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Miami

Cypen & Cypen
NEWSLETTER
for
November 5, 2020

Stephen H. Cypen, Esq., Editor

1.    RETIREMENT PLANNING NEEDS OF PRIVATE- AND PUBLIC-SECTOR EMPLOYEES MORE SIMILAR THAN DIFFERENT:
There has been a general perception in this country that public-sector, or government, employees have more generous retirement benefits than employees in the private sector and, thus, do not face the savings and planning needs private-sector employees do.

However, Mike Sanders, principal at Cammack Retirement Group, says there are many similarities in retirement planning needs for private-sector and public-sector employees. Still, there are some differences his firm focuses on when dealing with the two types of plans.

When the firm is working with a public plan sponsor, such as a city or state, it emphasizes that retirement planning should consider the differences in jobs, Sanders says. “For example, first responders tend to retire much earlier than other public-sector employees or those in the private sector. On average, they retire around age 55,” he says. “They need education about early retirement and possibly having a second career. They should be prepared for more time without the same level of income coming in. They need to save more and invest better because of the additional risk.”

Sanders says public employees tend to have a much longer tenure with employers than private-sector employees, and that allows public plan sponsors to gather better data about all sources of savings and compensation trends. Public employees are more likely to have access to a defined benefit (DB) plan, but he warns that public DB plans have been going through changes. “Some are starting to move to a hybrid plan. We’ve helped launch two of those with large public employers over the past two years,” he says. “New employees are not getting the same benefits they have in mind from what their parent public employee had.”

It’s important to show public employees how to supplement their DB plans. “Higher education 403(b) programs in which employees get 10% to 12% of their compensation put in a year is the closest thing to having a public DB plan,” Sanders notes.

In states where public-sector employees have a DB plan and get Social Security, they might only need to replace about 4% more of their income in retirement, so plans such as 403(b)s and 457s are truly supplemental, Sanders says. However, not all public employees get Social Security.

“You have to look at every employer’s benefits and determine employee planning needs. It’s different for each group,” he says.

From a knowledge standpoint, public employees have a very similar base, Sanders says. “With the exception of police and firefighters, I find they have a very high financial acumen, but, overall, they need to understand basic finance and why retirement is important,” he says.

In the private sector, where the majority of companies do not offer a DB plan, there have been discussions for years about adding lifetime income options or annuities into defined contribution (DC) plans, so, upon retirement, participants can annuitize and get a DB-like income stream, Sanders notes. “Annuities often can deliver fantastic results,” he says.

Still, there is a large proponent of people who, if not properly educated, will go into retirement and look at an annuity and look at the large amount saved and make a poor decision,” he continues. This is why working with a financial adviser would be helpful. However, Sanders says, many workers might not feel comfortable or even know how to reach out to an adviser.

“We still don’t know how to overcome people being uncomfortable with handing a large amount of assets over to an annuity provider,” Sanders says. “But that’s the next thing to happen for our industry.”

Consider Health Care Costs
Health expenses should also be considered in retirement planning, Sanders suggests, no matter if a retiree is a public-sector or a private-sector employee.

“Even if a person gets retiree health benefits, it’s important for them to know the costs and what benefits they are getting,” he says. “More education about costs is needed for private-sector employees. And, some studies say, those who are healthy will have more health expenses in retirement because they’ll live longer.”

The things people don’t think about or don’t talk about ultimately results in hidden costs, Sanders says.

There has been a long trend of retiree health benefits going away in the private sector, says John Barkett, senior director of policy affairs at Willis Towers Watson. “It’s stabilizing now. Around 25% of private-sector companies still offer retiree health benefits, but, 30 years ago, 50% to 65% were,” he says. “In general, public-sector employers continue to provide retiree health benefits at a higher rate than in the private sector--between 60% and 80% do.”

However, Barkett says, while public-sector benefits in general are stickier, there are factors that could be creating conditions that might change retiree health benefits. “Combined with GASB [Government Accounting Standards Board] rules for more transparency about other post-employment benefits [OPEBs], there are a couple of things that could drive employers to look for new options--the threat of declining financial health of employers or governments and the threat of lawsuits if benefits are changed,” he explains.

And public employees aren’t the only ones who might see retiree health benefit changes. Some courts have ruled that health benefits private-sector employees thought were for life are not, Barkett says. Add that potential change to the cost of health care getting more expensive, and it shows all employees need to plan for health care costs in retirement.

“I start discussions with employees reminding them what the costs are,” Barkett says. “Medicare is not as generous as people think and it does have premiums.” He explains that even with Medicare, individuals are still on the hook for about 20% of costs unless they buy supplemental insurance. “They get no drug coverage without purchasing a separate drug plan, and the Part B premium is around $120 to $140 a month. So, they’re looking at $1,300 a year in Part B premiums, and potentially more costs if buy they buy a supplemental plan,” Barkett notes. “With Medicare premiums, individuals are looking at $5,000 a year before any cost sharing. That’s a huge chunk of a retiree’s budget, so planning for this is important.”

