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ESOP Rebalancing

“One of my clients with an Employee Stock Ownership Plan (ESOP) asked about a true up provision in his plan. What is an ESOP true up provision?”

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with an advisor in Illinois is representative of a common inquiry related to an ESOP.

Highlights of Discussion

I believe what your client is referred to is a “rebalancing” provision in the ESOP. Rebalancing is the periodic mandatory transfer of employer securities among participant accounts, resulting in all participants having the same proportion of employer stock to other investments as in the ESOP trust as a whole (see this 2010 IRS Memorandum for more details). For example, if the ESOP was invested 70 percent in employer stock and 30 percent in other investments, after rebalancing, each participant’s ESOP account would be invested 70 percent in stock and 30 percent in other investments.

Rebalancing usually happens at the end of the plan year and does not affect the face value of an ESOP participant’s account balance. According to the IRS’s, Listing of Required Modifications for ESOPs, “rebalancing, which treats all participant accounts the same, will not raise issues of current or effective availability and is generally acceptable.” Rebalancing is different than “reshuffling,” which will be covered in a future Case of the Week.

For an ESOP to be able to perform rebalancing it

  • Must hold cash and
  • The plan document must include an annual rebalancing provision.

An example of where rebalancing may come into play might be in a mature ESOP that has allocated all of its shares to its employees and begun contributing cash into the accounts of new employees. Without rebalancing, the new ESOP participants would not be shareholders in the ESOP.


Rebalancing is the mandatory transfer of employer securities into and out of the accounts of ESOP participants, usually on an annual basis, designed to result in all participant accounts having the same proportion of employer securities. In order to rebalance, the plan document must have specific language permitting rebalancing.

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EBSA Spring Regulatory Agenda

On June 13, 2023, the Department of Labor (DOL) released its Spring regulatory agenda, including initiatives for the Employee Benefits Security Administration (EBSA), the subdivision responsible for employee benefit plans. According to the agenda, we can expect to see the following releases throughout the remainder of 2023.

DOL/EBSA Prerule Stage Improving Participant Engagement and Effectiveness of ERISA Retirement Plan Disclosures 1210-AC09
DOL/EBSA Prerule Stage Pooled Employer Plans 1210-AC10
DOL/EBSA Prerule Stage Emergency Savings Accounts Linked to Individual Account Plans 1210-AC18
DOL/EBSA Prerule Stage Plan Reporting for Retirement Savings Lost and Found 1210-AC19
DOL/EBSA Prerule Stage Worker Ownership, Readiness, and Knowledge 1210-AC20
DOL/EBSA Prerule Stage Exemption for Certain Automatic Portability Transactions 1210-AC21
DOL/EBSA Prerule Stage Review of Pension Risk Transfer Interpretive Bulletin 95-1 1210-AC22
DOL/EBSA Proposed Rule Stage Adoption of Amended and Restated Voluntary Fiduciary Correction Program 1210-AB64
DOL/EBSA Proposed Rule Stage Improvement of the Form 5500 Series and Implementing Related Regulations Under the Employee Retirement Income Security Act of 1974 (ERISA) 1210-AC01
DOL/EBSA Proposed Rule Stage Conflict of Interest in Investment Advice 1210-AC02
DOL/EBSA Final Rule Stage Amendment of Abandoned Plan Program 1210-AC04
DOL/EBSA Final Rule Stage Prohibited Transaction Exemption Procedures 1210-AC05
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QDIA – Looking Beyond Target Date Funds

Auto-enrollment has emerged as an effective way to drive 401(k) plan participation. As a result, the importance of a plan’s default investment has increased significantly. Currently, target date funds are the leading default investment alternative for 401(k) plans. According to Plan Sponsor Council of America’s 65th Annual Survey, 87 percent of a plans with a QDIA use Target Date Funds (TDFs) as their default investment. TDFs have become the “easy button” when it comes to default investments, but there are other default investment types that could be a more prudent fit for plans and should be considered.

Prior to passage of the 2006 Pension Protection Act (PPA), most sponsors, out of an abundance of caution, defaulted investment to either a money market fund or a guaranteed investment contract (GIC) – so as to ensure that participants who had made no affirmative choice as to how to invest their money (or even as to their plan contribution rate) didn’t lose anything.

