22|COMPLIANCE&ADMINISTRATION WINTER2027

WHEN BUSINESS OWNERSHIP CHANGES, RETIREMENT PLAN RULES CAN TOO The key is making sure someone asks the retirement plan questions early enough that there is still time to act on the answers. By Shannon Edwards

Business sales can move fast.

Attorneys are working on documents. CPAs are reviewing numbers. Everyone is focused on the closing date. Sometimes the retirement plan doesn’t come up until it’s too late. That can create a real problem, especially when the plan is part of a multiple employer plan (MEP), pooled employer plan (PEP), controlled group, or affiliated service group. I recently worked through a situation that perfectly illustrates how quickly this can get complicated. For many years, a father and his adult son owned two companies with identical ownership. Because the ownership was the same, the companies were part of a controlled group and were treated as one employer for retirement plan purposes. Both companies participated in the same 401(k) plan. Then the ownership changed. Eventually, the two companies were no longer part of the same controlled group. They were now unrelated employers, but both were still participating in the same retirement plan. That meant something very important had changed. What had historically been a single-employer plan was now a multiple-employer plan. Nothing about the plan’s day-to-day operation necessarily looked different. The same participants were there. Contributions were still being deposited. The same trust was holding the assets. However, from a retirement plan standpoint, the structure had changed. Then the father decided to sell his company in a stock sale to a completely unrelated buyer. This is where timing became extremely important. In a stock sale, the company itself does not go away. The ownership of the company changes. So if the buyer does not want to take over the existing 401(k) plan, the retirement plan must be dealt with before the sale closes. A buyer may not want to inherit the seller’s plan for many reasons. The buyer may already have a retirement plan. They may not want to maintain two plans. Or they may be uncomfortable taking responsibility for a plan they did not administer and whose compliance history they do not know. Whatever the reason, if the buyer does not want the plan, that decision cannot wait until after closing. Once the sale is

complete, the buyer has inherited the company, and with it, the company’s retirement plan obligations. If the buyer already sponsors another defined contribution plan, terminating the acquired plan after closing may not result in a distributable event because of the successor plan rules. Many of us still think of this as the “same desk” issue. The employees are still sitting at the same desk, doing the same jobs. The ownership changed, but their employment did not necessarily end. That is why the order of events matters so much. In my client’s situation, another complication arose. The company being sold was not sitting in its own standalone plan. It was participating in a MEP. That meant we could not simply terminate that employer’s portion of the plan. The MEP itself was not terminating. Only one participating employer wanted out. Therefore, we first had to spin out the portion of the plan attributable to that employer and place it into its own single-employer plan. Then the new standalone plan could be terminated before the stock sale was completed. That sounds simple enough when you say it quickly. It is not. You must prepare documents. Assets must be identified and transferred, which generally means you have to work within the record keeper’s schedule. Participant records and service histories must follow the plan. Providers must coordinate. Depending on the transaction, there can also be notice and filing requirements. All of that takes time. The problem is that business transactions don’t always leave much time. Sometimes we find out there is a closing date only a few weeks or even sometimes a few days away, and suddenly everyone is trying to accomplish several months’ worth of retirement plan work in a very small window. Another issue comes up when an employer leaves a MEP or PEP that is easy to overlook or generally misunderstood. That is the recognition of service. While employers participate in a MEP or PEP, they must recognize service performed

23|COMPLIANCE&ADMINISTRATION

Sophon Nawit / Shutterstock.com

WINTER2027

by employees who work for any of the other participating employers. This is true even if they leave the MEP or PEP. They must continue to recognize that service for any employee who worked for a participating employer while that employer was participating in the MEP or PEP. The employer and the plan providers need to ensure the required prior service is preserved and tracked. That can become a real recordkeeping challenge. It is also one more reason a buyer may prefer to have the seller’s plan terminated before closing rather than inherit an ongoing plan with years of history inside a MEP or PEP. Discrimination testing is another issue to consider. If the plan is not a safe harbor plan, ADP and ACP testing generally must be performed separately for each participating employer in a MEP. What happens when an employer leaves the MEP midyear? Or what if the employer leaves before the prior year’s testing is completed? Who is responsible for completing the test? If corrective distributions are required, which plan makes them? How do you coordinate the correction if the employer and its participants have already moved out of the MEP?

These are the kinds of operational questions that are not always easy to answer, and there is no formal guidance addressing them. That makes communication and planning even more important. The biggest lesson is simple. If a company is being sold, purchased, restructured, or changing ownership, the retirement plan professionals need to be part of the conversation early. Not a week before closing. Not after the purchase agreement has been signed, and definitely not after the transaction is complete. MEPs and PEPs can provide tremendous opportunities for employers. Getting into one can be easy. However, getting out of one can be extremely challenging. If the participating employer is being sold, planning and communication are vital to the transaction’s success. Companies get bought and sold. Family ownership changes. Controlled groups form and controlled groups break apart. None of that is unusual. The key is making sure someone asks the retirement plan questions early enough that there is still time to act on the answers. PC

24|COVERSTORY WINTER2027

The TPA of the

Future: PREPARING AI-generated / ChatGPT

FOR THE NEXT DECADE

25|COVERSTORY WINTER2027

THEY NEED TO PRICE THEIR EXPERTISE APPROPRIATELY BY INVESTING TODAY IN THE PEOPLE, PROCESSES, AND SYSTEMS THAT WILL HELP THEM ADAPT. BY THERESA CONTI

26|COVERSTORY WINTER2027

As a TPA business owner for 25 years, and now working with TPAs every day, I think about what a TPA will look like in 10 years. When we talk about a TPA of the Future, I think a decade is long enough to figure out what comes next. To prepare for this article, I first considered the topics that affect TPAs and the questions to ask. The questions focused on staffing, servicing plan sponsors and financial advisors, technology needs, security/

cybersecurity considerations, and pricing, along with what we need to do today to thrive in 10 years. I interviewed five TPAs across the country for their input, and I must thank them for spending time with me because I truly could not have done this article without their input! The TPAs that I interviewed were: • Jordan Cross, QKA, President, CrossPlans • Kirsten Curry, CEO & Attorney,

Leading Retirement Solutions • Jill Dennis, CPC, QPA, Director of Business Development/ Shareholder, Dunbar, Bender & Zapf • Russ Hooker, CEO, Nova 401(k) Associates • Chad Johansen, QKA, Partner & Director of Consulting, Plan Design Consultants, Inc. The first thing that stood out about the TPA of the Future is that

27|COVERSTORY WINTER2027

we’ll define ourselves differently as TPAs. In fact, we will no longer just receive data, perform administration and compliance, and deliver results to our clients. Instead, we will move forward into an “emerging model.” This emerging model means we receive data continuously, use technology to process and validate it, have our team interpret it and advise the client, and ultimately drive an outcome. Curry mentioned moving from reactive annual administration toward real-time information and outcome-based consultation. Johansen sees technology doing more of the actual processing while our people become the communicators and interpreters of what the technology produces. The TPA may become advice- and outcome-driven, rather than purely administrative. Another important piece that came from these interviews is the “intersection” of technology and people. As AI and automation have sometimes been seen as a threat to the TPA in recent years, what is really happening is that as technology commoditizes work, the differentiator becomes human judgment. Cross emphasized how technology doesn’t really matter if you don’t answer the phone and email and solve the client’s problem. Curry noted that clients can get an answer from technology but wonder whether they can trust it. The answer comes from the people they are dealing with at your firm. Hooker said we will probably all gain access to similar technology for plan servicing, but the service we provide will be harder to commoditize than the software. Technology will be necessary but will not eliminate the TPA’s advantage; instead, it will redefine it around relationships, judgment, and service. We then discussed using AI in our TPA firms, but no one said that AI was their strategy. Instead, they all

viewed AI as a necessary part of their overall operations. They view it as a complete package: data + automation + people + workflow + client service Curry mentioned using data warehouses, AI dashboards, automation, and vendor integration to create a whole “product” that works together, rather than individual pieces. Johansen talked about how systems need to communicate and produce information our clients can easily understand, and Cross made it clear there is no “easy button.” Instead, we should find the problem, then apply technology rather than adopting it just because it’s new. What stood out to me is the amount of “hype” around using AI (not just in the TPA world), but everyone I talked with was clear that they would use it to improve their operations and what they provide to clients. In the technology conversation, data integration matters more than AI. The data we get doesn’t flow cleanly. We need to have a clean flow that would look like this: Payroll g recordkeeper g TPA g compliance system g CRM g client Johansen’s vision was clear: we need standardized data fees, real-time validation, and technology to convert compliance results into something a client can truly understand. Curry also wants real-time data exchange so we can be more proactive with our clients and the consultation they want us to provide. So even though AI is getting all the attention, the operations behind it will determine who succeeds. What does our market look like in the future? There are probably two emerging markets based on the conversation. First is: high-volume + automated + standardized + lower-touch + pricesensitive There also will be: high-service + consultative + customized + relationship-driven + higher-value

Clearly there will be room for both, and you can determine which you want to move toward, but some of this will also dictate what you charge for your services. Johansen felt that fee compression will remain for the high-volume model, whereas higher fees can be charged for the high-service model. Dennis felt that there will be a market for the low-cost, low-touch services in the future. But she also sees clients leaving those high-volume environments when they need help with a problem or a correction and realize they need the high-service model instead. I agree that the two models will continue to exist, but as TPAs we need to decide which model we want to go with and stick with it; being somewhere in the middle will not be a viable solution. What do you need to consider as it relates to the service model you choose in the future? You don’t want to put yourself at risk…risk of not being large enough to compete on scale, not being automated enough to compete on efficiency, but also not differentiated enough to demand higher consultative fees. Cross gave a great comparison to this model as it relates to the banking industry. Do you want to be the big box bank or the regional bank? The smaller regional and independent firms will survive if they know who they are and the value they provide. We also need to recognize consolidation in the TPA industry. We all agreed that consolidation will continue, but who will survive? Johansen thought there will be considerably fewer traditional TPAs in our 10-year future. Cross said there will be fewer independent TPAs, but thinks there will be a place for them alongside the national firms, and the strong ones will definitely have a significant place in the market! Some interviews also raised significant, specific considerations. These related to our operating model, the client experience, what

28|COVERSTORY WINTER2027

path. We will still need that knowledge base to review work being completed and sent to our clients. We need junior people to know more than how to “click the button.” As an industry, we need training systems that replace the learning that used to happen by doing the actual work. I also discussed outsourcing with each interviewee. Ten years ago, outsourcing was new, and very few were doing it (and no one was talking about it). Today, many use it as their “junior staff” to complete tasks that automation should ultimately be able to do.

