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Brokerage Windows–A Matter of Prudence

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“Several of my plan sponsor clients are considering adding a brokerage window to their plans’ investment line ups. Is that a good idea?”

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 Georgia is representative of a common inquiry related to 401(k) plan investments.

Highlights of Discussion

Adding a brokerage window to a plan’s investment menu is not a question of good or bad, but of prudence and loyalty under ERISA’s best interest standards. As clearly stated in Q&A 39 of Field Assistance Bulletin 2012-02R, plan sponsors that utilize brokerage windows that enable participants and beneficiaries to select investments outside of their plans’ designated investment alternatives (DIAs) have a statutory and ongoing fiduciary duty to evaluate whether such options are prudent investment alternatives for their plans under ERISA Sec. 404(a).

Further, with respect to participant disclosures related to brokerage windows, a plan sponsor must provide a(n)

  1. General description of the brokerage window (or like arrangement) sufficient enough to enable participants and beneficiaries to understand how the window works;
  2. Explanation of any fees and expenses that may be charged against the individual account of a participant or beneficiary on an individual, rather than plan-wide, basis in connection with the window; and
  3. Statement of the particular service and dollar amount of fees and expenses that actually were charged during the preceding quarter against the participants’ accounts in connection with the window.

While the DOL, clearly, does not prohibit the use of brokerage windows within self-directed plans, neither has it given much regulatory guidance on the matter. The ERISA Advisory Council confirmed the lack of solid guidance in a December 2021 study, “Understanding Brokerage Windows in Self-Directed Retirement Plans.”  However, most Council members did not believe that additional guidance in this area was needed. “In this regard, the Council observed that the marketplace seemed to be functioning well.”  The Council did recommend the DOL consider further fact finding related to brokerage-window-only (BWO) plans (i.e., plans that have no DIAs and brokerage accounts are the sole investment option) out of a concern “… that those types of plans may not incorporate the spirit of ERISA’s intent and protections for financially inexperienced employees and may need the Department’s attention …”

With respect to brokerage windows, the question for plan officials is whether such an arrangement, as a whole, is a prudent option for a plan and its participants (not each of the investment alternatives within the window).  That said, it seems the DOL may begin peeking inside the window a bit further. In Compliance Assistance Release No. 2022-01,  the DOL commented to the effect that if plan participants can access investments the agency deems “risky” through a brokerage window, “… plan fiduciaries responsible for … allowing such investments through brokerage windows should expect to be questioned about how they can square their actions with their duties of prudence and loyalty in light of the risks  …”

Conclusion

The DOL will hold plan fiduciaries and other officials to the ERISA standards of prudence and loyalty with respect to offering brokerage windows within self-directed plans. Such individuals and their advisors should be prepared to offer documentation in defense of their decisions and actions.

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IRS as Creditor

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Is the account balance of a 401(k) plan participant protected from an IRS tax levy?

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 Alabama is representative of a common inquiry involving 401(k) plans and IRS tax levies.

Highlights of Discussion

Unfortunately, no it is not. If the participant has an unpaid tax liability the IRS has the authority to levy against his or her 401(k) plan account balance [ Reg. § 1.401(a)-13(b)(2)].  In fact, any qualified retirement plan or IRA [including traditional, Roth, savings incentive match plan for employees (SIMPLE) or simplified employee pension (SEP) plan IRAs] may be subject to an IRS tax levy.

11.6.3 of the IRS’s Internal Revenue Manual (IRM) provides instructions and strict procedures when an IRS tax levy involves assets in retirement plans (as opposed to retirement income under 5.11.6.2 of the IRM). The IRM instructs agents to levy on retirement accounts only after considering the following questions.

1) Does the taxpayer have property other than retirement assets that may be available for collection first?

2) Has the taxpayer exhibited “flagrant” conduct? (See example next.)

EXAMPLE:  Jake, who has an outstanding tax liability with the IRS, continues to make voluntary contributions to retirement accounts while asserting his inability to pay the amount he owes to the IRS.   The IRS could deem this conduct as flagrant.

3) Are the retirement plan assets  necessary to cover the tax payer’s essential living expenses?

4) Does the taxpayer have “present rights” to receive the retirement plan assets?

EXAMPLE:  Amanda has money in a 401(k) plan, but cannot withdraw it until she experiences a distribution triggering event as listed in the plan document. An IRS levy may identify her 401(k) plan balance, but the money cannot be paid over until Amanda can withdraw it under the terms of the plan.