Dissatisfied with this ultra-cautious approach, Congress, in the PPA, instructed the Department of Labor to develop regulations “on the appropriateness of designating default investments that include a mix of asset classes consistent with capital preservation or long-term capital appreciation, or a blend of both.” Those regulations, finalized in 2007, provided that sponsors would be protected from fiduciary risk if participant contributions were defaulted to one of three “qualified default investment alternatives” (QDIAs):

  • “Target maturity-type” funds, defined as “an investment fund product or model portfolio that applies generally accepted investment theories, is diversified so as to minimize the risk of large losses and that is designed to provide varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures based on the participant’s age, target retirement date (such as normal retirement age under the plan) or life expectancy.”
  • “Balanced funds,” subject to the same general rules as “target maturity-type” funds except that the asset mix did not consider an individual participant’s age but only the demographics of the participant group as a whole.
  • Individualized “Investment management services.”

Since 2007, TDFs (as “target maturity-type” funds are now called) have emerged as the go-to 401(k) plan default fund.

Too often, however, sponsors and their advisers opt for a generic TDF design that focuses only on two asset classes – US large cap (as the “higher risk” asset class) and US investment grade fixed income (as the “lower risk” asset class). And the TDF’s glide path design simply forces (for a given age cohort) a mechanical stock/bond split between these two asset classes, depending on the participant’s age cohort or target retirement age.

The result of all this is multiple age-based investment “buckets” and an investment design that manages to be both overly simplistic and overly complicated. This simplistic, two-asset class approach often does not reflect, for example, fixed income duration risk or inflation effects. More critically – as with most passive investment approaches – it ascribes a simple, binary risk factor to the two as classes, without adjusting for, e.g., increases/decreases in stock or interest rate market volatility. Finally, most TDFs have very limited diversification within the two risk-on/risk-off asset classes – there is, for instance little exposure to non-US securities.

All of this worked when – as was the case since 2008 and until very recently – US interest rates remained at historic lows, and US markets outperformed the alternatives. But as interest rates have risen and the rally in US markets has “paused,” the value of diversification as a hedge in down markets has become clear. It is time to think more deeply about risk, as something other than stocks vs. bonds or simply passively accepting large cap beta. Critically, it’s time to think about risk as not just involving interest rates and stock markets but also the effects of inflation.

In that context, there may be a better default investment solution than the typical TDF. With most 65-year-olds living well into their 80s – the “power” of adjusting risk based on age may be overrated. And TDFs’ dumbed down view of risk as a simple function of binary fixed percentages of stocks vs. bonds may be inadequate to the current situation.


As an alternative, it’s time to look beyond TDFs to another QDIA option – a balanced fund – run on traditional (and “generally accepted”) investment principles, with a diversity of investments – very much including non-US investments – and with an active concern for what is an appropriate investment in choppier markets. Instead of the faux-science of a (somewhat artificial) age-based investment horizon, a balanced fund that seeks long-term appreciation while seeking – through a diversity of investment classes – to minimize the risk of large losses. It’s a QDIA that is both more intuitive and more adapted to a variety of market conditions.

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Q2 2023 Regulatory Update

Current Status of ESG and Proxy Voting Regulations

The Environmental, Social and Governance (ESG) and proxy voting rules for qualified retirement plans have been a controversial issue for Democrats and Republicans. As of March 2023, the (Biden) Department of Labor’s (DOL’s) 2022 revision of the (Trump) DOL regulation stands. Consequently, fund managers for ERISA plans may include ESG considerations in the investment process for plans, and plan fiduciaries may consider climate and ESG factors when exercising shareholder rights, such as in proxy voting. However, if such factors are considered, they must be based on issues that the fiduciary reasonably determines are relevant to a risk and return analysis.

As background, in March 2023, Congress passed a Congressional Review Act resolution that would have voided the (Biden) DOL’s 2022 ESG investment rule for retirement plans. President Biden, subsequently, vetoed that resolution; and Congress failed to over-ride his veto.

IRS Proposes Stricter Rules for Use of Plan Forfeitures

The IRS is calling for stricter guidelines on the use of plan forfeitures. On February 24, 2023, the IRS issued a proposed regulation regarding the use of forfeitures in defined benefit and defined contribution plans, including 401(k) plans. A public comment period on the proposed rule ended May 30, 2023, with a scheduled effective date for plan years beginning on or after January 1, 2024. However, plan sponsors may rely on the proposed rule immediately.