So where does that leave the outsourcing model? Everyone seemed to have a different opinion. Cross and Johansen felt that technology could replace this work and would also allow the TPA to maintain control over what is being produced. Hooker questioned how this ultimately benefits clients and raised concerns about data security. Both Curry and Dennis viewed outsourcing as a solution that will continue for TPA firms. That remote workforce is part of the team and, in many cases, is viewed as junior administrators. Even though some of the functions they do today can be automated, the

AI-generated / ChatGPT

technology cannot do, how the business in place today will transfer knowledge to the next “generation,” and the future role of outsourcing. Curry took a strong stance on the operating model TPAs will need for the future. She believes it’s not about hiring better people or using AI, but about having a scalable operating system. That includes trustworthy data, repeatable automation, employee development, KPIs, profitability, and the client experience. “The future TPA isn’t created by buying technology. It is created by redesigning the company around technology, people, and processes.” Hooker was skeptical of our tendency to chase technology just so that we can say we do it. Instead, he focuses on whether what we are doing improves the client experience. We can’t buy technology that can’t work with what we already have in place. His view that clients won’t leave because of price or lack of technology, but because of a lack of response, is true today and will remain true in the future. “Technology will become table stakes. Service will remain the competitive advantage.” Dennis knew technology would keep evolving and do more of the work we do, but we need people who know whether the output is correct. We will need experienced, technically sound staff to review and validate the output. This may require staff with even more knowledge to verify the work being produced. In fact, this can create a different problem: how do you teach this expertise when technology performs more of the tasks we used to learn historically? This led us to discuss the potential knowledge-transfer crisis. We can use automation to do much of the juniorlevel work, but that work is how we all learned the industry. We can (and should) use our experienced consultants to train younger employees as a career

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“TECHNOLOGY IS NECESSARY AND WILL IMPROVE EFFICIENCY AND ACCURACY, BUT OUR COMPETITIVE ADVANTAGE WILL COME FROM KNOWLEDGEABLE PEOPLE, TRUSTED RELATIONSHIPS, AND RESPONSIVE SERVICE.”

consensus was that they will still have a place to help TPAs get the necessary work done. Cybersecurity was another consideration, and the consensus is that you need to make sure your cybersecurity is “mature” to retain your business as an accepted service provider …basically it is nonnegotiable. Both Johansen and Dennis felt that scrutiny from plan sponsors, financial advisors, broker/dealers, and recordkeepers will be brought to the forefront. More scrutiny and formal cybersecurity policies will be required to compete. Cross was concerned that the stronger this security gets, the more inconvenient it will be for employees, but no one feels we can do business without strong cybersecurity protocols. We then talked about the two Ps …pricing and profitability. In my mind, these go together …we can’t maintain our firm at a level that provides quality work if we aren’t making money, and we can’t make money if we don’t charge enough for the work we do.

Pricing has been a long-term problem for TPAs. We have felt for a long time that we are part of fee compression, and maybe we are, or we should start thinking about it in the past tense, that we were. I used to raise my fees regularly (every two to three years), but many TPAs struggle with this part of their business. I felt that even if I raised fees by 20% and 20% of clients left, I’d still have the same revenue but be servicing fewer clients (and it would give me more time to spend on those clients). I argued that we should think of that as part of the value discussion. Curry believed clients continue to value what a TPA can remove from their workload, since even those with HR teams don’t necessarily have retirement plan knowledge. Instead, we want to provide the outcome that they need when we talk about retirement. Hooker said that we should focus on identifying what clients actually value rather than simply being the cheapest provider. Another thing to consider when we think about pricing is that we need to stop pricing everything as though all services are equal. Dennis and Johansen both thought regular operational support could be one price, but the consulting and fiduciary services we often provide shouldn’t be free; we should charge for them as the value we provide to the client. Why do we think that, as TPAs, we should charge rock-bottom prices but provide complex consulting, hire exceptional staff, invest in cybersecurity, and keep building sophisticated technology? Technology investments and exceptional client service require economically healthy firms. Curry and Cross both felt that profitability allows them the ability to invest in people and technology… and that profitability is paramount to the continued success of their firms… as it should be for all TPAs. As I wrap up this article, I want to highlight what I felt was most

important in each interviewee’s message. They shared many similar opinions, but each seemed to focus on something slightly different. Cross: A competitive strategy for the independent TPA — technology investment, pricing, differentiation, and independence Curry: Focus on building a scalable TPA firm — people, data, systems, metrics, and outcomes Dennis: A practical balance between automation and human expertise Johansen: Transformation of the TPA industry — technology, efficiency and consulting Hooker: Protect the client service and value and adapt technology intelligently Technology can dramatically change how we as TPAs do the work. But we need to know what the work means, how to recognize when something is wrong, how to communicate clearly with our clients, how to anticipate problems (proactive instead of reactive), and ultimately how to help the client make the best decision as it relates to their retirement plan. As Bill Gates says, “We always overestimate the change that will occur in the next two years and underestimate the change that will occur in the next ten.” Based on my conversations, the TPA of the future will use integrated data, automation, and AI to move toward outcome-driven consulting. Technology is necessary and will improve efficiency and accuracy, but our competitive advantage will come from knowledgeable people, trusted relationships, and responsive service. To thrive over the next decade, firms must choose a clear service model, build scalable operations, strengthen cybersecurity, and keep developing the next generation of professionals. They will also need to price their expertise appropriately by investing today in the people, processes, and systems that will allow them to adapt over the next decade. PC

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CYCLE 4 IS YOUR GROWTH

OPPORT

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All your staff members are in sales because each one helps clients experience your value. Cycle 4 gives you a wonderful opportunity to make that value visible. BY REBECCA HOURIHAN

Shestak Vera / Shutterstock.com

TUNITY

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Somewhere in your office, a team member is answering a question about eligibility. Another is helping an HR director untangle a payroll issue. Someone else is explaining why the plan document needs to be updated again.

Those conversations influence whether a client stays with your firm, refers you to another advisor, or tells a new business owner, “You need to call our TPA.” And with Cycle 4, your team has an outstanding reason to start meaningful conversations. I believe restatement windows are the greatest marketing opportunities available to TPAs. You already have the expertise and relationships. Now, you have the required document update that can bring everyone back to the table. Let’s make these meetings count.

YOUR TEAM IS ALREADY BUILDING YOUR REPUTATION

Think about the person who calmly explains a confusing request, follows up as promised, or spots a recurring payroll problem and suggests a better process. That is how trust grows. Help your employees understand that connection. A team member who says, “I’m just the administrator,” may be overlooking the very reason a client loves working with your firm. Give them members credit for their patience, accuracy, and follow-through. Everyone can contribute in ways that fit their role: • Explain the reason behind a request in plain English. • Notice recurring frustrations and bring them to the right colleague. • Ask a thoughtful question when a client mentions a business change. • Make a clear introduction when another professional can help. • Keep commitments and

communicate the next step. As a business leader, give your team training, realistic workloads, and a simple way to flag opportunities for further conversations. Turn recurring questions into useful marketing content: an FAQ page on your website, a year-end checklist emailed to clients, or a plan administrator guide shared on social media. These resources demonstrate your expertise to clients and prospects. Your staff hears the questions, frustrations, and business changes that can lead to your next opportunity. Help them recognize those moments and know what to do next.

CYCLE 4 GIVES YOU A REASON TO RECONNECT

For employers using pre-approved plans, Cycle 4 requires a restatement. You know the technical work involved. But do you see the marketing opportunities? Before asking for a signature, ask this: “If we were designing your retirement plan today, would we build it the same way?” Give the employer time to answer. A productive Cycle 4 conversation can follow the same path employees take through the plan. • Entry. Do eligibility and enrollment processes fit the workforce? Are payroll and HR teams prepared to track long-term, part-time employees correctly? • Savings. Do contribution rates and employer contributions support the employer’s goals? Is automatic enrollment working as intended? • Investing. Invite the advisor to review the investment lineup,

default investment, and retirement income considerations within the scope of their responsibilities. •E ducation. Coordinate with the advisor so employees receive relevant information at different stages of life. •W ithdrawals. Review available distribution options, retirement transitions, and the administrative steps required to support them. Your team can identify the questions. Your advisor partners can help deliver education and investment guidance. Together, you can make the plan easier for the employer to understand and more useful to the people it serves. Every one of these questions gives your team a marketing opportunity to demonstrate expertise, identify a need, and bring the right people into the conversation.

GIVE REFERRAL PARTNERS A USEFUL REASON TO CALL

Advisors, CPAs, attorneys, and payroll professionals have clients who need your knowledge. Help them recognize when to involve you. An advisor may hear that an employer wants to improve employee retention. A CPA may learn that an owner wants to increase retirement savings. A payroll professional may notice enrollment problems. Create a short Cycle 4 discussion guide that partners can share. Offer a joint planning meeting. Host a lunchand-learn about questions employers should ask before restating their plans. Be specific about how you can help and respect each professional’s responsibilities. The CPA evaluates the tax implications. The advisor handles investment recommendations.

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decumulation, loans, birth and adoption distributions, student loan payments, PLESA accounts, disaster distributions, higher catch-up limits for ages 60 through 63, Roth catchups, RMDs, and much more. As you train your teams, evaluate provider capabilities, and create internal processes to handle these requests, your time is valuable. You need to be compensated. If you haven’t reviewed your fee schedule, this is a good time. Explain what your fees cover, price additional services thoughtfully, and communicate changes clearly. In recognition of the hard work that you do and the knowledge you bring, please take care of yourself, your team, and your business.

START WITH A PLAN YOUR TEAM CAN CONFIDENTLY DELIVER

Your team explains plan design and administration. Nobody needs to pretend to know everything. Afterward, send a useful recap with decisions, open questions, and assigned next steps. Reliable collaboration gives partners confidence to introduce you again. That is how a required project can lead to stronger referral relationships.

HELP YOUR MARKETING CARRY THE CONVERSATION FORWARD

At the recent TPA Growth Summit, we explained how all marketing is an extension of your team. Your website, professional profiles, meeting materials, and ongoing communication all reflect your firm’s reputation. Cycle 4 unites a message with a purpose. When a referred employer searches for your firm online, can they understand what you do? Are your team bios current? Does your website make it easy to request a conversation? Does your presentation explain your services in readable language and, please,

readable font sizes? Give your contact a clear summary they can confidently share with the owner after your meeting. Then use one strong Cycle 4 article or checklist across several channels. Email it to clients. Share it on LinkedIn. Give advisor partners a version they can use with their employers. Build a short webinar around the questions it raises. Keep your contact information accurate, organize clients, prospects, and referral partners into separate groups, and track follow-up. Consistency helps people remember you when they need you. Your staff’s good work deserves marketing that reflects their expertise and your firm’s reputation.