Logistically, the IRS will use Form 668-R, Notice of Levy on Retirement Plans for levying retirement plan assets.  When money is withdrawn from a retirement account to satisfy an IRS levy the taxpayer would include any pre-tax amounts in his or her taxable income for the year. Fortunately, an exception to the 10% additional tax on early distributions for taxpayers under age 59 ½ applies if the money was withdrawn because of a notice of levy served on the retirement account.

Conclusion

In most cases, 401(k) plan assets are protected from creditors—unless the creditor is the IRS.  However, IRS agents are instructed to levy against retirement plan assets only as a last resort.  Any taxpayer addressing an IRS tax levy should seek guidance from an experienced tax professional or attorney experienced in this area.

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Lead Employer Leaves MEP

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“If the lead employer in a MEP wants to leave the arrangement, does that mean the MEP is terminated?”

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 Massachusetts is representative of a common inquiry involving multiple employer plans (MEPs).

Highlights of Discussion

If the Lead Employer (a.k.a., the Controlling Member or Plan Sponsor) wants to leave a MEP, that does not mean the MEP is automatically terminated. Check the terms of the governing plan document to see if there is a process for a Lead Employer or Participating Employer (i.e., any employer who participates in the MEP) to leave the arrangement.

For example, a review of one plan document revealed the Lead Employer has some options as to how to leave the MEP.

  1. The Lead Employer could terminate the MEP.  In this case, the document states: “The Lead Employer may terminate this Plan at any time by delivering to the Trustee and each Participating Employer a written notice of such termination.” If the entire MEP is terminated, all participants become 100% vested in their assets (if a vesting schedule applies).
  2. The Lead Employer could withdrawal from the MEP.  The document states: “Upon thirty (30) days written notice to the other party, either the Lead Employer or Participating Employer may voluntarily withdraw from the Plan.”

Under a withdrawal, the MEP is not terminated. The MEP could remain intact but would have to be amended to designate a new Lead Employer. If none of the Participating Employers wanted to take on the role of the Lead Employer, each could withdraw from the MEP and set up its own individual plans and transfer assets to their respective new plans.

Conclusion

A Lead Employer may have options for leaving the MEP aside from plan termination. Be sure to check the terms of the plan document to see what alternatives—such as withdrawal—may be available.

 

© Copyright 2024 Retirement Learning Center, all rights reserved
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Investment Advice Fiduciary, PTE 2020-02 and Enforcement Deadlines

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“I read that the DOL is delaying the release of its regulations regarding the definition of investment advice fiduciary. Does that mean the enforcement of prohibited transaction exemption (PTE) 2020-02 is also delayed?”

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 a financial advisor from California is representative of a common inquiry related to the Department of Labor’s (DOL’s) definition of investment advice fiduciary.

Highlights of Discussion
While it is true the DOL is delaying until the end of 2022 the release of its notice of proposed rulemaking (NPRM) with respect to the definition of the term “fiduciary” for persons who render investment advice to plans and IRAs for a fee, the enforcement deadlines for PTE 2020-02 remain the same for those following the PTE. The final enforcement deadline for the last elements of PTE 2020-02 was July 1, 2022.

For a little background, a final DOL regulation, effective July 7, 2020, officially reinstated the original 1975 Five-Part Test for determining investment advice fiduciary status. An investment advice fiduciary must follow a PTE in order to receive pay for advice given. PTE 2020-02 provided further interpretive guidance on the Five-Part Test and included a process for avoiding a prohibited transaction involving the provision of investment advice for a fee. Other PTEs also address the receipt of fees for advice.

PTE 2020-02 originally took effect February 16, 2021. Later, the DOL implemented a “nonenforcement policy” under Field Assistance Bulletin (FAB) 2018-02 until December 20, 2021, for those who diligently and in good faith complied with the “Impartial Conduct Standards.” FAB 2021-02 further extended the nonenforcement policy through January 31, 2022. The three Impartial Conduct Standards mandate that advice be given
• In the best interest of the retirement investor,
• At a reasonable price,
• Without any misleading statements.

After January 31, 2022, investment advice fiduciaries following PTE 2020-02 are required to continue to follow the Impartial Conduct Standards and
• Acknowledge in writing their fiduciary status under ERISA and the Internal Revenue Code;
• Describe in writing the services to be provided and any material conflicts of interest that may exist;
• Adopt policies and procedures prudently designed to ensure compliance with the Impartial Conduct Standards and that mitigate conflicts of interest; and
• Conduct an annual retrospective review of their compliance with the requirements and produce a written report that is certified by one of the financial institution’s senior executive officers.