Barkett says using a health savings account (HSA) is a good idea for both private- and public-sector employees. “It really makes sense to try to save for health costs in retirement using those accounts because of their triple tax advantage. It’s the most tax-efficient vehicle for saving for retirement,” he says. “The challenge people have is they might need their HSA accounts to pay for care in the present. Or do they have enough money to put into an HSA? Not everyone’s situation is the same.”

If an employee does have a retiree health benefit, he might need to save less; however, Barkett says planning needs are still the same. “Health costs continue to increase, and public-sector employers have changed how they offer health benefits to retirees,” he says. “Anyone relying on retiree health benefits to cover costs hopes they can rely on it, but they should be prepared. Some public employers have capped how much they contribute to premiums or have implemented different eligibility requirements. The fact that those changes have been made implies similar changes can happen in the future.”

Barkett adds that employees should remember there will be health care costs that aren’t included in retiree benefits--such as hearing aids, for example. So it is still a good idea to save for such items.

Having savings in an HSA is valuable if retiree benefits don’t cover everything or if they change. Barkett notes that once an HSA-holder reaches age 65, he can use the money in the account for non-medical related items, and it is taxed as ordinary income. “So, if retiree health care covers health costs and you have to use your HSA for other things, that’s not the worst situation to be in,” he says.

Sanders says public and private employees differ when it comes to the adoption of technology, such as mobile applications--which could be helpful for retirement expense calculations and planning.

“There’s more adoption in the private sector than in the public sector. It comes from long tenures in employment. Public sector employees may not have gone through job changes and had to adapt to technology for benefits enrollment and education,” he says. “However, tech use may become more aligned because of COVID-19.”  Rebecca Moore, PLANSPONSORwww.plansponsor.com, October 27, 2020.
 
2.    VIRTUAL SERIES - SYSTEMIC RACISM AND RETIREMENT PLANS:
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What does systemic racism mean in the context of retirement plans? Jeff Brown, dean of University of Illinois' Gies College of Business, discusses racial justice and retirement plans at P&I's DCW Fall Series.  Click here or above to watch. Pension & Investmentswww.pionline.com, October 27, 2020.

3.    US PENSION FUNDS FAILING IN CLIMATE CHANGE CHALLENGE:
Fewer than one-in-five pension funds in North America have committed to achieving net zero carbon emissions across their portfolios by 2050 according to a study that underlines the need to accelerate the fight against climate change in the world’s largest pensions market.

Just 17 per cent of North American pensions funds aim to reach net zero by the middle of the century while a further 8 per cent expect to reach that target at a later date, according to the Aviva Investors analysis.

Four out of every 10 pension funds in both Asia and Europe have already committed to reaching net zero carbon emissions by 2050, more than twice as high as in the US where the Trump administration has played down the risks of global warming.

However, devastating wildfires in California, which have burnt more than 2m acres of land, have led to calls from pressure groups for pension funds in the golden state to divest entirely from fossil fuels. 

The investment arm of UK insurer Aviva polled 535 pension funds and 532 insurance companies from 34 countries with combined assets of more than €2tn to assess how sentiment among institutional investors was shifting during the coronavirus pandemic.


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The EU has created a green taxonomy to encourage more sustainable investing in contrast to the US where the Department of Labor is insisting that private pension administrators must prove that they will not sacrifice financial returns by incorporating environmental, social and governance (ESG) considerations into their asset allocation decisions. The DoL’s narrow interpretation of an administrator’s fiduciary duty which focuses purely on financial returns has restricted US pension plans’ room for manoeuvre. Climate Capital Where climate change meets business, markets and politics. Explore the FT’s coverage here 

The $412bn California Public Employees’ Retirement System (Calpers) is the only US pension plan to have signed up to the UN-backed Net-Zero Asset Owner Alliance, a coalition of thirty of the world’s largest asset owners that have committed to cutting the carbon emissions linked to companies they invest in by up to 29 per cent within the next four years.

The alliance’s chair, Günther Thallinger, said “many discussions” were ongoing. “We recognise that achieving net zero carbon emissions is a very big commitment which requires big changes to the investment management processes and portfolios of pension funds,” said Mr Thallinger, who is also a board member at Allianz, the German insurer.

“Asset owners have to protect their portfolios from threats such as climate change if they are to fulfil their fiduciary duties. Pension funds have a clear responsibility to consider the climate impact of the businesses that they own as shareholders,” he said.

Almost half of the insurance companies in Europe and Asia which were surveyed by Aviva have already signalled a commitment to reaching net zero by 2050.

“Sustainable investments were seen as an expensive ‘nice to have’ through much of the last decade,” said Mark Versey, chief investment officer for real assets at Aviva Investors. “Now, however, almost eight-in-10 global investors believe that the pursuit of achieving ESG objectives is no longer at the expense of financial returns.”  Chris Flood, Financial Timeswww.ft.com, November 1, 2020.

4.    US STATE LIABILITY BURDENS FALL TO 5%; FIVE STATES TOP 20% DRIVEN BY PENSIONS:
Long-term liabilities burdens fell for a fourth straight year for U.S. states and hit a notable threshold last fiscal year, according to Fitch Ratings in its latest annual survey of state direct debt and pension liabilities.