A LOVING NUDGE ABOUT YOUR FEES

I recognize that I’m overstepping here, but I feel this is worth mentioning: TPAs need to charge more when their fees no longer reflect the work required. The 401(k) plan is becoming the nucleus for American savings, touching retirement accumulation and

Over the next 90 days, choose a manageable group of clients for strategic planning meetings. Prioritize employers with known business changes or recurring administrative challenges and coordinate your outreach with applicable amendment deadlines. Give staff a short conversation guide and a clear contact for follow-up. Have the relationship owner invite the employer and relevant partners. Record what you learn in your CRM, including who will act and when. Measure completed reviews, useful introductions, qualified opportunities, and the time required to deliver the work. Celebrate a team member who catches an issue early or helps a client understand a difficult decision. All your staff members are in sales because each one helps clients experience your value. Cycle 4 gives you a wonderful opportunity to make that value visible and build on it together. With every well-run plan, you help hardworking people prepare for their American retirement dream. That is work worth being proud of. Give your team a high five, choose your first few conversations, and let’s make this a good season for your clients and your business. PC

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The

RISK,

RECOVERY,

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and

REWARD BY JENNIFER MANATT

Shestak Vera / Shutterstock.com

Beyond Psychological Safety: A New Perspective on Leadership in Retirement Plan Operations

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Risk management professionals working in operations are experts at identifying and mitigating risk. From compliance testing and fiduciary oversight to plan administration and investment monitoring, they must follow strict rules to protect both plan sponsors and participants. Yet one kind of risk often gets left off the checklist: the risk that comes from people being afraid to speak up. A workplace setting is considered “psychologically safe” when employees feel comfortable asking questions, raising concerns, and admitting mistakes without fear of embarrassment, retaliation, or damage to their professional credibility. Contrary to popular belief, psychological safety isn’t about making everyone comfortable or avoiding difficult conversations. It’s actually attributed to better performance, accuracy, and teamwork, critical to highly regulated, complex industries like retirement plan management. Harvard professor Amy Edmondson describes psychological safety as a workplace where people feel comfortable being themselves and speaking up. Her work demonstrated that psychological safety isn’t simply an employee engagement initiative, but a competitive advantage and form of risk mitigation. In retirement plan operations, this may look like an employee questioning a plan provision, raising a compliance concern, or admitting an error before it affects a client. Psychological safety is not lowering standards or eliminating accountability. In fact, psychologically safe organizations often hold people to higher standards—the real difference in managing mistakes. Rather than immediately assigning blame, leaders first want to understand what happened, why, and how to prevent it in the future. Performance conversations happen privately and respectfully to protect process integrity while preserving the individual’s dignity. The end goal is clarity, learning, accountability, and better decision-making going forward. Research continues to reinforce the value of this approach. Google’s Project Aristotle examined more than 180 teams and determined the single most important factor of high-performing teams was psychological safety, not intelligence, seniority, or technical ability. Teams that felt safe speaking up caught mistakes faster, offered new ideas, and adapted to change. In retirement plan management, where precision and trust are essential, advantages like this keep your organization competitive and relevant. Managing retirement plans depends on far more than technical expertise. It depends on people asking questions when something doesn’t seem right, admitting mistakes before they become costly, challenging assumptions, and raising concerns without hesitation. When employees don’t feel safe doing those things, even the

“MANAGING RETIREMENT PLANS DEPENDS ON FAR MORE THAN TECHNICAL EXPERTISE. IT DEPENDS ON PEOPLE ASKING QUESTIONS WHEN SOMETHING DOESN’T SEEM RIGHT, ADMITTING MISTAKES BEFORE THEY BECOME COSTLY, CHALLENGING ASSUMPTIONS, AND RAISING CONCERNS WITHOUT HESITATION.” strongest operational processes can begin to fail. Consider a few scenarios where psychological safety is absent: • A team member notices a discrepancy in a plan amendment but assumes someone else will fix it. • An administrator is unsure about a plan provision but doesn’t ask for clarification to avoid appearing inexperienced or being wrong. • A recurring process failure is quietly worked around, causing rework and more risk later on. Technical competence isn’t the issue; a work environment where speaking up is constantly met with

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criticism feels riskier than remaining silent. Over time, silence becomes expensive as innovation slows, and the organization’s efficiency and trust decline because the very people depended on to identify risk begin protecting themselves instead. Here, leaders must become the biggest supporters of psychological safety in an organization. Employees pay much closer attention to leadership behavior than any written policy. When leaders ask thoughtful questions, listen without judgment, acknowledge uncertainty, and respond constructively, they signal that speaking up is both safe and expected. Just as organizations rely on internal controls to reduce financial and operational risk, they can establish a cultural framework that reduces people-related risk. A basic psychological safety framework includes: • Normalizing asking questions. The leader’s meeting agendas consistently hold space for open and honest feedback. Such as: “What concerns or risks do we need to be aware of this week?” • Remain curious, not critical. When issues arise, direct energy toward determining where the process broke down, not who caused it. • Clarify roles, including issue identification. When everyone knows their responsibilities and everyone is tasked with identifying issues, people are more likely to speak up before it’s too late. • Performance metrics. Consider trends surrounding turnover, engagement, communication, and recurring error rates. These can reveal risks to the organization’s health long before financial reports do. If psychological safety is one of the most valuable investments

“THE END GOAL IS CLARITY, LEARNING, ACCOUNTABILITY, AND BETTER DECISIONMAKING GOING FORWARD.” an organization can make, then an equally important, often forgotten, question naturally follows: What happens when employees have spent months, or years, in work environments without psychological safety? As awareness of psychological safety continues to grow, so does the recognition that prolonged exposure to psychologically unsafe work environments can have lasting effects on those leading and working in them. Emerging evidence suggests that prolonged occupational stress from excess workload may be associated with measurable changes in brain regions involved in executive functioning, emotional regulation, attention, and threat detection.1 While workload alone can contribute to these brain changes, it’s reasonable to consider how work environments characterized by chronic criticism, uncertainty, fear of speaking up, or persistent interpersonal conflict might further amplify those effects. Years of neuroscience research show how chronic stress can alter the neural circuits involved in learning, decision-making, and threat detection, suggesting that chronic workplace stress adaptations can begin to shape how people communicate, make decisions, respond to feedback, and approach risk.2 Over time, protective adaptations may become the default way they navigate work, even after the original environment has changed.

This research helps us understand how once-confident contributors may begin holding back and secondguessing themselves. Why leaders who once welcomed difficult conversations find themselves avoiding conflict or becoming reactive under pressure, and why a once positive influencer begins contributing negatively to the work environment. These responses, often interpreted as performance issues, are actually adaptations to speaking up when it carries too much social or professional risk. Researchers, advocacy organizations like www.EndWorkplaceAbuse.com, and policymakers increasingly recognize that psychologically unsafe workplaces are more than a morale issue; they can become an occupational health concern with implications for leadership, performance, retention, and long-term organizational resilience. That recognition raises another question. If organizations understand how to build psychologically safe environments, are we giving enough attention to helping professionals recover after workplaces without psychological safety have shaped how they operate, communicate, and lead? Today’s leadership development programs teach essential leadership competencies of communication, conflict resolution, emotional intelligence, and strategic thinking. However, they often assume professionals can access them when it matters most. What receives much less attention is how to cope with chronic stress,

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interpreted as a constant threat by the brain, which makes it impossible to access these learned skills under pressure consistently. For example: • That leader who once welcomed feedback is now avoiding difficult conversations. • A confident decision-maker begins second-guessing every opportunity or solution. • Someone known for their calm, steady leadership becomes increasingly reactive, withdrawn, or skeptical. People often interpret these changes as declining performance or diminished capability. In many cases, these reflect the brain and nervous system doing exactly what they are designed to do: shift from production to protection. This requires leaders to shift from asking, “What’s wrong with them?” to asking, “What experiences may have shaped the way this professional now responds under pressure?” That shift moves leadership development beyond correcting behaviors to understanding the conditions that influenced them. The conversation usually ends at defining psychological safety, discussing prevention, and leadership’s role - It can’t. Much has been written about psychologically safe workplaces. Far less has been written about what to do after the impact. The professionals who have spent months, or years, working in psychologically unsafe work environments don’t need another article explaining it. Coping strategies may look like: • Talking to friends and family. • Commiserating with co-workers. • Reading articles on burnout, resilience, leadership, workplace culture, etc. • Finding comfort in similar stories posted online, knowing they’re not alone. Yet, they’re still:

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“ORGANIZATIONS THAT INTENTIONALLY INVEST IN PSYCHOLOGICALLY SAFE CULTURES REDUCE PEOPLE-RELATED RISK BEFORE IT GROWS INTO OPERATIONAL RISK.”

• Replaying conversations long after meetings end. • Hesitating before speaking up or sharing an idea. • Anticipating criticism before it’s offered. • Carrying workplace stress home. And even though you genuinely want to respond differently, the same reactions keep surfacing automatically. This is because awareness, while important, isn’t always enough. These responses, once conscious habits, can become learned patterns shaped by repeated experiences over time. Recognizing those patterns, and intentionally working to change them, is a conversation leadership development has only begun to explore. This is the perspective I’ve coined as Leadership Recovery & Empowerment. Leadership Recovery is the process of recognizing how prolonged workplace stress may have affected confidence, communication, decisionmaking, leadership presence, and how people respond under pressure. Leadership Empowerment is the intentional work of strengthening self-awareness, emotional regulation, resilience, and the ability to lead with greater clarity, confidence, and purpose moving forward. The distinction matters. Recovery isn’t about suggesting leaders are broken. It’s about recognizing that capable professionals sometimes spend years adapting to environments

that require protection rather than performance. Empowerment happens when they address those adaptations effectively, reconnect with their strengths, and can lead with intention again. If the psychological safety framework represents prevention, Leadership Recovery & Empowerment represents restoration. Neither replaces the other, and to be successful, organizations need both because even if the framework is in place, hiring brings new people’s past experiences into your environment. Leadership Recovery & Empowerment acknowledges that when psychological safety has been absent, leaders and employees alike may benefit from opportunities to address the lasting influence of those experiences better while developing new ways to move forward. This perspective also challenges organizations to think differently about leadership development itself. Though traditional leadership skills remain part of the curriculum, the future of leadership development may include helping capable leaders recognize how their experiences shape how they think, respond, and lead under pressure, and providing tools that support recovery, growth, and resilience.

When leaders gain these resources, something important happens, as they: • Become better equipped to recognize these patterns in others. • Ask different questions. • Respond with greater curiosity. • Create environments where accountability and dignity coexist. In doing so, they strengthen the psychologically safe workplace that helps prevent these patterns from developing while delivering significant value to the organization. For retirement planning organizations, the implications are significant. While technical expertise will always remain essential, regulatory compliance will too. But neither exists independently of the people responsible for carrying them out. Organizations that intentionally invest in psychologically safe cultures reduce people-related risk before it grows into operational risk. Those organizations that also recognize the importance of Leadership Recovery & Empowerment strengthen something equally valuable: the people entrusted with protecting clients, navigating complexity, and making sound decisions every day. Just as the retirement plan industry’s operational excellence depends on strong processes, perhaps it’s time we recognize that it depends just as much on the people working within them. Because the greatest risk isn’t always found inside the process. Sometimes it’s found in the question unasked. And sometimes the greatest opportunity isn’t in preventing that silence but helping someone rediscover the confidence to speak again. PC

1 Jang W, Kim S, Kim Y, et al Overwork and changes in brain structure: a pilot study Occupational and Environmental Medicine 2025;82:105-111. 2 G emmerich R, Müller O, Schaller A. The application of f NIRS in studies on occupational workload: a systematic review. Front Public Health. 2025 Apr 22;13:1560605. doi: 10.3389/fpubh.2025.1560605. PMID: 40331113; PMCID: PMC12053328.

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FROM OPERATIONAL ERROR TO OPPORTUNITY Here’s how to turn operational challenges into opportunities for leadership, learning, and trust. By Scott Pounds

Operational issues are inevitable in retirement plan administration. For retirement

industry professionals leading service, operations, and administration teams, these moments can be opportunities to strengthen processes, build trust, and support team development. A routine question or review may reveal that something does not align with expectations. When a team member pauses to examine the details and challenges an assumption, the issue may become an opportunity for leaders to strengthen both the process and the team. This article offers a leadership framework for responding when an operational issue emerges: protect those affected, support team members, reinforce accountability, and turn the challenge into a broader learning opportunity. Although the facts may vary, the core principles remain consistent: understand what happened, collaborate across teams, communicate responsibly, and improve the process so the organization is stronger going forward.

A HYPOTHETICAL OPERATIONAL SCENARIO Consider this scenario: during a routine review or inquiry, a team member identifies a potential error in a plan setup, or transaction process that requires further investigation. In moments like this, the immediate question is often whether the specific issue can be corrected. That is important, but it is only part of the

response. A strong approach also asks what the situation can teach the organization about process design, quality review, communication, and team member development.

