PLANADVISER - Summer 2023 - 30

Roundtable
back and forth [in terms of hours worked]? So there are
several open questions.
There are also many questions on the mandatory Roth
catch-ups for the higher-income people. ... Some plans don't
have a Roth money type. Well, they need to add it and to
implement the catch-up-there are a lot of questions on
that, as well as, " Can you mandate that all catch-ups are
Roth? " That question keeps coming up. That's got to be an
IRS answer. I don't think the statute or the regs get you to
" yes " right now.
Then the third area where we're getting a lot of interest
or questions is the provision about matching in the 401(k)
plan, the student loan repayments. One question that comes
up with almost every committee I talk to: " What about the
student loans I have for my kids? Does it have to be the
tion was posed. Right now, it's this giant black hole, about
which the people who administer these plans are thinking,
" How in the world do we do all this? And will my provider
be able to do this? " -whether it's the payroll provider or
the recordkeeper. I think the feeling, in general, in the HR
circles is, " Oh, man, there's one more thing I have to be
responsible for, and if it's not going to be me, can the other
ones really do it? "
I think, long term, some questions could arise in HR
circles as to, " Well, OK among the companies I compete
with in the market for employees, for staff, if they add
these benefits and I don't, will our benefits package still be
attractive? " I think that's a long-term question. I can see
the HR person saying, " Now, do I have to do this for retention
and recruitment, or can I get away with not doing it? "
I'm not at all saying that HR folks
" Right now, it's this giant black
hole, about which the people
who administer these plans are
thinking, 'How in the world do we
do all this? And will my provider
be able to do this?' " SEND
student? I have the loans; I'm on the hook. " I don't think we
have an answer. I can read the statute to say, " Yes, those
would count. " But then I read the legislation history, and it
doesn't really seem like that was the intent. So I don't know
the answer, and I think we need guidance on that. Those are
three about which I'm definitely getting the most questions.
McPherson: We've had lots of questions on catch-ups, on
the Roth mandates, on the long-term/part-time workers,
and on how onerous many of the administrative duties
related to these provisions are going to be. Even some sponsors
trying to think through whether they need to hire some
additional folks in their HR department. ... The other thing
that's come up is whether their payroll provider can accommodate
some of the functionality they'll need because of
provisions they'll be adding; there is much consideration on
that front, as well. Will they need to reevaluate providers
and add that to their list of time-consuming and administratively
onerous functions right now?
Send: That's exactly what I thought of when this quesdon't
want to offer state-of-the-art
benefits, but I do think that's a natural
outcome of feeling like this is an awful
lot of work for them to take on.
PA: Those are some pain points that
need further clarity. How about the
areas you're excited about and see
potential to increase retirement
savings nationally?
McPherson: I'm excited about the
automatic portability provision and
the consortium that's been created
in the market to support that. I
think it's really great that we've seen
some major recordkeepers working together to keep more
assets in qualified plans, which ultimately speaks to all of
our goals, which is helping people be ready for retirement
however that's defined for them. Any features that make it
easier for individuals to contribute, and that increase the
amounts they can contribute, are amazing. Then, anything
that helps you track it or allows it to follow you-like the
DOL [Department of Labor] lost and found, and these things
coming into play that not only help to increase participation
and the amount people are saving, but also help to
prevent those assets from coming out, or just make it a lot
easier for individuals to keep track of their accounts-is
really beneficial.
Send: One thing I think is a really good, though probably not
a key, provision is the fact that now there will be a mandate
to at least do an occasional paper statement. It's really so
important, since we meet with so many participants who
say, " I used to work at ABC company, 20 years ago, and,
gosh, I thought I saved in its plan, but I have no idea where
that money is. " ... You really hope that that will reduce the
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PLANADVISER - Summer 2023

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