Long-term liabilities relative to personal income declined to 5% in fiscal 2019, from 6% in fiscal 2016. "The downward trend does not necessarily reflect an enduring drop in state burdens, especially for pensions," said Senior Director Doug Offerman. "Instead, robust economic growth up to the coronavirus pandemic drove faster gains in personal income than in debt and pensions."

Over that time, median personal income by state grew 4.1% annually. Direct debt, which constitutes about 40% of long-term liabilities, remained relatively flat, at 2.1% of personal income in fiscal 2019, vs. 2.3% in fiscal 2016. State debt is carefully managed, including through various limits on authorization, issuance and debt service.

By contrast, net pension liabilities, adjusted by Fitch to a 6% investment return assumption, fell to 2.7% in fiscal 2019, from 3.1% in fiscal 2016, and has been volatile, driven by shifting market values for pension assets.

States have tightened pension management over the last decade, trimming benefits, lowering return targets and raising contributions, but only a few states have seen lower pension burdens. This is because falling investment return assumptions raise liabilities, more than offsetting the incremental gains from lower benefits, higher contributions and other assumption changes.

Five states continue to carry elevated long-term liability burdens above 20% of personal income in fiscal 2019, including Illinois (at 27% of personal income), Connecticut, New Jersey, Hawaii and Alaska. For all of them, pensions remain the driver of elevated liabilities. Conversely, 37 states carried burdens below 10% of personal income, which Fitch views as low. 

Fitch's '2020 State Liability Report' is available at 'www.fitchratings.com'.  FitchRatings, www.fitchratings.com, October 26, 2020.

5.    WHAT EMPLOYERS SHOULD KNOW ABOUT LIFETIME INCOME DISCLOSURE REQUIREMENTS FOR DEFINED CONTRIBUTION PLANS:
Section 203 of the Setting Every Community Up for Retirement Enhancement Act (“SECURE Act”) amends the disclosure rules under Section 105 of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), to add an annual lifetime income disclosure requirement for all defined contribution plans subject to ERISA. According to the legislative history of the SECURE Act, the purpose of the new requirement is to help a defined contribution plan participant understand how his or her plan account balance correlates into a lifetime income stream.  The SECURE Act also requires the Department of Labor (“DOL”), within one year after enactment of the SECURE Act, to issue model lifetime income disclosure language and assumptions to be used by plan administrators in complying with the lifetime income disclosure requirement.

On August 18, 2020, the Department of Labor released an Interim Final Rule, entitled “Pension Benefit Statements – Lifetime income illustrations.”As directed by Congress, the Interim Final Rule provides assumptions to be used by plan administrators in converting a defined contributions plan participant’s account balance to an equivalent single life annuity and a qualified joint and survivor annuity. The Interim Final Rule also includes model language designed to explain the lifetime income illustrations to plan participants and beneficiaries.

The following is a summary of key elements of the new lifetime income disclosure requirement as clarified by the Interim Final Rule.

Two lifetime illustrations must be provided at least annually
ERISA Section 105(a)(1) requires a plan administrator to provide benefits statements to participants. Such statements must be provided quarterly in the case of plans under which a participant can self-direct the investment of his or her account and annually in all other cases. As amended by the SECURE Act, Section 105(a)(2) requires the benefit statement to include two illustrations of the monthly benefit payments that would result if a participant’s total accrued benefit were used to purchase a lifetime income stream. The first illustration assumes the purchase of a single life annuity. The second illustration assumes the purchase of a qualified joint and survivor annuity (“QJSA”) that provides a survivor benefit equal to 100 percent of the participant’s benefit during life.

Contents of a benefit statement that includes a lifetime income illustration
A benefit statement that includes a lifetime income illustration must include the following information:

  • The beginning and ending date of the benefit statement period;
  • The value of the participant’s account balance as of the last day of the benefit statement period;
  • A lifetime income illustration expressed as a single life annuity; and
  • A lifetime income illustration expressed as a QJSA with a 100 percent survivor annuity.

Assumptions in calculating lifetime income illustrations
The Interim Final Rule specifies the assumptions a plan administrator must use in calculating lifetime income illustrations. These assumptions are summarized in a Fact Sheet issued by the DOL (“DOL Fact Sheet”). The assumptions are as follows:

  • Assumed commencement date – Each lifetime income illustration must assume a benefit commencement date that is the last date of the period reflected in the benefit statement that includes the illustration.
  • Assumed age – Each lifetime income illustration must assume that the participant is age 67 unless the participant is older, in which case the participant’s actual age is used in calculating the illustration. Age 67 is the age at which most participants can commence full Social Security benefits.
  • QJSA assumptions – A QJSA lifetime income illustration must be provided to all participants, even if unmarried, and must assume the spouse is the same age as the participant.
  • Assumed interest rate – In calculating monthly payments for each lifetime income illustration, the plan administrator must use the 10-year constant maturity Treasury rate as of the first business day of the last month of the benefit statement period. According to the DOL Fact Sheet, this interest rates approximates the rate used by insurance companies in pricing immediate annuity contracts.
  • Assumed mortality table – For each lifetime income illustration, the plan administrator must use the gender neutral mortality table in Section 417(e)(3)(B) of the Internal Revenue Code.
  • Plan loans – Plan loans are included in a participant’s account balance for purposes of calculating a lifetime income illustration unless the participant has defaulted on the loan.
  • Vesting – For purposes of calculating a lifetime income illustration, a participant is assumed to be 100 percent vested in his or her plan account.