The DOL delayed enforcement of PTE-2020-02’s specific requirements for rollover advice until July 1, 2022. On and after that date, if the advice involves a rollover recommendation, then advisors must
• Document the reasons that a rollover recommendation is in the best interest of the retirement investor; and
• Disclose the justification for the rollover in writing to the retirement investor.

Conclusion
PTE 2020-02 and the (anticipated) proposed rules regarding the definition of investment advice fiduciary are separate DOL pronouncements. The DOL is delaying the release of its proposed rules with respect to the definition of investment advice fiduciary until the end of 2022. However, that delay does not affect the enforcement deadlines for PTE 2020-02.

 

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Top Heavy Safe Harbor Plans

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“One of my clients has a safe harbor 401(k) plan and his recordkeeper told him the plan was top heavy. How could that be? I thought all safe harbor plans were exempt from the top-heavy testing rules.”

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 a financial advisor from Florida is representative of a common inquiry related to safe harbor 401(k) plans.

Highlights of Discussion

No—not all safe harbor plans are exempt from the top-heavy rules.

A safe harbor plan that provides for salary deferrals and just the required safe harbor contribution (i.e., either the employer matching or nonelective contribution) would be exempt from top-heavy testing. However, there are three scenarios that would make a safe harbor plan subject to top-heavy testing, according to Revenue Ruling 2004-13:

  1. If, in addition to employee salary deferrals and the employer’s safe harbor contribution, the plan allocates an additional profit-sharing contribution;
  2. If the plan allocates forfeitures as a profit sharing contribution; and
  3. If employees are eligible to make elective deferrals upon hire but are not eligible for matching contributions until after they complete one year of service.

If your client’s safe harbor plan falls under one of the three above-listed exceptions, then the plan will have to be tested for top-heaviness. In general, a plan is considered top heavy if more than 60 percent of the plan’s assets belong to key employees. A top-heavy plan must satisfy minimum contribution and vesting requirements (see Treasury Regulation 1.416, Q&A Sections V and M).

Here are a couple of extra pointers regarding the minimum contribution requirement for safe harbor plans that fail top-heavy testing:

  • Safe harbor employer contributions can be used to help satisfy the minimum contribution requirement for a top-heavy plan.
  • When determining the top-heavy minimum contribution amount, the plan must use “full year compensation,” regardless of how the plan document defines compensation for contribution purposes (see Treasury Regulations 1.416-1, Q&As M-7 and T-21).

Conclusion

Not all 401(k) safe harbor plans are exempt from top-heavy testing. The IRS has identified three scenarios in which safe harbor plans would be required to apply the test and, if found to fail, meet minimum contribution and vesting requirements.

 

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Railroad Retirement Benefits

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“I have a client who participates in a pension with the railroad. Can you give me information on the arrangement?”

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 a financial advisor is representative of a common inquiry related to Railroad Retirement Benefits.

Highlights of the Discussion
The client is likely covered by the Railroad Retirement Act and the Railroad Unemployment Insurance Act, federal laws that provide retirement and disability benefits for qualified railroad employees and their spouses, and survivor benefits for family members. The program is governed by the Railroad Retirement Board and has been in existence since the 1930s.

Railroad Retirement Benefits are provided under a federal program parallel to the way Social Security operates for nonrailroad workers. There are several differences, however. For more information, interested parties can visit the following links online U.S. Railroad Retirement Board and An Overview of the Railroad Retirement Program.

Generally, Railroad Retirement Benefits have two tiers. Tier I was designed to be equivalent to Social Security benefits, while Tier II was structured to provide additional benefits comparable to private pension plans. And those covered by Railroad Retirement Benefits can login in here to check their benefits: https://rrb.gov/Benefits/myRRB

The form of payment is an annuity at full retirement age, which is approaching age 67 (like Social Security). Payments can start as early as age 62 with a reduction in benefit amount (also like Social Security). And if an individual has at least 30 years of service with the railroad, benefits can start at age 60 with no reduction of benefit. Annuities are payable to surviving widow(er)s, children, and certain other dependents. Lump-sum benefits are payable only in limited circumstances (i.e., after the death of a railroad employee if there are no qualified survivors of the employee, and in the case of a residual lump sum death benefit).

Railroad companies can also cover their employees with their own defined contribution or defined benefit plans. Receipt of a private railroad pension (but not a 401(k) distribution) could reduce the amount of annuity benefits payable by the Railroad Retirement Board (see Private Rail Pensions May Reduce Supplemental Annuities).

Coverage under Social Security or Railroad Retirement isn’t coverage under an employer retirement plan. Therefore, such benefits may not be rolled over to a qualified plan or IRA. Additional information on Railroad Retirement Benefits is available in IRS Publication 575, Pension and Annuity Income, and IRS Publication 915, Social Security and Equivalent Railroad Retirement Benefits .