SHIFTING THE FOCUS FROM BLAME TO UNDERSTANDING

When a significant error is uncovered, a natural question often follows: “Who made the mistake?” Accountability matters. Organizations need to understand what happened and who was involved. But when investigations begin and end with assigning fault, opportunities to learn can be missed. The better question is often: “How did this happen?” A leader’s role is to create the conditions for that better question to be answered objectively. That means slowing the conversation down, gathering facts, and helping team members focus on the full sequence of events rather than jumping immediately to conclusions. The goal is not to minimize accountability. Accountability remains essential. But accountability is most effective when it is paired with curiosity, coaching, and a commitment to understanding the process conditions that allowed the issue to occur.

THE IMPORTANCE OF COLLABORATION

Like many complex operational issues, no single team member possesses all the answers.

Team members may need to gather documentation, review transaction history, validate assumptions and consult subject matter experts. Leaders help by clarifying ownership, keeping the work coordinated, and ensuring decisions are based on accurate information. The investigation reinforces an important lesson: significant issues are rarely solved by one person. When teams view a problem through the lens of blame, information can become fragmented. Team members may become defensive or hesitant to share uncertainties. Progress slows, and critical details can be overlooked. By contrast, when teams focus on solving a shared problem, collaboration often improves. Team members are likely to become more willing to ask questions, challenge assumptions, and contribute expertise.

MAINTAINING TRUST THROUGH COMMUNICATION

Technical resolution alone may not be enough when an operational issue affects or could affect participants, advisors, third-party administrators, plan sponsors, or internal partners. Communication is equally important. Internally, teams need a clear understanding of what is known, what still needs to be reviewed, who owns each next step, and how decisions will be documented. Externally, stakeholders need confidence that the matter is being reviewed thoughtfully, that appropriate steps are being taken, and

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Peshkova / Shutterstock.com

WINTER2027

that communication will remain timely and accurate. Moments like these can test relationships. Clients and advisors do not expect organizations to be perfect. They do, however, expect organizations to respond responsibly when problems arise. Transparency, ownership, empathy, and timely updates can have a significant impact on how an issue is perceived. While accuracy remains essential, stakeholders also need confidence that the organization understands the problem and is committed to making it right. Looking Beyond the Immediate Correction Many organizations stop once a correction has been completed. That could be a mistake. Fixing the symptom does not necessarily address the cause. The visible issue may be corrected through established procedures, but the deeper value comes from examining the process that produced the outcome. That review may identify opportunities to clarify documentation, strengthen

handoffs, refine quality checks, improve training, or involve specialized reviewers earlier in the process. That required asking difficult but necessary questions. Those questions may include: Were expectations clearly documented? Were the right teams involved at the right time? Did the review process include the expertise needed to identify the issue? Were controls designed to detect inconsistencies before they reached the client or participant experience? Answers to these questions reveal opportunities for improvement. When leaders approach the review this way, the outcome extends beyond a single correction. The organization gains practical insight that can strengthen future service delivery and reduce the likelihood of similar issues recurring.

THE REAL MEASURE OF SUCCESS

Looking back, the most important outcome of a well-managed operational issue is not simply that the immediate matter was resolved. A routine question can become a catalyst for stronger controls, clearer procedures, more effective coaching,

and better collaboration across teams. The greater achievement is that leaders help the organization learn from the experience, while supporting team members through the review in a way that reinforces accountability without creating fear or defensiveness. In the retirement plan industry, trust is one of an organization’s most valuable assets. No organization can eliminate every mistake. What distinguishes strong organizations is how they respond when mistakes occur. The best responses are grounded in curiosity rather than blame, accountability rather than defensiveness, and improvement rather than complacency. When handled well, an operational challenge can become an opportunity to reinforce trust, develop team members, and strengthen the way work gets done. That may be the most valuable lesson of all: strong service cultures are built not by avoiding every challenge, but by responding to each one with curiosity, collaboration, accountability, and care. PC

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PARTNERING FOR ‘RETIREMENT DIGNITY:’ COMMON CAUSE FOR A GROWING STATE NETWORK The connections include cooperation in providing retirement benefits to citizens who work for privatesector employers that don’t offer a retirement plan. By John Iekel

In the earliest days of our republic, connections between states were limited.

They were largely by water — rivers and routes through lakes and an ocean — as well as a few rough roads, really glorified paths. Over the years, connections across borders have grown. States became more than neighbors or distant national relations. Roads, railroads, Route 66, the interstate highway system, air travel, commerce, the internet. The states may be disparate, but they are far from islands, including Hawaii. With time, states’ connections came to be about more than commerce and the connections between the private citizens living in them. As our society and economy grew and became more complex, so too did the relationships between the states — and the need for them. Those connections include cooperation in providing retirement benefits to citizens who work for private-sector employers that don’t offer a retirement plan.

THE CENTENNIAL STATE

The linchpin in these connections is a state established in the United States’ centennial year, 1876 — the nation’s 100th birthday, an event that took place barely a decade after the

rupture between the states had ended and relationships between the states were beginning to heal. Symbolic, then, that Colorado was the catalyst for connections between the states in providing retirement benefits. Colorado State Treasurer Dave Young, in a press release concerning one of the agreements his state entered into by which it established cooperation with another state to provide retirement plan coverage to private-sector employees, said, “I’m proud to see Colorado leading the nation on this. Partnerships increase the number of Americans saving for retirement, while decreasing fees for Coloradan and American savers alike, helping states with smaller populations offer a cost-friendly, state-run retirement program option for workers who don’t have access to one at work.”

FIRST THINGS FIRST

The first connection was between Colorado and its southern neighbor, New Mexico. Both states enacted their programs in 2020. On Nov. 9, 2021, the Colorado Department of the Treasury announced that the Colorado SecureSavings Program and the New Mexico Work and $ave programs had signed a Memorandum of Cooperation to pursue a formalized partnership agreement for

their auto-enroll IRA programs. That created the first auto-enroll IRA multi-state program in the United States. Officials hailed the agreement as a way to reduce fees by creating economies of scale and a “truly portable benefit that follows workers across jobs and state lines.” They sought to collaborate through (1) shared program administration and financial services, (2) marketing and outreach support, (3) program evaluation, (4) research, (5) data collection, and (6) participant privacy. “This is one step in the right direction for a truly portable retirement benefit — one that carries across state lines,” said Colorado State Treasurer Dave Young in a press release. His counterpart in New Mexico, State Treasurer Tim Eichenberg, said the partnership “exemplifies the best in forward thinking and collaboration.” But not so fast. Unlike other such programs, participation by private-sector employers in New Mexico Work and $ave was voluntary. The state concluded that for the program to succeed, participation by privatesector employers that didn’t offer their own retirement plan needed to be mandatory. Legislation was proposed in 2022 and 2023 to do that, but it did

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“I’M PROUD TO SEE COLORADO LEADING THE NATION ON THIS. PARTNERSHIPS INCREASE THE NUMBER OF AMERICANS SAVING FOR RETIREMENT, WHILE DECREASING FEES FOR COLORADAN AND AMERICAN SAVERS ALIKE, HELPING STATES WITH SMALLER POPULATIONS OFFER A COST-FRIENDLY, STATE-RUN RETIREMENT PROGRAM OPTION FOR WORKERS WHO DON’T HAVE ACCESS TO ONE AT WORK.” not progress or pass. Which means that the agreement between the two western neighbors “has been delayed,” as the Office of the New Mexico Treasurer put it.

AI Generated / ChatGPT

BUT LIFE GOES ON. AND ON!

The agreement between Colorado and New Mexico might be in limbo for now, but the Centennial State was not content to sit still. Down East. While Colorado and New Mexico worked on the details

of their agreement, Maine Gov. Janet Mills (D.) signed into law a measure creating the Maine Retirement Investment Trust (MERIT). Under that law, each covered employer must allow covered employees to decide whether to contribute to a payrolldeduction Roth IRA by automatically enrolling them but allowing them to opt out. They may be on almost opposite ends of the country. Still, two years later Colorado and Maine inked a

deal establishing formal cooperation in offering retirement plan coverage to their citizens. Colorado SecureSavings and MERIT established a partnership on Aug. 11, 2023, to provide retirement plan coverage to private-sector employees whose employers do not. Under the agreement, MERIT joined the the Colorado SecureSavings program to offer coverage, share governance, and still operate independently.

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“IN ADDITION TO ENSURING THAT MORE WORKERS CAN RETIRE WITH DIGNITY, THE EXPANSION OF THIS PROGRAM STRENGTHENS OUR ECONOMY AND SAVES STATES MONEY IN THE LONG TERM.” “We are excited to be working with Colorado SecureSavings to deliver a proven automatic savings program that follows employees throughout their careers while being easy and free for participating Maine employers,” said MERIT Executive Director Beth Bordowitz in a press release. Maine Treasurer Henry Beck hailed the agreement as “a model for multistate efforts” that offers an opportunity to “reduce fixed costs and focus on results.” Apparently, the Eastern Seaboard is fertile ground for Colorado — Maine was only the beginning. The First State. Still flush with the adrenaline of agreeing with Maine, Colorado Secure Savings agreed with Delaware’s program, Delaware EARNS, four months later. The first state was not the first to adopt a state auto-IRA, but it was one of the first; Gov. John Carney (D) signed legislation creating it into law in August 2022. The Delaware EARNS Program Board, which oversees the program’s design and implementation, wasted little time giving its imprimatur to pursuing interstate agreements. Less than a year later, on July 13, 2023, it voted unanimously to authorize State Treasurer Colleen Davis’s office to evaluate entering into an interstate partnership or multistate consortium to support the launch and future success of EARNS. The EARNS Program Board later that year authorized the Office of the State Treasurer to execute all agreements necessary to join and participate in Colorado’s interstate

consortium — which by then had the name Partnership for a Dignified Retirement. Davis and Colorado State Treasurer Dave Young thanked the Delaware EARNS Program Board for its action, and Colorado SecureSavings Program Director Hunter Railey called it “an important milestone.” They hailed it as an important step in expanding retirement coverage. Ted Griffith, Program Director of Delaware EARNS, later confirmed with ASPPA Net that Delaware EARNS was negotiating with Colorado and keeping Maine informed of their progress. EARNS Board Chair Fayetta M. Blake told Delaware News, a state government news service, that she expected that joining the consortium would benefit EARNS participants by giving them access to economies of scale that would help them to increase their savings. Off to the Green Mountains. Fast forward half a year, and Colorado welcomed a fourth state to the partnership — the Green Mountain State, a.k.a. Vermont. While the Delaware EARNS Program Board prepared to decide whether to authorize Delaware State Treasurer Davis to explore an interstate partnership or multistate consortium for that state’s new autoIRA program, Vermont was joining the auto-IRA club. On June 1, 2023, Gov. Phil Scott (R) signed into law a measure creating Vermont Saves, a providing retirement plan coverage to private-sector employers in the state that do not offer one.

One year later, VT Saves announced that it had joined Colorado, Delaware, and Maine as a member of the Partnership for a Dignified Retirement. Vermont Treasurer Mike Pieciak said in a press release that membership would make it possible to accelerate the program’s launch. “By partnering with Colorado, our office will be able to launch Vermont Saves sooner than expected,” he said. Similarly, Becky Wasserman, Director of Economic Empowerment at the Vermont State Treasurer’s Office, hailed the arrangement as “a critical step forward” in launching Vermont’s program. Colorado Treasurer Dave Young said that the partnership with Vermont “leads the way for more savers to have access to a retirement program through their employer.” He continued, “In addition to ensuring that more workers can retire with dignity, the expansion of this program strengthens our economy and saves states money in the long term.” Colorado SecureSavings Program Director Hunter Railey similarly said, “Too many workers lack access to retirement savings opportunities. Partnering with Vermont continues to build on a proven solution to close the savings gap.” Vermont officials were also positive about it. Pieciak remarked at the announcement of Vermont’s joining, “Our partnership shows that states can make significant progress for their constituents when they work together.”