Assumptions for defined contribution plans with annuity distribution options
In the case of defined contribution plans offering an annuity distribution option through a licensed insurer, the plan administrator may substitute the assumptions in the terms of the plan’s insurance contract in lieu of the assumptions listed in the Interim Final Rule. However, a lifetime income illustration must still assume that (1) benefit payments commence on the last day of the benefit statement period, (2) the participant is age 67 (unless older), and (3) the participant has a spouse of the same age.

Deferred annuities purchased by participants are excluded from lifetime income illustrations
If a portion of a participant’s account includes a deferred lifetime annuity contract purchased by the participant from a licensed insurer, the amounts payable under such contract are excluded from the Lifetime income illustration.  This rule applies whether the deferred annuity contract is in the form of a life annuity or a qualified joint and survivor annuity. However, the Lifetime income illustration statement must include the following information with respect to the deferred annuity:

  • The date payments are scheduled to commence and the age of the participant on such date;
  • The frequency and amount of payments as of the commencement date, expressed in current dollars;
  • A description of any survivor benefit, term certain, or other similar feature; and
  • A statement whether payments are fixed, adjust with inflation, or adjust in some other way and how such adjustment is determined.

Interim Final Rule includes model explanatory language
The Interim Final Rule requires that benefit statements include explanations of the assumptions used in calculating the monthly payments in the illustration and provides optional model language for the explanations. According to the DOL Fact Sheet, the explanations are designed to help participants and beneficiaries understand the method of calculating the estimated monthly payments and that the estimates are only illustrations and not guarantees with respect to future benefits. For example, the model language includes a description of the assumptions relating to the benefit commencement date, participant’s marital status, interest rates and mortality tables used in making calculations. The model language also defines the terms single life annuity and qualified joint and survivor annuity for participants and beneficiaries who may be less familiar with these concepts.
The Interim Final Rule requires an explicit cautionary note to participants that the monthly payments shown in the benefit statement are not guaranteed.
Special model language is provided for defined contribution plans that offer annuity distributions or if participants have purchased deferred annuities.

No liability by reason of providing illustrations if model explanatory language is used
The Interim Final Rule provides that no liability will be imposed on plan fiduciaries and plan sponsors solely as a result of providing lifetime income illustrations.  To qualify for this relief, the lifetime income illustration must be based on the required assumptions in the Interim Final Rule. In addition, the lifetime income illustration statement must include the explanatory language provided in the Interm Final Rule or language that is substantially similar in all material respects.

Effective date
The effective date of the Interim Final Rule is one year after its publication in the Federal Register.  Although not required to do so, the DOL has invited public comment with respect to the Interim Final Rule for 60 days after publication. The DOL has further stated its intent to adopt a Final Rule prior to the effective date of the Interim Final Rule that takes into account comments on the Interim Final Rule. The DOL has indicated that the adoption date of the Final Rule will be sufficiently in advance of the effective date of the Interim Final Rule to minimize compliance burdens for plan administrators.

Conclusion
The lifetime income disclosure requirement has potential to enhance a participant’s understanding of the impact of his or her existing retirement savings and the need to continue or increase future retirement savings. However, the lifetime income illustrations are based on many assumptions that could be misleading to participants. For example, the assumptions that a participant is 100 percent vested, married, and that the participant’s spouse is the same age, and the inclusion of plan loans in the calculation of the account balance, could significantly skew the lifetime income illustrations. In addition, some participants may not fully grasp that the illustrations are estimates only and not guarantees of future benefits. It will be important for plan administrators to ensure that communications to plan participants are clear with respect to the true nature of the lifetime income illustrations.  Thompson Coburn LLP, www.thompsoncoburn.com, November 2, 2020.

6.    FREE WEBINAR - HOW TO MAINTAIN WORPLACE CULTURE VIRTUALLY:
As many organizations implement mandatory work from home amid the Coronavirus (COVID-19), many leaders are asking, how can we keep our staff engaged, and maintain our culture through this turbulent time.

We definitely don't have all the answers, and we are continuing to figure out what works for us, however as one of Fortune Magazine's "100 Best Companies to Work For," a two time winner of Inc. Magazine's "Best Workplace," and a six time winner of Crain's Chicago Business' "Best Companies to Work For" we thought we'd share what we have been doing. 

During the webinar, Sirmara can lend advice on what employees need most during this pandemic, and how companies can continue to keep their cultures thriving regardless of being virtual, pointing to what LaSalle Network is doing listed in the blog link above that companies can easily adopt.  Click here to sign up.  www.workforce.com.

7.    EMPLOYERS’ SENSE OF RESPONSIBILITY FOR EMPLOYEES’ FINANCIAL WELLNESS IS RISING:
The last decade has seen important growth in employment-based financial wellness programs, which have become an integral part of employer benefits offerings. Yet the pandemic has brought employee financial well-being into sharper focus, particularly because workers face greater stress and demands on their time, straining their overall sense of wellness.