Under the proposed guidance as currently written, plan sponsors must use forfeitures incurred under a defined contribution (DC) plan within 12 months following the close of the plan year in which the forfeiture arises.  Further, such forfeitures may only be used to

  1. Pay plan administrative expenses;
  2. Reduce employer contributions under the plan; or
  3. Increase benefits in other participants’ accounts in accordance with plan terms.

The regulation provides transition relief for forfeitures that arise in any plan year beginning before January 1, 2024. Those prior forfeitures will be treated as if they arose in the first plan year that begins on or after January 1, 2024. As a best practice, plan sponsors should consider reviewing the forfeiture provisions in their retirement plans for any necessary updates (e.g., to include all three acceptable usages so that all forfeitures can be used up within the required 12-month period).

IRS/DOL Changes Participant Count Rules for Form 5500 Audits

On February 24, 2023, the Department of Labor (DOL), IRS and Pension Benefits Guaranty Corporation (PBGC) published final Form 5500 forms and instructions applicable for plan years beginning on or after January 1, 2023. Simultaneously, the DOL issued final regulations in support of those forms and instructions. For more information, please see the final regulations for Annual Reporting and Disclosure.

The DOL requires sponsors of employee benefit plans subject to the annual Form 5500 series of returns and schedules to include an audit report from an independent qualified public accountant (IQPA). There is an exception to this requirement under DOL Reg. 2520.104-46 for “small plans” (i.e., those with fewer than 100 participants at the beginning of the plan year). The current rules, applicable for the 2022 Form 5500 filing, count individuals who are eligible to participate even if they have not elected to participate and whether they have an account in the plan or not.

For plan years beginning on or after January 1, 2023, participant count for the audit waiver will be based on the number of participants and beneficiaries with account balances at the beginning of the plan year. This change is intended to reduce the number of plans that need to have an audit, lower expenses for small plans and encourage more small employers to offer workplace retirement savings plans to their employees. Note that a plan may qualify for the audit waiver even if there are more than 100 participants under the “80 to 120 Participant Rule.” This rule states if the number of participants covered under the plan as of the beginning of the plan year is between 80 and 120, and a small plan annual report was filed for the prior year, the plan administrator may elect to continue to file as a small plan and, therefore, qualify for the audit waiver.

Key Considerations in Plan Lawsuits from the Seventh Circuit Court Decision

A recent Seventh Circuit Court decision, upon remand from the U.S. Supreme Court, articulated a set of considerations that could prove useful both for retirement plan plaintiffs contemplating lawsuits and plan fiduciaries wishing to avoid being sued. In January 2022, in Hughes v. Northwestern University, 142 S. Ct. 737 (2022), the Supreme Court vacated a 2020 Seventh Circuit decision for defendants in an ERISA prudence case involving two 403(b) plans, remanding the case to the Seventh Circuit for further consideration. On March 23, 2023, the Seventh Circuit handed down its decision in this litigation, siding with plaintiffs on the issues of recordkeeping fees and the selection of retail share classes. Key takeaways include the following items.

  • Generally, quoting the court: “To plead a breach of the duty of prudence under ERISA, a plaintiff must plausibly allege fiduciary decisions outside a range of reasonableness.” That is probably the best one-sentence explanation of how to think about these issues.
  • With respect to recordkeeping: While a fiduciary has no duty to “constantly solicit quotes for recordkeeping to comply with his duty of prudence with respect to plan expenses, … a fiduciary who fails to monitor the reasonableness of plan fees and fails to take action to mitigate excessive fees may violate the duty of prudence.”
  • The use of retail share classes remains a significant vulnerability, and justifications for their use (e.g., higher quality services, attractiveness for small accounts, lack of availability of institutional share classes, or a better revenue sharing deal) may not be considered on a motion to dismiss.
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Q2 2023 Legislative Update

FY 2024 Budget Includes Proposed Modifications to Retirement Plans

On March 9, 2023, the Administration released its Fiscal Year 2024 Budget. The related General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals included a description of “modifications to rules relating to retirement plans” consistent with, for the most part, proposals that were, at one point, part of the Administration’s 2021 “Build Back Better” proposal. These include a proposed $10-$20 million cap on retirement account accumulations, plan sponsor reporting on account balances of more than $2.5 million, and the elimination of certain “Roth conversions,” for certain high-income taxpayers (e.g., joint filers with income over $450,000). While action on these initiatives is not expected this year, targeting large retirement account balances has some populist appeal, has had the support of a number of policymakers for some time, and is likely to persist beyond the next election.