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He added that the partnership “will help lower costs and achieve the best possible outcomes for businesses and individuals enrolled in the program,” and provide a retirement plan that will benefit the state’s workers and economy and reduce budgetary pressures. Striking Silver. Done with the East for at least a time, Colorado cast its eyes closer to home and struck a vein in the Silver State. Less than a year later, after Vermont joined the partnership, Nevada followed suit. Nevada had adopted legislation creating the Nevada Employee Savings Trust (NEST) Program in 2023. What does Nevada joining the Partnership for a Dignified Retirement mean? For Nevada, it means leveraging the Colorado SecureSavings Program’s model and taking advantage of lower plan fees. For the Partnership for a Dignified Retirement, Nevada’s addition meant it had amassed almost $130 million in assets under management.

“We are thrilled to welcome Nevada to the consortium and look forward to working with additional states in the coming months,” said Young in a press release. Nevada State Treasurer Zach Conine, who also serves as Chair of the Board of Trustees for the Nevada Employee Savings Trust, said he was “honored to join Colorado and the Partnership for a Dignified Retirement to help Nevadans prepare to save for retirement.’ He continued, “By working collaboratively, we can strengthen financial resilience within our respective programs to ensure that workers — especially those that have traditionally lacked access to retirement savings — have the tools they need to plan for their future.” Lake Country. Then it was time to expand north. As 2025 neared its close, the partnership added its 6th member when the Land of 10,000 Lakes, less colorfully known as Minnesota, joined. Minnesota Gov. Tim Walz (D) signed

into law a bill creating Minnesota Secure Choice in May 2023; however, the program’s pilot did not launch until January 2026. Joining the partnership is helping the state with its launch, Executive Director Chad Roberts of the Minnesota Secure Choice Retirement Program said. “Joining the Partnership for a Dignified Retirement enables the Minnesota Secure Choice Retirement Program to minimize fees to our savers, provide an easy enrollment onramp for employers, and successfully launch this innovative program for Minnesotans in January of 2026,” said Roberts in a press release. As for the partnership, Colorado’s treasurer said, “Joining forces with Minnesota means more savers, reduced costs, and greater financial security for families across the country.” In dollars and cents, the partnership collectively had amassed more than $212 million in assets under management, with approximately 140,000 people covered.

THE BIG PICTURE

Partnership for a Dignified Retirement programs are modeled after Colorado SecureSavings. “The continued expansion of the Partnership for a Dignified Retirement shows the power of interstate collaboration,” said Hunter Railey, Director of the Colorado SecureSavings Program, when Minnesota joined. “With the success of Colorado SecureSavings and similar programs across the country, the growth of the Partnership for a Dignified Retirement represents the next breakthrough in expanding low-cost, portable retirement savings opportunities for private sector workers,” said Colorado Treasurer Young. Young continued, “As the partnership grows, we are building real momentum toward a future where every worker can retire with dignity.” PC

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BENCHMARKS, STANDING, AND THE DIFFERENCE A FEW FACTS CAN MAKE Here’s what you need to know for emerging trends in the most recent quarter of ERISA litigation. By Nevin E. Adams, JD, and Bonnie Treichel, JD

The third-quarter litigation landscape offered what might seem to be conflicting lessons. Courts continued to dismiss

claims based on hindsight, speculation, weak comparisons and injuries that had not actually occurred. At the s ame time, other plaintiffs survived dismissal, or revived previously dismissed claims, by supplying more specific facts, better comparators or a different theory of injury. However — and as the courts repeatedly reminded both sides this quarter, the difference between speculation and a plausible claim — and between disappointing results and fiduciary imprudence — is often found in the details, so let’s dive into the details you need to know.

HERE’S WHAT YOU REALLY NEED TO KNOW

• The “meaningful benchmark” remains a powerful defense against investment-underperformance claims, but courts are increasingly emphasizing that it is not necessarily the only way to establish imprudence. However, the Supreme Court will take on the “meaningful benchmark” issue on October 6, so this might be the most important concept to watch right now. • Pension risk transfer suits continue to turn on standing, with most courts finding that retirees receiving promised benefits have no concrete injury requiring a remedy, or even a trial.

• Forfeiture reallocation challenges continue to be filed, and while most are rejected at the motion to dismiss stage, the challenges show no sign of fading. • Courts remain skeptical of plan provisions that require individualized arbitration when those provisions effectively eliminate the Employee Retirement Income Security Act’s (ERISA) plan-wide remedies. Let’s dive in!

BENCHMARK ‘MARKS’

Perhaps no issue dominated the quarter more than the role of a “meaningful benchmark” in ERISA investment litigation and with the Supreme Court scheduled to hear Anderson v. Intel on October 6, the timing could hardly be better. The quarter began with a reminder of the standard’s practical power. In a suit challenging the Fidelity Stable Value Fund, a federal judge rejected a “cherrypicked assortment of comparators.”1 Merely placing investments in the broad stable value category did not make them comparable; strategy, assets, risk and potential return all mattered. The case was dismissed with prejudice after the plaintiff had already amended the complaint. The Court of Appeals for the 3rd Circuit supplied an even more fundamental reminder in litigation involving the Quest Diagnostics plan.2 Affirming summary judgment for the fiduciaries, the court began with a refreshingly straightforward

observation: “Sometimes, even a good process produces disappointing results.” Quest’s committee hired an outside consultant, met quarterly, reviewed reports, met with investment managers and received annual fiduciary training. Short-term underperformance did not require immediate removal, and better-performing alternatives did not prove that the selected investments were imprudent. Significantly, the court could describe the process precisely because it had been documented. The victory reflected evidence that the committee reviewed information, sought more when needed, understood its advisor’s recommendations and remained involved. Then came a pair of target-date fund (TDF) decisions that, at first glance, seem to point in opposite directions. In Scholin v. Digi-Key Corp., a Minnesota federal judge dismissed a challenge to the American Century TDF series because the complaint did not adequately explain the objectives, strategies or risk profiles of the proposed comparator suites.3 Naming Vanguard, T. Rowe Price, Capital Group and BlackRock TDFs and charting their returns was not enough since, after all, TDFs bearing the same retirement year can have materially different glidepaths, allocations, active/ passive approaches and risk objectives. By contrast, plaintiffs challenging 3M’s custom TDFs got a second chance after an earlier dismissal and made more of it.4

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Their amended complaint supplied detailed comparisons involving asset allocation, Morningstar categories, risk ratios, management strategy and investment structure. The court found several proposed alternatives sufficiently similar to serving as meaningful benchmarks, allowing portions of the case to proceed.5 The Court of Appeals for the 11th Circuit complicated the narrative further.6 In the Royal Caribbean litigation, the district court granted summary judgment because the plaintiff failed to establish that Russell TDFs were objectively imprudent compared with funds having the same strategy and risk profile. The appellate panel reversed, explaining that an ERISA plaintiff does not need an apples-to-apples comparator in every case. A fiduciary process based on “prayer, astrology or just blind luck” would not become prudent merely because the investment performed acceptably. That does not render benchmarks irrelevant. It recognizes that a benchmark — or more precise comparisons to a relevant benchmark — is circumstantial evidence of a deficient process, not the statutory duty itself. Direct evidence of a flawed process, or other circumstantial evidence supporting that inference, may also establish imprudence.

PENSION RISK ‘TRANSFERS’ — STANDING STILL MATTERS

During the quarter, the pension risk transfer (PRT) litigation wave also produced decisions that appear to diverge, though most continue to turn on whether plaintiffs have suffered a concrete, current injury. In these cases, participants generally allege that a plan sponsor transferred pension obligations to an insurer that is less safe than a traditional carrier.7 While permitted under ERISA, the transfer ends the federal insurance protection of the Pension Benefit Guaranty Corporation (PBGC), replacing it with that provided by state insurance regulation and guaranty associations. Yet plaintiffs typically continue receiving every dollar promised, a fact that has proved difficult to overcome. In the ATI litigation, involving approximately $1.5 billion in pension obligations transferred to Athene, concerns about the insurer’s structure, investments and possible future default were deemed “pure speculation,” not an actual or imminent injury.8 Under the Supreme Court’s Thole decision, participants receiving their promised benefits lacked Article III standing.9 A Colorado federal court reached much the same conclusion in the Lumen case, involving roughly $1.4

billion and 22,600 participants.10 Athene had made every required payment, and neither an asserted reduction in value nor the possibility of future default established a present or imminent injury. The case was dismissed without prejudice, allowing plaintiffs to try again. During the quarter, the Department of Labor (DOL) weighed in on the fiduciaries’ side in the Bristol-Myers Squibb appeal, arguing that undertaking a PRT is a settlor decision and that fiduciary duties attach to selecting the annuity provider — not the transfer itself.11 The loss of ERISA and PBGC coverage, it argued, is an intended consequence of a transaction which ERISA permits, not a separate injury. According to its brief, no annuity selected in a PRT transaction over the past three decades has defaulted. However, Piercy v. AT&T demonstrates that PRT litigation does not always end at the courthouse door. A magistrate judge recommended dismissing AT&T but allowing a claim against State Street Global Advisors (the independent fiduciary that recommended the PRT provider) to proceed.12 The amended complaint supplied comparisons with other annuity providers and alleged that Athene was comparatively riskier. It still did not show that AT&T interfered with State

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Street’s selection, knew the process was defective, or failed to monitor. Delegation did not eliminate AT&T’s obligations, but plaintiffs needed facts showing a breach. The allegations against State Street were different. Plaintiffs cited its alleged connections with Apollo and Athene, its role in other Athene PRTs and its compensation as an independent fiduciary. The magistrate concluded that those allegations could support an inference of disloyalty or a flawed process. Of course, that recommendation still awaits the district judge’s action, and the plaintiffs still must prove their allegations. Nonetheless, the decision highlights an important point: hiring an independent fiduciary can be a powerful procedural protection, but the independent fiduciary’s own process, conflicts and documentation remain subject to scrutiny.

CITS, FORFEITURES, AND A FEE CLAIM THAT SURVIVED

This quarter also brought two variations of a familiar “kitchen sink” complaint, combining challenges to the use of forfeitures to offset employer contributions, allegedly excessive recordkeeping fees and the newer claim that selecting collective investment trusts (CITs) was imprudent. In a case involving Centene, the court dismissed allegations that the plan acted imprudently by selecting CITs instead of mutual funds. Describing CITs as “structurally opaque” and speculating about liquidity risk did not establish to the court’s satisfaction that the participant paid more, lost money or faced imminent harm.13 The recordkeeping comparisons were similarly deficient: identifying three other “jumbo” plans without describing their services or other relevant characteristics did not render them meaningful comparators. The court also dismissed the forfeiture claims. Aside from the legality of the option, the plan document expressly allowed Centene to use forfeitures either to pay administrative expenses or reduce employer contributions. Although the court acknowledged that choosing between

those options could be a fiduciary act, the complaint did not plausibly allege that the choice was imprudent or disloyal. The court ruled that an incidental benefit to the employer did not constitute a reversion of plan assets, particularly where the forfeitures remained in the plan, and contribution obligations owed to participants were satisfied. That said, the plaintiffs were given leave to amend, though that revised complaint met largely the same fate in September. Fiduciary defendants also prevailed in a suit involving Lithia Motors, at least on allegations involving the use of plan forfeitures and a transfer of plan assets to a CIT.14 The court acknowledged that the majority of courts addressing forfeitures have rejected the theory when the governing document authorizes their use to reduce employer contributions.15 This time the forfeiture claims were dismissed without leave to amend because the legal theory — not merely the factual pleading — was deficient. Similarly, allegations that converting mutual-fund TDFs to CITs reduced participant transparency did not explain how the structure impaired the fiduciaries’ own monitoring or caused a loss. “Opacity” may sound ominous, but it is not itself an injury or a fiduciary breach, according to the court.