Clearly, more needs to be done to ensure employees feel supported at work – financially, physically, emotionally and mentally. In fact, our recent Workplace Benefits Report for 2020 identified that 62% of employers feel “extremely” responsible for their employees’ financial wellness today, compared to 13% in 2013. Employers’ increased responsibility is even greater with respect to the retirement front, with 80% feeling very or extremely responsible for helping employees prepare for retirement healthcare needs and costs, up from 22%; and 78% for preparing employees for retirement income needs, up from 33%.

This report also reported on trends in workplace financial benefits and wellness, tracking both employee and employer sentiment. Based on a nationwide survey of 996 employees and 808 employers, key findings include:

  • Financial wellness and productivity are interconnected. Eighty three percent of employers believe employee financial wellness programs and tools help to create more productive, loyal, satisfied and engaged employees. This works both ways, as 57% of employees feel their well-being has a great impact on productivity. When asked what factors contribute to their overall sense of well-being, employees cited physical (51%) and mental wellness (54%), only slightly more so than financial (49%).
  • Financial wellness has declined since 2018, though it does vary by generation. In March of 2020, 49% of employees rated their financial wellness as good or excellent, down from 55% in 2019 and 61% in 2018. Fewer Gen Z (41%), Millennial (41%) and Gen X (38%) employees rate their financial wellness as good or excellent today, compared with 60% of Baby Boomers and those in the Silent Generation.
  • Professional financial advice and holistic support remain top priorities. Fewer than 4 in 10 employees say they have made significant progress toward specific personal financial goals, and the main obstacle cited is a lack of disposable income after monthly expenses. Employees most wanted advice from a financial professional with whom they can discuss a range of topics, and they also wanted flexibility in terms of how they accessed the advice.
  • Debt is a multifaceted challenge. Most (82%) of employees reported carrying debt, with the most common types being credit card (50%), mortgage (46%), and student loans (21%). Unfortunately, debt can erode a sense of overall well-being: 59% of employees say they lack a high level of control over their debt, and 36% say debt affects their ability to achieve financial goals.

Fortunately, the range of topics being addressed by workplace financial wellness programs has also increased substantially over time. Such programs today, compared to 2013, focus on:

  • Saving for retirement (81% vs. 70%)
  • Planning for healthcare costs (71% vs. 38%)
  • Budgeting (63% vs. 14%)
  • Saving for college (55% vs. 13%)
  • Managing debt (54% vs. 15%)

Our report also differentiated financial wellbeing of working women versus men. We found that 41% of women rate their financial wellness as good or excellent, compared to 58% of men. Combined with the fact that women often earn less than their male counterparts, this implies that women may be more likely to take time out of the workforce to raise a child or provide care for a family member, and they typically live longer. All of these realities underscore the need for financial wellness programs tailored to women’s unique financial journeys and life paths.
Other financial wellbeing differences between men and women include:

  • Women are more likely to have credit card debt (56% vs. 43% of men) and student loans (30% vs. 11% of men), and are more likely to feel a lack of control over their debt (67% vs. 49% men).
  • Women are more than twice as likely to rank paying off credit card debt among their top financial goals (21% vs. 9% of men).
  • Women are nearly twice as likely to cite lack of cash after monthly expenses as a primary challenge to achieving financial goals (47% vs. 27% of men).

The key takeaway from this report is that employers are making great progress in providing wellness programs to address the diverse needs of their workforces. Yet more remains to be done, as the pandemic creates new challenges to maintaining financial wellness.  Pension Research Council, the Wharton School, University of Pennsylvania, https://pensionresearchcouncil.wharton.upenn.edu.

8.    POOLED EMPLOYER PLANS MAKING SPLASH AS MORE FIRMS DIP TOES INTO THE WATER:
Several major retirement plan service providers are diving into the pooled employer plan market with high hopes that small and midsize employers will jump in, too.

Pooled employers plans, or PEPs, were established under the Setting Every Community Up for Retirement Enhancement Act last year and go live Jan. 1, 2021. PEPs make it easier for employers in unrelated businesses to join a collective or pooled retirement plan for their workforces, with the intention that companies will be able to reduce administrative burdens and lower retirement plan costs through economies of scale as well as attract employers that currently do not offer plans.

PEPs have the opportunity to transform the retirement landscape much like 401(k) plans transformed the pension landscape, said Paul Rangecroft, Princeton, N.J.-based North America retirement practice leader for Aon PLC.

That's a major reason why Aon in June said it will launch a PEP on Jan. 1, 2021.

"PEPs are going to take the beginning of the transformation that 401(k)s started, and especially with small- and midsize employers and gig workers, will create a sustained vehicle where people can move jobs without losing all of their retirement savings, where they can save money without giving a lot of it to investment advisers or administrators, where they can make choices in an informed way, and actually give coverage to lots of people," Mr. Rangecroft said.

Aon will serve as the pooled plan provider, the entity that administers the PEP, with Aon Investment Services USA Inc., the company's investment services group, serving as a 3(38) fiduciary adviser. Aon selected Voya Financial Inc. as the record keeper.