More State-Mandated Plans in Sight for Businesses Without Retirement Plans

Minnesota, Missouri and Vermont have become the latest states to pass legislation mandating state-sponsored retirement plans for employees without access to plans in the workplace. Most states have at least considered offering state-sponsored retirement plans, with 10 states having active programs. Only four states are hold outs: South Dakota, Alabama, Florida and Alaska. But businesses without a retirement plan do not need to be forced into an ill-fitting, state-mandated plan considering the new and enhanced plan designs available, plus increased plan startup tax credits for those firms that qualify. See RLC’s Case of the Week Sweeter Deal Awaits Small Businesses When Starting a Workplace Retirement Plan on plan startup tax credits.

Retirement Savings for Americans Act (S 5271) Would Create Government-Run Plan

Congress is poised to re-introduced a bill similar to the Retirement Savings for Americans Act (S 5271) of 2022. If the bill is resurrected for 2023, it would establish a new savings program, “The American Worker Retirement Plan” (AWRP) that would give eligible workers access to federally-sponsored, portable, tax-advantaged retirement savings accounts. Key features of the AWRP are described below.

  • Available to full and part-time workers without access to an employer-sponsored retirement plan.
  • Automatic enrollment at 3% of income, with the ability to increase or decrease the deferral rate or opt out.
  • Independent workers would also be eligible.
  • Low- and moderate-income workers would be eligible for a federal 1% automatic contribution (as long as they remain employed) and up to a 4% federal matching contribution via a refundable federal tax credit, phased out for those with income above certain levels.
  • Accounts would remain attached to workers throughout their lifetimes, and workers would be able to stop and start contributions at will.
  • The accounts would be the property of the worker and the assets could be passed down to future generations to help them build wealth and financial security.
  • Participants would be given a menu of simple, low-fee investment options to choose from, including lifecycle funds tied to a worker’s estimated retirement date, or index funds made of stocks and bonds.

While the provisions in the bill have bipartisan support, there is some skepticism in the industry as to whether a government-run retirement savings plan would be in the best interest of investors. Even more reason for business owners who do not offer a retirement plan to consider sponsoring their own workplace retirement plans now, before a federally-mandated plan takes form.

Bill Would Allow 403(b)s to Invest in CITs

The newly introduced Retirement Fairness for Charities and Educational Institutions Act of 2023 (HR 3063) would amend current securities laws to fully clear the way for 403(b) plans to invest in collective investment trusts (CITs). The SECURE Act of 2022 amended tax laws in the Internal Revenue Code to allow 403(b) plans to use CITs but stopped short of making similar accommodating changes to securities laws. The bill has been referred to the House Committee on Financial Services.

Changes to Key Retirement Policy Congressional Committees

In the Senate, Bernie Sanders (I-VT) has taken chairmanship of the Senate Health, Education, Labor, and Pensions (HELP) Committee from Patty Murray (D-WA). Dr. Bill Cassidy (R-LA) is now Ranking Member. We note that longtime committee member and retirement policy advocate Rob Portman (R-OH) has retired and that his bi-partisan partner in many retirement policy initiatives, Ben Cardin (D-MD), has announced his retirement at the end of his current term. Senators Ron Wyden (D-OR) and Mike Crapo (R-ID) will continue as Chairman and Ranking Member of the Senate Finance Committee.

In the House, Rep. Virginia Foxx (R-NC) has taken over as Chairwoman of the House Education and the Workforce Committee, and Bobby Scott (D-VA) has now become Ranking Member. Rep. Jason Smith (R-MO) has taken over Chairmanship of the Ways and Means Committee, and former Chairman Rep. Richard Neal (D-MA) has now become Ranking Member.