Conclusion
Railroad employees may be eligible for unique benefits paid through the federal Railroad Retirement Board, which are similar to–but different from–benefits paid from the Social Security Administration.  Railroad companies could also sponsor private qualified retirement plans for their employees.  Individuals affected by Railroad Retirement Benefits should seek tax advice to help them sort out the details of how their various retirement benefits interact with each other.

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Sources of Retirement Income

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“I’ve been talking to my clients about sources of retirement income. On average, what are the most prevalent sources of income for a retiree and what percentage does each represent?”  

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 a financial advisor from Alabama is representative of a common inquiry related to retirement income.

Highlights of the Discussion

No longer do we have the old “three-legged stool” of retirement income, which consisted of Social Security, private pensions and personal savings. A 2021 study by the Social Security Administration revealed that the average retiree’s income comes from workplace retirement plans (primarily defined contribution plans) and IRAs (36%), followed by Social Security benefits (30%) and earnings from work (25%).

Retirement Income

Source: Social Security Administration, Improving the Measurement of Retirement Income of the Aged Population, 2021

The DOL’s requirement for plan sponsors to provide retirement income illustrations to participants with defined contribution plans will push the issue of retirement income even more. A key differentiator for advisors, moving forward, will be the ability to effectively support participants in transitioning away from a lump sum accumulation mindset to a true retirement income focus.

Conclusion

Nowadays, the primary sources of retirement income come from a person’s defined contribution plans and IRAs, Social Security benefits and workplace earnings. How to convert retirement plan and IRA balances into a reliable stream of retirement income is the next critical issue that needs innovative solutions.

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Fiduciary Investigation Program

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“Do you have any insight into what happens during a DOL plan investigation?”

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 a financial advisor from Ohio is representative of a common inquiry related to Department of Labor (DOL) plan investigations.

Highlights of the Discussion

Yes, the Employee Benefits Security Administration (EBSA) division of the DOL has a very detailed Enforcement Manual posted on its website (dol.gov). One of the chapters of the manual pertains specifically to the Fiduciary Investigation Program (FIP), applicable to employee benefit plans such as 401(k) plans. Included along with the detailed descriptions and procedures in the FIP are several DOL checklists — referred to as “Figures” in the text — that the DOL auditor completes as part of an investigation. For example:

 Figure 3 is a Bonding Checklist
 Figure 4 is a Reporting and Disclosure Checklist
 Figure 5 is an Individual Benefit Statement Compliance Checklist
 Figure 6 is the DOL’s general Investigation Guidelines

The DOL clarifies that the Investigation Guidelines (Figure 6) should not be considered as either mandatory or all-inclusive but should be used to the extent deemed appropriate for the plan. Also, the DOL can expand the scope of the investigation beyond the original allegations or suggest additional areas of inquiry if new information is uncovered during the investigation.

The Investigation Guidelines are arranged in two parts:

 Part I, Background Information, covers data related to the type and size of the plan, and the responsible parties.
 Part II, Review Procedures, explores compliance with the Employee Retirement Income Security Act of 1974 (ERISA) and probes for potential violations of ERISA, particularly fiduciary violations.

The investigator may apply additional investigative steps if deemed necessary.

Conclusion
Plan sponsors can use the DOL’s FIP as a guide for conducting their own fiduciary reviews to uncover any potential deficiencies in their plans and implement remedies before the DOL targets them for formal investigations. For plan sponsors who have already been notified of a pending investigation, the FIP can give them an idea of what to expect.

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The Audit Formerly Known As “Limited Scope”

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“My plan clients are asking questions about changes to what used to be called the “limited scope audit” for Forms 5500 that take effect for the 2021 plan year filings. Can you summarize the changes?”

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 a financial advisor from Pennsylvania is representative of a common inquiry related to the report performed by an independent qualified public accountant (the auditor) that accompanies certain Form 5500 filings.

Highlights of the Discussion
The limited scope audit related to Form 5500 filings is now more involved and has a new name: the ERISA Sec.103(a)(3)(C) audit. From a plan sponsor’s perspective, the changes do not affect anything in ERISA. Therefore, a sponsor’s ability to elect such an audit continues. The new rules change what is expected of the plan auditor, starting with the 2021 filing year in most cases.