The Aon PEP will offer various target-date funds, three core passive funds and five active funds, Mr. Rangecroft said. "We're going to encourage people to make decisions based on their level of comfort and knowledge in a way that drives the right outcome for them rather than a typical plan these days offering 30 funds with not enough knowledge of how to pick them," he added.

Jeff Cimini, Windsor, Conn.-based senior vice president, retirement product management at Voya, said he and his colleagues are currently working with Aon on the "unglamorous" behind-the-scenes work "so that on Jan. 1 we can start accepting plans into the PEP."

Voya, which is no stranger to the pooled plan space -- it serves as the record keeper for multiple employer plans offered by the American Bar Association and ADP -- thinks PEPs can help close the retirement coverage gap, Mr. Cimini said. PEPs "have the potential to allow (employers) to offer a retirement benefit at an economical price with limited legal liability to do so," he added.

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International expansion
Following passage of the SECURE Act, Smart Pension, a large London-based online record keeper, established operations in the U.S. to take advantage of anticipated business opportunities.

"It became kind of a no-brainer" to enter the U.S. market, said Jodan Ledford, Nashville-Tenn.-based CEO of Smart in the U.S.

Smart has more than 70,000 U.K. retirement plans on its platform and runs the U.K. defined contribution multiemployer Smart Pension Master Trust.

Mr. Ledford said Smart will look to use its experience reaching smaller employers in the U.K. with its U.S. PEP, which will likely launch at the end of the first quarter.

Though Mr. Ledford couldn't disclose any specifics, like the PEP's pooled plan provider, he said early success for Smart would be bringing on hundreds of plans within the first nine months on the way to thousands of plans in the years thereafter. "We onboarded 70,000 plans in the first five years in the U.K.; we would be thrilled if we could have that kind of success in the U.S. Obviously it's a bit different market," he said, noting that U.K. employers are required to offer workers a retirement plan.

Within the next five years, Mr. Ledford is hopeful that small employers will buy in. "Done right in the small plan market, I think you're going to see it go the way of the (outsourced chief investment officer) market has gone in the larger institutional retirement space, which is I think companies will once again keep being reminded that they make cars and food products, they don't necessarily need to be in the business of administering retirement plans," he said. "If these platforms grow big enough then, they're going to afford the economies of scale to all plan sponsors that are only afforded to some of the largest megaplans out there."

Mr. Ledford said PEPs have the potential to reach gig workers and Smart's model in the U.K. "demonstrates that we can be competitive and profitable searching down to that level."

In a letter to the Labor Department in February, the American Benefits Council in Washington urged the regulator to confirm that owner-employees of unincorporated businesses without common law employees can participate in PEPs in order to expand coverage. "PEPs can be established to provide gig workers across many industries with access to the economies of scale and lower costs available to large employers," the American Benefits Council wrote.

Not so fast
But Aron Szapiro, Morningstar Inc.'s director of policy research based in Washington, is less sold on PEPs transforming the retirement landscape. "I don't think that they're so attractive that there are going to be a bunch of employers to go, 'I wasn't offering a plan before but now with this pooled employer plan I'm going to,'" he said.

While proponents of PEPs say that employers will be happy to shed a bulk of their fiduciary responsibilities when joining a PEP, Mr. Szapiro said fiduciary risk isn't a big hurdle for small employers.

"The plaintiffs' bar is not going around suing employers with 50 workers," he said. "There's no money in it."

In states like Illinois, California and Oregon that have adopted automatic individual retirement account programs where most employers are required to enroll their workers in the state-backed program if they do not offer a retirement plan of their own, PEPs will likely be more attractive to employers, Mr. Szapiro said.

"If industry is smart, and I think industry is pretty smart, they will market themselves and say, 'Hey, you don't want to be in that crappy government plan; here, join my PEP. You will have a much high contribution limit as a principal so you can really put some money away and the fees are low and the investment options are better and we're going to start everybody in a more aggressive target-date fund,'" he said. "They should be able to market these things and they'll have the benefit of being truthful."

PEP contributions, like 401(k) plans, are limited to $19,500 annually for most savers, while IRA contributions are limited to $6,000 a year for most savers.

A bill was introduced in the House on Oct. 26 that, among dozens of other provisions, would permit 403(b) plans to participate in PEPs, expand the tax credit for small employer retirement plan startup costs and allow that tax credit to be used by employers that join a PEP for three years regardless of when the PEP was started. Under current law, if a small business joins a multiple employer plan that has already been in existence for three years, the startup credit is not available.

While it's unlikely the bill is signed into law this Congress because there are few legislative days remaining on the congressional calendar, "it's a great signal for bipartisanship for 2021," said Kent Mason, a partner with law firm Davis & Harman LLP in Washington.

For small employers, the bill's expansion of the tax credit is a major win, Mr. Mason said. "This can change the dynamics of whether small businesses can afford to have a plan," he added.  Starting Jan. 1, 2020, the retirement industry will see if those employers are ready to jump in.  Brian Croce, Pension & Investmentswww.pionline.com, November 2, 2020.

9.    RETIREMENT SAVING IS HARD EVEN FOR THOSE WHO CAN AFFORD IT:
Covid-19 has thrown a wrench in retirement planning. Rising unemployment, a volatile stock market and economic uncertainty are jeopardizing the ability of many families to plan for the future. However, even before the pandemic, saving for retirement was not easy. 

