WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more
Contingent deferred annuities (CDAs) represent an interesting approach to securing lifetime income but have struggled for recognition in the marketplace since their introduction more than a decade ago. Recent developments,...more
The first two district court opinions deciding whether plaintiffs have Article III standing to challenge pension risk transfers have reached opposite conclusions. One case will proceed to discovery, and the other has been...more
The recent rule and form amendments adopted by the SEC to facilitate the registration of registered index-linked annuities (RILAs) and market-value adjustment annuities (MVAs) on Form N-4 have been broadly welcomed by the...more
The stay of the effective dates of the amended fiduciary regulation and amended exemptions means that the “old” DOL fiduciary regulation (the 5-part test) and the existing exemptions continue in effect indefinitely. As a...more
The stay of the effective dates of the amended fiduciary regulation and amended exemptions means that the “old” fiduciary regulation (the 5-part test) and the amended exemptions continue in effect indefinitely. As a result,...more
The DOL’s fiduciary regulation was scheduled to become effective this September 23. The exemptions were scheduled to become partially effective this September 23 and fully effective September 23, 2025....more
The Department of Labor’s final regulation defining fiduciary status for investment advice to retirement investors will be effective this September 23. Where a fiduciary recommendation results in additional compensation for...more
On April 25, 2024, the Department of Labor published its final regulation defining fiduciary status for investment advice and the related exemptions—PTE 2020-02 and 84-24. The exemptions provide relief from prohibited...more
Over the last several years, numerous large pension plan sponsors have transferred billions of dollars in financial risk related to their pension plan benefit obligations to insurance companies through the purchase of group...more
As recently noted by the US Department of Labor (“DOL”), since the passage of the Employee Retirement Income Security Act of 1974 (“ERISA”), “the retirement plan landscape has changed significantly, with a shift from defined...more
We recently posted some advice related to retirement planning and the need to take pen to paper (fingers to keyboard?) to make realistic assessments of future needs and available resources. And, because this is a divorce...more
The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more
The DOL has not appealed the decision in the Florida Federal District Court that vacated its fiduciary “re-interpretation.” That re-interpretation, in effect, said that ongoing investment advice to a rollover IRA could be...more
I always say a retirement plan provider needs to find its niche to stand out in the retirement plan marketplace. A new firm, Annuity Research & Consulting, has been created to help 401(k) retirement plan sponsors and their...more
SECURE 2.0, which was included as part of the Consolidated Appropriations Act of 2023, was signed into law in late December 2022. The statute contains 92 substantive sections making reforms to a broad array of...more
There has been a push to add annuities to retirement plans, but I don’t see it gaining ground. According to Alight, plan sponsors are hesitant to add it, which was part of the 2019 SECURE Act. ...more
This is an odd topic for a family law blog until I started to think about. Today’s on line Marketwatch website featured an article by Chris Farrell about whether retirees should consider rolling assets from defined...more
When it comes to plan design, I believe in the idea of KISS: keep it simple, stupid....more
The Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”) amended ERISA to require ERISA-covered 401(k) and other defined contribution plans to provide two estimated lifetime income (annuity)...more
With a push for fixed income products, there is n shock that BlackRock is putting annuities in American workers’ 401(k)Plan....more
Lifetime Income Disclosure Requirement. The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), enacted December 20, 2019, added a new annual disclosure requirement for benefit statements to...more
Earlier this year, we discussed the lifetime income disclosure requirement that was included in the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). When the disclosure requirement becomes...more
The SECURE Act of 2019 made three statutory changes to ERISA regarding lifetime income benefit payments from defined contribution plans (e.g., 401(k), 403(b), profit sharing, and money purchase pension plans). This blog will...more