Under the old rules, a limited scope audit permitted plan sponsors to elect to have the plan auditor exclude certain investment information from his or her review that pertained to investments held and certified by qualified institutions. In 2019, the American Institute of Certified Public Accountants’ (AICPA) Auditing Standards Board issued two new auditing standards related to the financial statements of employee benefit plans and transparency in annual reports:

1. Statement on Auditing Standards(SAS) No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA; and
2. Statement on Auditing Standards (SAS) No. 137, The Auditor’s Responsibilities Relating to Other Information Included in Annual Reports.

SAS 136 creates a new section in the AICPA Professional Standards, and deals with the auditor’s responsibility to form an opinion and report on the audit of financial statements of ERISA employee benefit plans. SAS 136 takes effect for audits of ERISA plan financial statements for periods ending on or after December 15, 2020. SAS 137 enhances transparency in reporting related to the auditor’s responsibilities for nonfinancial statement information included in annual reports.

SAS 136 will affect limited-scope audits beginning with the 2021 filing by

1. Referring to such audits as ERISA Sec.103(a)(3)(C) audits;
2. Clarifying what is expected of the auditor, including specific procedures when performing the audit; and
3. Establishing a new form of report that provides greater transparency about the scope and nature of the audit, and describes the procedures performed on the certified investment information.

For a summary of the SAS 136 changes to Form 5500 reporting, please refer to AICPA’s At A Glance: New Auditing Standard for Employee Benefit Plans.

Conclusion
Limited scope audits associated with IRS Form 5500s have a new name and scope because of changes that are effective starting with the 2021 filing year in most cases. A plan sponsor’s ability to elect such an audit continues. The new rules change what is expected of the plan auditor. Make sure the plan has an experienced auditor who is keenly aware of the new expectations.

© Copyright 2024 Retirement Learning Center, all rights reserved
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Roth IRAs v. Designated Roth 401(k)s

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“What are the differences between Roth IRAs and designated Roth 401(k) accounts?”

Highlights of discussion

While there are many differences, the following chart summarizes some of the key dissimilarities.

Feature Roth IRA Designated Roth 401(k) account
Investment options Generally, unlimited, except for life insurance and certain collectibles As specified by the plan
Eligibility for contribution  Must have earned income under $144,000 if a single tax filer or under $214,000 if married filing a joint tax return ·   Access to a 401(k), 403(b) or governmental 457(b) plan with a designated Roth contribution option and

·   The individual must meet eligibility requirements as specified by the plan
Contribution limit (2022) $6,000 ($7,000 if age 50 or older) $20,500 ($27,000 if age 50 or older)
Conversions Anyone with eligible IRA or employer-plan assets may convert them to a Roth IRA Plan permitting, anyone with eligible plan assets may convert them within the plan to a designated Roth account
Recharacterize contribution Yes, within prescribed period No
Required minimum distributions Not during owner’s lifetime Yes
Tax- and penalty-free qualified distributions, regardless of type of money Taken

·      After owning the Roth IRA for five years and

·      Age 59 ½, death, disability, or for first home purchase

 Must have a distribution–triggering event under plan terms, plus

·   Five years after owning the designated Roth account and

·   Age 59 ½, death, or disability
Tax and/or penalty on nonqualified distributions based on type of money According to IRS distribution ordering rules:

1.     Contributions: Always tax- and penalty-free

2.     Taxable Conversions: On a first-in, first-out basis by year; always tax-free; penalty if taken within five years of conversion

3.     Nontaxable conversions:  On a first-in, first-out basis by year; always tax- and penalty-free

4.     Earnings: Taxed as ordinary income, subject to penalty unless exception applies

 Withdrawals represent a pro-rata return of contributions and earnings in the account; earnings are taxable and subject to penalty unless an exception applies. See IRS Notice 2010-84 for rules applicable to the return of designated Roth 401(k) converted amounts
Timing of distributions At any time, subject to tax and/or penalty depending on type of assets distributed Following plan-defined, distribution triggering events
Loans No Yes, if plan permits
Five-year holding period for qualified distributions Begins January 1 of the year a contribution or conversion is made to any Roth IRA of the owner ·         Separate for each 401(k) plan in which an individual participates

·         Begins January 1 of the year a contribution or in-plan conversion is made to the account
 Beneficiary Anyone, but spousal consent required in community property states Anyone, but spousal consent required

 

Conclusion

While both Roth IRAs and designated Roth 401(k) plan contributions offer the potential for tax-free withdrawals, there are several key differences between the two arrangements. Whether one, the other or both may be right for a particular investor depends on the individual’s circumstances and goals and should be determined based on a thorough conversation between the investor and his or her tax advisor.

 

 

© Copyright 2024 Retirement Learning Center, all rights reserved