MULTIPLIER ‘EFFECTS’

That focus on fees and provider compensation also appeared in one of the quarter’s largest developments: a proposed $48 million settlement involving the $4.4 billion ADP TotalSource Retirement Savings Plan.16 The case, filed in 2020, alleged excessive fees, poorly performing investments, self-dealing and prohibited transactions. With trial approaching after six years of litigation, the parties— plaintiffs again represented by Schlichter Bogard LLC — reached agreement covering roughly 50,000 participants. The defendants admitted no wrongdoing, and a settlement is not an adjudication. Even so, its size and non-monetary provisions deserve attention.

In addition to the substantial cash award, the settlement agreement calls for a full TDF review, consideration of at least three alternatives and restrictions on TDF-provider revenue sharing beginning in 2028. A competitively selected independent fiduciary must also review certain payments from plan assets to ADP. This follows the substantial verdict and settlement involving Pentegra’s multiple employer plan (MEP).17 The facts differ, but the common structure is hard to ignore. When one provider stands at the center of an arrangement serving many employers, compensation can look like part of the product rather than an expense requiring periodic evaluation. Scale can also turn modest per-participant amounts into very large alleged losses. For pooled and multiple employer arrangements, scale can provide purchasing power, but it can also create litigation magnitude. Someone must own the obligation to identify every form of direct and indirect compensation, assess the services received, benchmark the arrangement and document why it remains reasonable. As pooled employer plans (PEPs) continue to grow and expand, this will bear watching.

COURTHOUSE ‘DOORS’ — AND WHO GETS PULLED THROUGH THEM

Finally, several decisions addressed not the substance of a fiduciary claim, but whether, and at what personal risk, a participant can pursue one. The Court of Appeals for the 9th Circuit refused to enforce Capital Group plan terms requiring individualized arbitration of a participant’s fiduciary-breach claims. The plan committee had unilaterally added mandatory arbitration and a waiver of class, collective and representative actions. Although federal law generally favors arbitration, the provision effectively prevented the participant from pursuing the plan-wide relief ERISA expressly authorizes under section 502(a)(2). The court therefore found the provision unenforceable under the “effective vindication” doctrine.

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The decision adds to the authority rejecting arbitration provisions that eliminate a statutory remedy rather than merely selecting a forum. The circuit split remains, but an individual arbitration clause may not keep planwide claims out of court. Meanwhile, a newly filed suit may expand both the range of benefits challenged and the potential fiduciary defendants. In McCalla v. USI Insurance Services, LLC, participants sued their employer, an insurance brokerage and consulting company, over voluntary benefits funded through participant-paid premiums. Unlike most recent VBO suits, this one effectively combines the employer, broker and consultant roles in a single defendant.19 The complaint alleges that USI acted as a fiduciary in selecting and placing voluntary benefit products while also helping determine — and receiving — the commissions and administration fees embedded in participant premiums. Plaintiffs claim USI could influence whether its compensation was a high first-year “heaped” commission, level commission, flat payment or administration fee through its authority over the plan’s insurance arrangements. Those remain allegations, and USI has not yet tested them at the motionto-dismiss stage. Still, the suit raises not only whether participants may pursue plan-wide relief, but which providers may be treated as fiduciaries. Receiving commissions or performing services alone does not create fiduciary status. But if a provider exercises discretion over plan management, product selection or its own compensation, plaintiffs will argue that it crossed the line from selling or administering benefits to exercising fiduciary authority. The case also reinforces the emerging focus on voluntary benefits that employers may have viewed as participant-paid and therefore largely outside their fiduciary risk. At the other end of the access-tocourt debate, the Court of Appeals for the 4th Circuit upheld a $122,951 attorney-fee award against a participant whose unsuccessful case arose from an attempted market-timing transaction.20 The appellate court largely rejected his

benefits and fiduciary claims, though it concluded that the plan’s administrative services agreement was a document under which the plan operated and therefore should have been produced upon request. The participant has requested en banc review of the fee award, arguing that imposing defense fees against unsuccessful benefit claimants’ conflicts with ERISA’s remedial purpose and could deter legitimate claims. The Supreme Court itself recently pointed to fee shifting as one tool courts can use against meritless ERISA litigation. The difficult question is where deterrence ends and chilling access to the courts begins.

ACTION ITEMS FOR PLAN SPONSORS

• Document the Analysis, Not Merely the Decision. Committee calendars and consultant reports are useful, but the Quest decision shows the value of documenting what fiduciaries actually considered, questioned and concluded. • Pressure-Test Investment Comparators. For TDFs, stable value funds and other specialized investments, confirm that benchmarks reflect objectives, glidepath or strategy, risk, asset allocation and structure. A namebrand index or higher-performing peer is not necessarily a meaningful comparator, but one may well exist even for a “custom” fund. • Review Independent Fiduciary Delegation and Monitoring (including PRT). Document the selection and monitoring of any independent fiduciary, the scope of its authority and the safeguards used to evaluate potential conflicts. • Align Forfeiture Practice With the Plan Document. Confirm that the plan document expressly permits the plan’s current use of forfeitures and that operations match its terms. Ambiguous language or inconsistent administration creates needless exposure to litigation. • Unbundle the “Package.” Whether the arrangement is a singleemployer plan, MEP or PEP,

identify and periodically evaluate direct fees, indirect compensation, revenue sharing and proprietaryproduct economics. •E xamine Litigation Provisions Carefully. Arbitration may remain available, but provisions that foreclose plan-wide statutory remedies face substantial judicial resistance. Fee-shifting provisions and litigation strategies should likewise be evaluated with counsel in light of developing circuit law. PC 1 Hensley v. Molson Coors Beverage Co. USA LLC Governance Committee, No. 2:25-cv-01371 (E.D. Wis. June 30, 2026). 2 J ohnson v. Quest Diagnostics Inc., No. 24-2866 (3d Cir. 2026). 3 Scholin v. Digi-Key Corporation et al., No. 0:26-cv01485 (D. Minn. filed Feb. 2026). 4B att et al. v. 3M Company et al., No. 0:25-cv-03149 (D. Minn.) 5O f course, surviving dismissal is not proving imprudence; it means only that the allegations, assumed true at that preliminary stage, permit discovery. Still, the case shows why leave to amend matters: a complaint lacking adequate comparisons may return with the missing details. 6 J ohnson v. Russell Investments Trust Co. et al., No. 2510692 (11th Cir. Aug. 17, 2026). 7 To date, most have targeted Athene, a private-equitybacked insurer. 8 Schoen et al. v. ATI Inc. et al., No. 2:24-cv-01109 (W.D. Pa. July 27, 2026). 9 T hole v. U.S. Bank N.A., 590 U.S. 538 (2020). 10 Dow et al. v. Lumen Technologies Inc. et al., No. 1:24-cv02434 (D. Colo. Sept. 1, 2026). 11 U.S. Department of Labor, Amicus Brief, Doherty v. Bristol-Myers Squibb Co., No. 26-1021 (2d Cir. filed July 21, 2026), https://www.dol.gov/newsroom/ releases/dol/dol20260721. 12 Piercy et al. v. AT&T Inc. et al., Report and Recommendation on Motions to Dismiss Plaintiffs’ Amended Consolidated Class Action Complaint, No. 1:24-cv-10608 (D. Mass. Aug. 31, 2026) (Levenson, Mag. J.). 13 Clark v. Centene Corp., No. 3:25-cv-09743 (N.D. Cal. July 17, 2026). 14 H owever, Lithia did not win everything. The complaint alleged that direct recordkeeping fees reached approximately $61 per participant in 2024, compared with $3 to $31 for three plans of similar asset and participant size. The court found those allegations sufficiently specific to support prudence and loyalty claims. It also allowed the related prohibited-transaction claim to proceed, rejecting the defendants’ arguments concerning party-in-interest status and the statute of limitations. 15 Ventura v. Lithia Motors, Inc., No. 2:26-cv-01786 (C.D. Cal. filed Feb. 20, 2026). 16 Berkelhammer et al. v. ADP TotalSource Group, Inc. et al., No. 2:20-cv-05696 (D.N.J. filed May 2020). 17 K han et al. v. Board of Directors of Pentegra Defined Contribution Plan et al., No. 7:20-cv-07561 (S.D.N.Y. filed 2020). 18 Pover v. The Capital Group Companies, Inc., No. 245298 (9th Cir. July 30, 2026). 19 McCalla et al. v. USI Insurance Services, LLC, No. 7:26cv-07691 (S.D.N.Y. filed Sept. 8, 2026). 20 Kelly v. Altria Client Services LLC, No. 25-2080 (4th Cir. 2026).

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MEET YOUR (SAVER’S) MATCH Here’s what to know about the 2027 change from Saver’s Credit to Saver’s Match. By Kevin Gaston

Last-minute facts! The Treasury just announced it will notify taxpayers who are eligible for the Saver’s Match if their income falls within the range. It’s 2001. Your flip phone just rang to “Hey Baby” by No Doubt, as you had just gotten off the line with MoviePhone to figure out when Shrek was playing. EGTRRA had just passed, and the Saver’s Credit was clearly on your mind. Fast forward: After 20-plus years of a challenging credit (requiring a filer to submit a full Form 1040, not EZ—rare in the income levels that the Credit covered), it has become a Match—one, with an easier form (8880-A), and for us, money coming to retirement plans vs. a check to the saver. We go live for tax year 2027. 401(k), 403(b), and 457(b) are all covered if the sponsor allows. The match: 50% of the first $2,000 contributed, capped at $1,000. Spouses filing jointly can each qualify. Unlike the credit, it doesn’t depend on tax liability: Treasury deposits it into the person’s retirement account even if they owe no tax. While I’m optimistic about the improvement (and hopefully greater uptake of the match vs. credit), I would still point out that for a single filer, that $1,000 applies only if you make a MAGI of just $20,500, and it plummets. Making just $28,000 drops the match down to $500, and it falls off completely at $35,000.