According to a U.S. Federal Reserve report from 2018, one in four non-retired households had no retirement savings at all, and more than 40% of non-retired adults said their retirement savings were not on track. Even for those households with the means to save, employers shifting from defined benefit plans (where they completely pay for and guarantee retirement income) to defined contribution plans (where employees contribute, participation is voluntary and there are no guarantees) made putting money away more complicated.

Why? Research has shown that the voluntary nature of these defined contribution plans created room for some common psychological blinds spots to get in the way of saving. For example, studies have found that when it comes to actively managing retirement plans, most people default to not doing anything year after year. Psychologists call this status quo bias, as it is far easier for someone to do nothing, and keep the status quo, than to take action.

Another blind spot is hyperbolic discounting, which occurs when someone puts too much weight on the present when making decisions about their money. As a result, they focus on how much money they have in the short term and tend to save less for the long run.

Both status quo bias and hyperbolic discounting tend to result in mistakes like not saving enough or not saving at all. There are other influences to watch out for as well. My own research has found that mental health issues such as anxiety and depression can decrease a person’s probability of holding a retirement account and a person’s retirement savings as a share of financial assets. These issues also are associated with having less money in retirement accounts and a greater probability of withdrawing from them. This is particularly pertinent today, as the Covid crisis has intensified depression and anxiety for many.

How can you overcome these influences? Recognizing blind spots can be difficult and even awareness of them is not sufficient to stop their effect on your behavior. The best way to prevent them from affecting your savings and financial future is to put the right processes in place.

If you do not have any retirement savings and you have the option to participate in a voluntary contribution plan through your employer, sign up now. If your employer does not have a defined benefit or defined contribution plan or you are self-employed, you should set up an Individual Retirement Account (IRA) with your bank or another financial institution.   

If you already have a retirement account, make it easier to contribute by setting up direct deposits to your account. Making these deposits automatic each month can help you sidestep hyperbolic discounting and other issues influencing how much you save. Your status quo will become regularly putting money away for retirement.

You also want to be wary of making withdrawals. The Internal Revenue Service recently relaxed some of the restrictions and penalties for early retirement withdrawals during the pandemic. However, withdrawing early should be a last resort. These funds take years to accumulate and could take years to replace. If you are nearing retirement, you may not have adequate time to make up for the withdrawal before you retire. Also, unless you are tapping into a Roth IRA that you contributed to with after-tax income, you will owe taxes on the money that you take out.

Following these guidelines can go a long way toward boosting your financial security.  Making regular contributions into, and avoiding early withdrawals from, your retirement nest egg not only increases your current balance but also helps your future balance grow exponentially. During tumultuous times, it is easy to discount the future, but now is precisely when you want to start planning ahead.  Vicki L. Bogan, Bloombergwww.bloomberg.com, November 1, 2020.

10.    THE MOST IMPORTANT RETIREMENT SAVINGS MOVE YOU CAN MAKE EACH DECADE:
Planning for retirement isn't something you can do in a few years' time -- it's something you should do your entire life. That idea, however, may seem daunting, so rather than get overwhelmed, here's a specific retirement-planning task you should focus on during each decade leading up to that milestone.

Your 20s: Open a retirement account
Many people spend much of their 20s paying off debt, socking away funds to buy a home, and grappling with the challenges of being a financially independent adult. As such, you may not have the capacity to max out a retirement plan each year in your 20s, and that's OK. What you should do during your 20s, however, is open a retirement account and start putting in some money, even if it's just $50 a month. If your employer offers a 401(k), that's a good place to start, especially if the company you work for matches contributions. If you don't have access to a workplace retirement plan, you can save in an IRA instead.

Your 30s: Focus on your investments
A winning investing strategy could help you capitalize on tax-advantaged growth in your 401(k) or IRA, so your 30s are a good time to establish a plan and choose funds or stocks that align with it. It pays to invest your retirement savings aggressively, all the while staying focused on keeping your fees to a minimum. For a 401(k), index funds may be a good bet, since they allow you to benefit from broad market gains without incurring the hefty fees actively managed mutual funds charge that heavily eat away at your returns.

Your 40s: Boost your savings rate
You may not have the financial means to max out your retirement plan during your 20s or even your 30s. But by the time your 40s roll around, you're likely to have already bought a home if that's a goal of yours, and your salary may be more substantial than it was earlier on in your career, so this is the time to ramp up your savings rate and pump more cash into your retirement plan. Doing so at this stage of life will still give your money plenty of time to grow.

Your 50s: Play catch-up
Maybe you didn't put much money into your retirement plan during your 20s and 30s, and your efforts during your 40s are still leaving you shy of where you want to be savings-wise. The good news is that once you turn 50, you get the opportunity to make catch-up contributions in your retirement plan, so if you're unhappy with your balance, take advantage. For both 2020 and 2021, you can put an extra $6,500 into your 401(k) if you're 50 or over, or an extra $1,000 into your IRA.