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The Optimal Pair: 401(k) + Cash Balance Plan

Some consider Cash Balance Plans (CBPs) to be the next generation of qualified retirement plans. The size of the CBP market exceeds $1.3 trillion[1]  and is growing—up 60 percent in the last three years. Financial advisors should take note of this burgeoning movement that could increase their assets under management (AUM) and help business clients thrive both now and in retirement.

The reasons CBPs have caught the attention of successful businesses with the right make-up are many. Perhaps the main reason such business owners are interested in CBPs is to achieve higher contribution and tax deduction limits than those available in defined contribution (DC) plans such as 401(k)/profit sharing plans. Currently, there are approximately 23,000 CBPs with 10 million participants.[2]

CBPs are a type of DB plan structured, specifically, to meet the increasing contribution and equity objectives of professional service firms and other high earning individuals (e.g., attorneys and health practitioners). CBPs provide a tax-advantaged wealth accumulation strategy for owners of the right firms. Such plans typically supplement a firm’s existing 401(k)/profit sharing plan and provide all of the following advantages:

  • Income deferral opportunities far beyond DC limits,
  • Flexibility around who is covered and the contribution level,
  • Tax-deductible contributions that are assets protected from creditors (unlike nonqualified deferred compensation plan assets),
  • Lump sum payouts available for rollover or Roth Conversion and
  • Transparency regarding the cost of each participant’s benefit.

“But don’t I have to be an actuary to sell CBPs?”

Let’s oust this myth right off the bat. Some financial advisors are intimidated by CBPs and avoid them, hiding behind the excuse, “I’m not an actuary—I can’t sell cash balance plans!” The truth is—advisors do not have to be actuaries to sell CBPs. They can partner with a firm or other entities for plan design, administration and actuarial services. The advisor’s role is to place the assets for CBPs on their usual wealth management platforms and get compensated just as they would with other assets under management. In fact, CBPs are easier for an advisor to service than 401(k) plans. For that reason, CBPs are a simple way to increase AUM without the usual DC plan headaches as long as the right team is assembled.

And 2023 is an unusually good year to prospect existing CBPs. Poor 2022 investment returns coupled with fixed rate interest crediting plan design has negatively impacted the contribution planning of plan sponsors. Existing CBP plan sponsors may be receptive to design changes—moving to a market return to stabilize plan contributions going forward.

How much more in contributions?

Total deductible contributions to a CBP can be two to four times more than contributions to a firm’s existing qualified DC plan. For 2023, DC plan contributions “max out” at $66,000 for participants under age 50, and $73,500 for participants age 50 and older. CBP contributions for an individual for 2023, potentially, based on a participant’s age and plan design, could be over $300,000—with a combined contribution total between a CBP and 401(k) plan nearing $400,000.

Because successful business owners often want to put away higher amounts than what a DC plan alone can provide, CBP plans are usually paired with a business’s existing DC plan—like a fine wine or favorite brew with a savory entree. Because a CBP is a type of DB plan, contributions can be in addition to and much larger than those allowed in DC plans. CBP contributions often are in addition to the amounts contributed to a business’s DC plan and, typically, vary based on a participant’s age, compensation level and/or employment group. The combination of plans can allow for much higher deductible contributions as the following table illustrates.

Assumes a 5% actuarial equivalence interest rate, 5% interest crediting rate adjustment, 5.5% lump sum conversion, discounting to the IRC Sec. 415 dollar limit from age 62, and maximum compensation for 2023 of $330,000

As displayed in this table, the maximum CBP contribution opportunity increases with age. Coupled with the maximum DC amounts from elective deferrals and profit sharing, the table shows the maximum deductible contribution opportunity available across all qualified retirement plans. While it may be appropriate for some key employees to have contributions at the highest levels, for others it may not. The flexibility built into the overall program is designed to meet the individual needs of each key employee.

Prime CBP Prospects

Firms that specialize in CBPs have found that the following industries are most likely to be interested in a CBP:

  • Medical specialty groups (think radiologists or imaging centers, anesthesiologists, orthopedics, gastroenterologists, etc.)
  • Law firms
  • Capital investment firms

While those are the “big three,” other prime prospects, including the following, have shown interest:

  • Engineering Groups
  • Accounting Firms
  • Architectural Firms 

Cash Balance Plan Designs

Cash balance plans are a type of DB pension plan that provides participants and beneficiaries with a promised retirement benefit. That means they carry with them a funding obligation that lies with the plan sponsor.  Although a CBP is a type of DB plan, it looks more like a DC plan. Increases and decreases in the value of a CBP’s investments do not directly affect the benefit amounts promised to participants. Thus, the investment risks and rewards on plan assets are borne by the employer.