WHAT TO TELL PLAN SPONSORS TODAY: IT’S NOT COMING TODAY Earned in 2027, paid in 2028. You must make contributions by December 31, 2027. Participants claim the match on a new Form 8880-A (as yet unreleased) filed with their 2027 return, so there is nothing to worry about directly for more than a year. The statute says payment comes “as soon as practicable” after filing; I’d expect the first payments sometime in 2028. Claiming it will be harder than it sounds. Form 8880-A requires MAGI, filing status, qualified contributions, and any distributions. Distributions matter because they reduce the match base, including cash-out force-outs, which participants may not remember or even know about when they file. Participants must also designate a destination account, so expect questions from them about account numbers. Three paths to a plan are under consideration: • Registration Path: The plan or recordkeeper registers with Treasury. Treasury opens a conduit IRA and immediately rolls the match into the plan. • Automatic Match Path: The plan or recordkeeper shares plan and participant data, similar to autoportability, and pays the match directly to the plan. I don’t know how excited the industry will be about this one. • Rollover Path: The IRS issues

the participant a Saver’s Match Confirmation Number. The participant gives it to the plan, which supplies identifying information. Treasury then pays a conduit IRA, which rolls the money in. Only money paid directly by Treasury carries the special match rules. Anything arriving through a conduit IRA is treated as an ordinary rollover. This matters substantially read on! What if I only have Roth? The match can’t go into a designated Roth 401(k) or 403(b) account. Given the (as of now) low lift of Roth Employer Match / Non-Elective, I don’t think this will be an issue for workplace plans, though Auto-IRA states will definitely see this. Proposed Solution? The Treasury would pay a conduit traditional IRA and immediately transfer the money to the Roth IRA. That counts as a Roth conversion, so it is taxable and subject to withholding. Roth contributions still count toward earning the match, but the match must land in a pre-tax or traditional vehicle. The point that sponsors will care about most. The match is treated as an elective deferral. Sort of: It is excluded from deferral limits, ADP testing, nondiscrimination testing, and top-heavy testing. Great, so just toss it in the plan, under (k), and keep moving. Seems unlikely the same person who got the match

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saved up to the plan limit (remember that $24,500 is already in the match phaseout (!)), so no worries, right? Well - problem. Plans that allow hardships take heavy note; the rules are odd: • Money that comes in the plan as saver matches is barred from hardship or unforeseeable distributions, but it CAN be distributed as the emergency $1,000 or a federally declared disaster distribution. Somehow, this does not apply to the earnings, just the actual match source funds. • So, if a plan allows both hardship distributions and saver match payments, it will need a new source, and I can hear the collective groans from here.

• Sponsors may not have any additional work to do, but administrators or recordkeepers do.

AMENDING THE PLAN TO ADD THE SAVERS MATCH

Is a plan amendment required? Yes. Acceptance is optional. If a plan wants to accept the match directly, the plan must adopt a discretionary amendment. The deadline is generally the end of the plan year in which it takes effect operationally, so a calendar-year plan that starts in 2028 has until December 31, 2028, to amend. Plans can set reasonable conditions, such as limiting acceptance to active employees or participants with balances, and can later amend prospectively to stop accepting the

match without an anti-cutback problem. A plan that accepts rollovers doesn’t need an amendment to take conduit IRA rollovers. Plans must report the aggregate match received on Form 5500. Key Takeaways: The Saver’s Match is expected to drive greater lift and more participants actually to get it paid. It’s positive, and plan sponsors don’t have much more to do (aside from amending the plan) to get it going. From an administrator’s viewpoint, there is plenty to contend with (if the proposed guidance sticks as written), since it creates a new source and alters hardship availability with those nuances. However, we may get clarity before we see Treasury payments, which aren’t expected until 2028. PC

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IS YOUR TPA FIRM BUILT FOR WHAT COMES NEXT? There’s no single right path for a TPA firm. The goal is to keep good options open, whatever direction leadership chooses. By Lisa Kottler

TPA owners have more choices today than they did a decade ago. They can remain independent,

grow organically or through acquisition, bring in a partner, transition leadership to the next generation, join a larger organization, or eventually sell. These paths look very different, but they draw on many of the same underlying capabilities. How a firm is built and run today shapes how many of those paths stay open later, and whether the terms are favorable or forced. Consolidation has made some of these choices more visible. Private equity-backed platforms acquire TPAs, longtime owners are thinking about succession, and a newer generation of operators brings different expectations about technology and manual work. But the real question isn’t whether ownership intends to sell. It’s whether the business is ready for whichever path it eventually chooses — long before there’s a transaction, a succession conversation, or a compelling offer on the table.

WHAT MADE THE FIRM SUCCESSFUL IN THE FIRST PLACE

Many successful independent TPAs were built in a personal way. The owner knew the clients, and the clients knew the owner. Experienced staff understood each plan’s nuances and solved problems as they came up. Decisions were made quickly, service was responsive, and relationships mattered. These are real strengths, and they explain why many independent TPAs have lasted for decades. As firms grow, something begins to

change. Knowledge that once moved naturally through a small group has to become visible and usable across a much larger organization.

CARRYING THE BUSINESS FORWARD WITHOUT ONE PERSON IN EVERY ROOM

The people who run a TPA firm — whether that’s a single owner or a leadership team — usually know which clients are at risk, where margins are getting squeezed, and which relationships drive referrals. But could someone else understand the business without them in the room explaining how everything works? That question matters regardless of which path comes next. When outside partners, new leadership, or potential buyers enter the picture, they ask questions ownership has answered instinctively for years: where revenue comes from, which services are profitable, how much business is being lost, and which processes depend on one person knowing what to do. The questions aren’t complicated. What changes is the expectation that the answers live in the business itself, not only in the people running it. Running a good TPA and building one that can operate without its founding team are not automatically the same thing. A TPA can provide excellent service while still relying heavily on knowledge that lives in someone’s head. That works, sometimes for decades, until growth, a departure, an acquisition, or a leadership transition puts pressure on the model. Making

that knowledge visible doesn’t diminish the people who built it. It preserves what they built.

WHAT TECHNOLOGY IS ACTUALLY FOR

The best technology decisions start with the operating model you want to build, not with the tools themselves. Technology conversations in this industry often start with efficiency: how do we save time or automate a manual step? That’s worthwhile, but there’s more at stake, now that AI can take on tasks that once required one person’s memory. Good technology, AI included, should help a firm capture knowledge, improve visibility, and reduce how much depends on any one person. Two examples make this concrete. A TPA working across half a dozen or more recordkeeping platforms, each with its own format, often ends up entering the same data separately for each one. And plan-specific details — vesting schedules, hardship criteria, client workarounds — may live in one administrator’s memory rather than somewhere the team can check, so the work slows when that person is out. Both point to the same problem: information moving through people, not a repeatable process. This is exactly where AI is useful, not replacing an administrator’s judgment, but making what one person knows available to the whole team. The goal isn’t automating everything; it’s being deliberate about which activities require real expertise, so experienced people

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spend more time on the work clients value them for.

Yuganov Konstantin / Shutterstock.com

FIVE QUESTIONS WORTH ASKING NOW

TPA leaders don’t need a ten-year plan today. They do need to understand what choices their current operating model is creating or limiting. Here are five questions worth asking. What do I want this business to be capable of five years from now? The answer might be growth, continued independence, expansion into a new market, an acquisition, or running a larger business without leadership touching everything. The destination shapes what to build now. What makes this firm valuable, and where does that value live today? In the owner? In a few senior people? In client relationships, documented processes, proprietary knowledge, or culture? There isn’t one right answer, but it raises another question: which of those strengths are built into the firm, and which are still attached to specific people? Can I see the business clearly? Could you answer questions about revenue, profitability, retention, and capacity, without needing someone to assemble that information by hand? Senior leaders know the business well. The test is whether the business itself can produce that same visibility.

What still depends on individual effort because the underlying systems were never built to do it any other way? Spreadsheets and manual handoffs aren’t automatically a problem. But a process that worked fine at 200 plans can create very different problems at 1,000. How much of this business depends on particular people, teams, or locations holding knowledge that isn’t shared across the firm? This is a resilience question more than a succession question, and it can reveal where knowledge or authority has become too concentrated in one place.

PRESERVE WHAT SHOULD REMAIN PERSONAL

There’s a risk of making every successful business sound like it should run like a large institution. Independent TPAs often compete well because they’re personal, responsive, entrepreneurial, and close to their clients. Those qualities should be protected, not engineered away. The opportunity is to separate what should stay human and distinctive from what’s manual because the systems underneath it were never built to be anything else. Client history shouldn’t disappear when someone retires. Leadership shouldn’t have to reconstruct the economics of the business on demand.

BUILD BEFORE THE DECISION FORCES YOU TO

It’s hard to make thoughtful changes once circumstances make the decision urgent. The trigger could be anything — a buyer showing up, a key employee leaving, growth outpacing the business, or the next generation stepping up. Firms that build with the future in mind are in a far better position when those moments arrive.

A SIMPLE TEST FOR WHAT COMES NEXT

Before adding another tool or process, a simple test helps: •D oes it make important knowledge easier for the organization to access? •D oes it reduce unnecessary dependence on one person, team, or location? •D oes it give experienced people more time to use judgment where it matters? If the answer is yes, the technology is doing more than saving time — it’s helping build a TPA that can grow, adapt, and keep more choices open. There’s no single right path for a TPA firm. The goal is to keep good options open, whatever direction leadership chooses. A future-ready TPA should be built so leadership gets to choose what comes next. PC

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WHEN INSTITUTIONAL KNOWLEDGE WALKS OUT THE DOOR Personnel turnover is inevitable. The loss of institutional knowledge doesn’t have to be. By Patrick J. Griffin

Pam has been the retirement plan administrator for Big Manufacturing Corporation for 25 years. She is a benefits

rock star. She knows the employees, understands the retirement plans, and knows exactly where to find the information needed to keep everything running smoothly. Her documentation is meticulous. She knows where every amendment is located, stays current on regulatory changes, and keeps year-end testing and audits moving efficiently. But after 25 years, today is Pam’s last day at Big Manufacturing.

She’s retiring, and the company hasn’t hired her replacement yet. Pam’s retirement isn’t really the story. The story is what happens next. Because when a long-tenured administrator leaves, years of history, context, and operational knowledge can disappear overnight. How TPAs and auditors respond can make the difference between a smooth transition and a difficult compliance year. In situations like Pam’s, the departing administrator is often proactive enough to communicate before and during the transition and help position all parties for success.

Even with Pam’s efforts to ensure a smooth transition, the biggest loss is her 25 years of institutional knowledge about the organization, its plans, and its people. Her replacement will likely be learning the plan while balancing competing responsibilities. No one can fully replace Pam. However, because of her organization and preparation, the company should be able to navigate the transition with minimal disruption. But what happens when the same situation occurs at an organization without a dedicated plan administrator and with significant turnover? What

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FIVE STEPS TO TAKE WHEN A KEY PLAN CONTACT LEAVES

XiXinXingi / Shutterstock.com

Use the transition period to proactively preserve institutional knowledge and reduce disruption. if it is a fast-growing startup where the payroll manager became the accidental plan administrator and leaves unexpectedly? What if a merger, acquisition, or restructuring results in turnover among key finance or benefits personnel? These situations create significant risks for plan operational failures. They can also create major challenges for year-end compliance testing and make the audit process far more difficult and inefficient. Pam may leave notes regarding upcoming SECURE 2.0 deadlines. The payroll manager at the startup may leave little documentation and may lack governance or oversight processes that help identify risks before they become problems. Auditors often rely on SALY, “same as last year.” When a key administrator leaves, however, new contacts, new relationships, new controls, and often a loss of planspecific expertise can create challenges. However, they also present a tremendous opportunity to add value. In some cases, the TPA and auditor may know more about the plan’s history than anyone remaining at the organization, making them a critical resource during the transition. That knowledge can help bridge the gap and give a new plan administrator confidence in areas where they are still learning. The TPA may know exactly where the prior year’s census data originated. The auditor may know who prepared specific items provided during the prior year’s audit and where they obtained supporting documentation. Both likely maintain permanent files and may have documents the new contact cannot locate. They may have the amendment no one can find, understand the status of a prior DOL inquiry, know who processes payroll remittances, or remember an unresolved VCP filing.

1. Meet Early: Schedule an introduction meeting with the incoming administrator and, if possible, the departing contact. 2. Review Upcoming Deadlines: Discuss outstanding compliance requirements, testing milestones, audit requests, and open action items. 3. Share Key Documents: Provide important plan documents, amendment histories, procedures, and reference materials. 4. Document Critical Processes: Identify who handles payroll remittances, census generation, approvals, and other key operational responsibilities. 5. Increase Communication: More frequent communication during the first several months can help the new contact get up to speed and avoid preventable issues.

TPAs and auditors often become the de facto historians of a Plan. Over years of servicing an engagement, they accumulate documentation, correction history, operational knowledge, and institutional context that can be invaluable during a transition. Helping a new plan administrator understand these historical events and responsibilities can significantly accelerate their path to success. This level of support requires additional effort from the TPA and auditor. However, proactive planning and guidance not only improve the efficiency of compliance testing and the audit process but also demonstrate meaningful value by reducing the stress and uncertainty that often accompany personnel turnover. They can also help mitigate client retention risk. Significant personnel changes are often the periods when service-provider relationships are reevaluated. One of the best ways to facilitate a transition is for the TPA, auditor, advisor, and incoming contact to meet early and align responsibilities, priorities, and support needs. Timing is critical. The meeting is most effective when held before Pam leaves and while compliance testing and audit

activities are still underway. This allows the incoming administrator to receive practical, real-time training and gain familiarity with the Plan. Even when the former contact is no longer available, a coordinated meeting among service providers sends an important message: the plan sponsor is not alone. It demonstrates that the TPA, auditor, and advisor are not operating as siloed service providers completing individual tasks. Rather, they are partners working together to support both the new contact and the retirement plan. By getting ahead of the situation, TPAs and auditors demonstrate engagement, responsiveness, and partnership from day one. More importantly, they can help reduce stress for someone stepping into a role that may not even be their fulltime responsibility. The year a key administrator leaves is often the year a service provider’s value is tested. Clients rarely remember who completed testing the fastest or issued the audit report first. They remember who helped them navigate uncertainty, reduced stress, and provided guidance when they needed it most. Personnel turnover is inevitable. The loss of institutional knowledge doesn’t have to be. PC

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WE’LL SEE YOU IN SAN ANTONIO! The spirit of ’66 lives on at the upcoming ASPPA Annual as the profession continues to shape the future. By Plan Consultant Staff

It’s time (almost) to celebrate 60 years of bold thinking, leadership, and innovation at ASPPA Annual!

We’re heading to San Antonio, Texas, in October to join retirement plan professionals from across the industry to explore the regulatory, operational, and technological changes driving what comes next. We’ll gain insights from Washington and industry agencies, discuss the growing impact of AI and workforce evolution, and build the knowledge, connections, and skills that will define tomorrow’s retirement solutions. The spirit of ’66 lives on as the profession continues to shape the future, and “Bold Since 66” (1966) is the tagline, something the branding and design reflect: a retro look back to a time of far-out fashion, groovy music, and a summer of love.

It will feature 36 workshops, six general sessions, 10 preconference sessions, and a Qualified Pooled Plan Professional™ (QP3™) Exam Cram. And don’t forget the TPA Growth Summit (like anyone could). It’s designed for TPA firm owners, senior leaders, and sales and marketing professionals ready to lead with bold ideas and build what comes next. We’ll explore new approaches to business development, firm strategy, client relationships, and long-term growth alongside peers shaping the future of the profession,” organizers explain. “Experience powerful conversations and new perspectives alongside industry peers who are focused on creating stronger, more forward-thinking firms.” Preconference activities include a Qualified Pooled Plan Professional™ (QP3™) Exam Cram with ASPPA’s own Kizzy

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Gaul and the always popular TPA Growth Summit, featuring topics like “Build the Leader: Build the Team,” featuring ASPPA Annual Keynote Speaker Lane Monson, as well as Megan Crawford, Shannon Edwards, Chad Johansen, and JJ McKinney. Amanda Iverson, Melissa Terito, Emily Minnich, and Blake Willis tackle “Building the Right Team Around the Right Work.” Specific preconference sessions include “Fiscal and Short Plan Years: What Plan Sponsors and Practitioners Need to Know,” “Designing and Administering In-Plan Roth Conversions: Strategy, Structure and Best Practices,” and “Passing the Torch: Developing the Next Generation of Actuaries.” These (and many more) sessions lead into the highly popular “Washington Update” with American Retirement Association leaders Brian Graff, Kelsey Mayo, and Josh Oppenheimer. The first day closes with a chance to relax and mingle with attendees, sponsors, and exhibitors at the President’s Welcome Reception in the exhibit hall. Day 2 opens with morning workshops on Cycle 4 plan restatements as well as plan administration fiduciary issues. Kizzy and ARA’s Robert Richter hit the stage for their retirement plan current events general session. That afternoon features Megan Crawford, Amanda Iverson,

and ARA’s Senior Director of Digital Marketing, Joey SantosJones, in “Thriving as a Human in an AI World.” That afternoon’s general session continues the futuristic theme with “AI and the Future Retirement Professional.” Day 3 starts with an EPCRS deep dive and a look at cybersecurity and retirement plans, specifically around fiduciary exposure and best practices. Justin Danhof, Director of Policy at the Department of Labor’s Employee Benefits Security Administration (EBSA), joins Brian Graff and Kelsey Mayo for an important government update. Roth catch-up contributions, hot topics in litigation, and advanced testing techniques for qualified plans are the afternoon’s focus, before ending with the always fun and theatrical “Haunted Pension Escape Room.” The Grotto at the Convention Center will host “ASPPA at Night,” with a Cosmic Cowboy theme. Attendees are invited to dress in their favorite groovy 60s attire or western wear. We’ll be celebrating 60 years of ASPPA with a dance floor, lounge space, and some extra special touches. If past years are any indication, it’ll be the best ASPPA Annual yet! PC

f11photo / Shutterstock.com

WINTER2027

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STRATEGIES FOR SUCCESSFUL REMOTE ONBOARDING AND TEAM BUILDING Investing in connection builds a cohesive, supportive team, boosting morale, productivity, and returns. By Jenn Taylor

looks different than when everyone is in an office together. While being together is ideal, it’s not always an option. In this article, I will cover strategies for successfully onboarding remote new hires and then explore how to plan and promote team building when employees are either fully remote or a mix of remote and in-office. The goal is to empower employers to create a successful onboarding and team-building experience that results in happier, more connected employees who want to stay with the firm for long-term success and career development. The work environment changed in 2020 because of the worldwide pandemic and its social impacts; those repercussions are still felt today. While some organizations are embracing the office again, many continue to employ remote workers or have moved to a hybrid setup. Bridging the disconnection gap for new hires who may be remote workers on a remote team is important to build a fully

connected team that works together, problem-solves together, and supports one another for long-term team and company success.

STRATEGIES FOR ONBOARDING REMOTE NEW HIRES

With a new hire, it’s important to capture their fresh enthusiasm and excitement for their new role and firm they are joining. There will be a lot of unknowns, but the interest in learning and getting to know their team is at its peak. To make the most of that enthusiasm, their first few weeks should be full of activity, training, learning, and team building. In my experience, system access requests for platforms, applications, and learning resources are often the priority, since it’s hard to train or follow along if the new hire can’t use any programs or applications. Many learners are hands-on, and when they can follow along, they’ll likely learn faster and remember what they’re seeing and doing. Depending on the organization, access requests could begin the week before the hire date, or it may have to be the focus of the first week.

DC Studio / Shutterstock.com

In a world where remote new hires are now common, onboarding and integrating them into a team

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Moreover, beyond access requests, daily check-ins can help verify access, guide the new hire on how to log in, and explain how they may use those applications in the future. Of course, you shouldn’t expect the new hire to remember everything the first time they hear it, but this can start the repetition they should experience throughout the first few weeks as they continue onboarding. Beyond the access the new hires will need, I’ve found it important to design dynamic training agendas for their first few weeks or months of employment, sending the message – “We are excited to have you; we have so many things planned for you! We want to get you off and running with everything you need!” As a former trainer, I always designed agendas with a set routine, such as a scheduled lunch break and, depending on company policies, set morning and afternoon break times. Aside from that, their time is spent on assigned activities, training, job shadowing, or downtime for learning consolidation, note-taking review, etc. As part of the onboarding agenda, some organizations may offer the opportunity to create and use pre-recorded or asynchronous learning material. Additionally, it can be beneficial to include training or shadowing sessions with teammates who are subject matter experts, as the new hire will learn relevant topics and processes for their role while also meeting and bonding with a teammate. When job shadowing, I usually encourage new hires to ask their teammates how they organize their day, set priorities, and manage their time. Each teammate may have a different approach the new hire can learn from. If they’re not training or shadowing, the new hire can also be tasked with a one-on-one call with teammates they haven’t had the chance to meet. They can be given specific questions to ask, such as tips for a new hire, what kind of tasks they handled that day, or what their experience has been like. Schedule similar check-in conversations with management or their supervisor, as this is also a good opportunity to troubleshoot access if needed, review what the new hire has learned so far, share observations, and set or manage expectations. Another helpful strategy during onboarding, and one that can extend to long-term team building, is to assign a team mentor or peer buddy who can guide them at the start and continue supporting them long term. Lastly, software and application tools at our fingertips can bridge gaps virtually and drive connection, such as a Teams chat or channel. Adding a new hire to these forums during onboarding helps them connect with the team immediately and interact with colleagues—whether remote, in office, or hybrid. Teams or similar platforms can also be used for joint viewing of a town hall and shared participation. You can set up dedicated channels or group chats for shared experiences. Breakout rooms offer opportunities for small group activities.

Using platform polls or free third-party polling tools also gives teammates opportunities to vote, answer questions, and engage in meetings & discussions in a different way. There are also other tools like SharePoint, Viva Engage, and Mentimeter.

STRATEGIES FOR REMOTE & HYBRID TEAM BUILDING

Best practices start during onboarding, but initiatives should continue over time, and for those who have already been on the team. It’s never too late to implement new tools and practices if the organization doesn’t already have them established. If the team is not already closely connected, or if there is a large group of new hires, they may benefit from an IceBreaker activity, or a “Get to Know You” activity. An IceBreaker may seem like it’s just for fun; however, the deeper purpose is human connection and learning something about teammates beyond their work skills. The more connected our teams feel and the stronger their bond, the more positivity comes from time spent working together and helping one another. If the team truly feels like a team, they will support each other, and the organization as a whole will experience success and growth. Ice-Breaker activities can be hosted via an online or hybrid setup with the organization’s software of choice – Teams, Webex, Zoom. They can involve trivia about teammates, polls to answer questions, bringing something to show via video, pictures in the chat, or a round-robin with one-minute answers. These activities can be long or short and can easily be incorporated into a regular team meeting. Team-building activities go beyond an icebreaker because they generally include a lesson such as the value of communication, teamwork, problem-solving, working with our strengths, or proactive listening. Again, these can be conducted in a virtual or hybrid setup. Breakout rooms could be used for pairs or small groups to work on something to bring back to the whole group for discussion. Another idea is to assign small groups to work on a presentation or training to present to the team during a meeting. You could also set aside time for teammates to share “kudos” for another teammate who helped them. While this article focuses on onboarding and teambuilding with remote employees, bringing the team together in person is a great opportunity. However, since that is not possible for every team or in every situation, I strongly encourage employers, managers, and team leaders to think creatively about how to engage their team through interactive experiences and activities using available platforms, ensuring everyone is involved and feels connected. Investing in connection builds a cohesive, supportive team, boosting morale, productivity, and returns. PC

Fall Exam Thursday, November 12 Deadline to purchase Exam: November 11