Similar to a 401(k) plan, a CBP is expressed as an account balance (albeit hypothetical). In reality, CBP assets are managed in a pooled trust rather than an individual accounts. It is a DB plan that has been structured specifically to meet the increased contribution and equity objectives of professional service firms. Unlike a traditional DB plan, a CBP has the look and feel of the firm’s existing DC plan where each participant has an “account” that grows each year with contribution credits and interest credits.

In a typical CBP, a participant’s account is credited each year with a pay credit (such as five percent of compensation from the employer) and an interest credit, often referred to as the “interest crediting rate” or ICR. The ICR is important, as it can be a key driver of how much risk and volatility is present within a plan design. The first way a plan can credit interest is by using a fixed ICR. Prior to 2007, all cash balance plans used a fixed crediting rate. In this case, the plan simply adds a set percentage to a participant’s account at the end of each year. For example, if the balance at the beginning of the year is $10,000 and the ICR is a fixed 4%, the participant gets $400 added to his/her account at the end of the year, regardless of the performance of the underlying assets.

A fixed ICR can be frustrating to plan sponsors and service providers. When the promise does not align with the underlying rate of return, contributions become volatile (either much higher or much lower than anticipated) in order to get assets back in sync with promised account balances. Not a desirable outcome for plan sponsors. For this reason, most prefer to use an interest credit where participants’ accounts grow with actual trust returns. This is called a market rate return CBP. This minimizes the risk and volatility present in fixed-rate CBPs. Note: If actual returns are used, a participant must receive at least the promised contribution credits, or, put another way, a guaranteed zero percent return over the lifetime of participation in the plan. The ICR for newer CBPs (after 2006) is often tied to the underlying investment returns to minimize risk to the plan sponsor and create a promise that behaves similarly to the way a 401(k) plan operates.


There is every indication that CBPs are the next generation of qualified retirement plans, offering financial advisors a new way to increase AUM. CBPs are a type of DB plan structured, specifically, to meet the increasing contribution and equity objectives of professional service firms and other high earning individuals. Oftentimes, CPBs are paired with a 401(k)/profit sharing plan to maximize qualified contributions and tax deductions. Contrary to popular belief, advisors do not have to be actuaries to sell CBPs. Partnering with a firm or other entities for CBP design, administration and actuarial services allows financial advisors to do what they do best within their exiting wealth management platforms.

[1] DOL, “Private Pension Plan Bulletin, “October 2022

[2] Ibid.

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October Three Acquires the Retirement Learning Center

Great news: On May 1, 2023, October Three acquired the Retirement Learning Center (RLC). By combining RLC’s independent education and thought leadership with October Three’s innovative and modern retirement plans and technology, the two companies will work to ensure everyone feels prepared for retirement.

Currently, October Three and RLC are working to integrate RLC’s offerings into O3 Edge to provide RLC clients with more resources, tools and 24/7 access to educational and prospecting materials—all while keeping the RLC brand intact. The two companies will innovate in additional areas over time.

As you may recall, RLC was founded in 2003 by John Carl, a pioneer in the advisor education and support marketplace.  He built an incredible team of industry experts providing invaluable support to advisors in the financial services industry.  John unexpectantly passed away in 2022.

“We have been a big admirer of John Carl and the entire RLC team for many years,” said Jeff Stevenson, CEO of October Three.  “In acquiring RLC it is our intention to honor the legacy of John by investing in the wonderful business he created and continuing to serve the advisor community with excellence and passion.  It is our desire to enhance client services by incorporating additional technology-based solutions into the business…something we are very good at doing.”

October Three Consulting will continue to focus on delivering actuarial consulting, design, and administration of retirement plans. The firm is a leading force behind Market Return Cash Balance designs and recently launched O3 Prime “Personalized Retirement Income for My Employees,” a plan design concept intended to address the looming retirement crisis. For more information, please visit or follow @octoberthree on Twitter.

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