Your 60s: Protect yourself
Many people retire in their 60s -- some by choice, and some against their will. In fact, you never know when health issues (your own or a loved one's) might cause you to have to leave the workforce sooner than planned, so a good bet for your 60s is to play defense. Start shifting some of your retirement plan investments into bonds, and set yourself up with a backup income stream in case the market tanks and your savings take a beating. That income stream could be a robust emergency fund you keep in the bank, or a home equity line of credit you arrange for.
Sometimes, when you're presented with a big task, it helps to break it out into steps and tackle each one individually. Such may be a good bet when it comes to retirement planning. Knowing what's expected of you each decade could help you more easily stay on track so you're ultimately able to enjoy the comfortable retirement you deserve.  Maurie Backman, The Motley Fool, www.fool.com, November 1, 2020.

11.    THREE WAYS YOU CAN LOSE THE FREE MONEY OF A 401(K) MATCH:
The typical employer 401(k) match can give you about $1,680 extra per year based on Bureau of Labor Statistics averages for income and company matching percentages. Allowed to grow for a few decades, that money could easily end up worth tens of thousands of dollars. But it's not a guarantee. You may be eligible for a 401(k) match, but you need to avoid the following mistakes if you want to keep yours.

Not contributing to your 401(k)
Most employer matches require you to put money in your 401(k) first. Then, your employer matches either all of your contributions if it's a dollar-for-dollar match, or a portion of them if it's a $0.50-on-the-dollar match, up to a certain percentage of your annual income. That means the real value of your match depends on how much you earn in a year and how much you contribute to your 401(k).

Contributing nothing is usually a bad idea unless you need every dime you earn for your living expenses. You're just passing up free money, and once the year is over, there's no way to recoup that lost match. Aim to contribute at least enough to your 401(k) annually to get your full match so you don't miss out on what is essentially a salary bonus.

Leaving your job before you're fully vested
Some companies allow you to keep your employer-matched funds as soon as you've earned them, but this isn't the norm. Most companies have vesting schedules, which dictate how long you must work for a company before you're allowed to take your employer match with you if you leave.

There are a couple of different types of vesting schedules. A cliff vesting schedule requires you to work for your employer for a certain number of years before you are allowed to keep any of your employer match. Quitting before this point costs you everything your company has given you thus far. Your personal contributions are always yours to keep.

A graded vesting schedule releases your employer contributions to you gradually over time. You might get to keep 20% of your employer match if you leave the company after one year, 40% after two years, and so on. Again, this doesn't affect your personal contributions to your 401(k).

You don't have to worry about a vesting schedule if you've been with your company for more than six years or so, but if you're new and you don't plan to stick with the company long term, make sure you understand how leaving could affect your retirement balance. Ask your plan administrator or your company's HR department if you don't know what your vesting schedule is and try to stick it out until you're fully vested.

Paying too much in fees
All 401(k)s charge fees, but they're highly variable depending on what you invest in, how large your company is, and how much your employer covers. You want to keep your costs as low as possible so more of your savings -- and your employer match -- goes toward your retirement.

You can check your plan summary for information on some of your 401(k) fees, and your prospectus should tell you about your investment fees. If you're at a loss as to where to find this information, talk to your company's HR department or your 401(k) plan administrator.

You may not have much say over your plan's administrative costs, but you can control your investment fees to an extent by choosing your investments carefully. Try to keep these fees under 1% of your assets per year if you can. Index funds are one option to consider. They offer instant diversification and, because they track a market index, there's little fund turnover. That means less work for fund managers and lower fees for you.

Talk to your employer if your plan doesn't have any affordable investment options. The company may be willing to add some other choices if you're interested. It doesn't have to, but it never hurts to ask.

Saving for retirement is a massive undertaking, often requiring over $1 million. Your employer match can help you toward that goal, so make sure you avoid the above mistakes. Once you've gotten your 401(k) match for the year, you can re-evaluate and decide if a 401(k) is the best place for the rest of your savings. If you don't like your plan's fees or investment options, an IRA could be a better option. But if you prefer to manage all your funds in one place, stick with your 401(k).  Kailey Hagen, The Motley Fool, www.fool.com, October 24, 2020.

12.    DEBUNKING THE THREE BIGGEST MYTHS ABOUT DISABILITY BENEFITS AND WORK:
Join on Wednesday, November 18, 2020, at 3 p.m. ET, for the next Work Incentive Seminar Event (WISE) webinar!  Get the facts about Social Security disability benefits and work!  They're debunking myths and sharing important information to help you as you make the decision to work, look for a job, and successfully transition to work.

Join the webinar to find answers to questions like:

  • Where can I learn more about how working and earning income will affect my Social Security disability benefits?
  • What types of services and job supports are available to help me transition to the workplace and work towards my career goals?
  • How can I connect with a Ticket Program service provider?

Register now
Online: choosework.ssa.gov/wise
By Phone: 1-866-968-7842 or 1-866-833-2967 (TTY)
You will receive a registration confirmation message with instructions on how to log in to the webinar. Please be sure to check your spam folder.

WISE in American Sign Language (ASL)
Our ASL Guide can help individuals who are deaf or hard of hearing access our monthly WISE webinars using Video Relay Service.
Additional accessibility information is available on the registration page.

Questions about Ticket to Work?
The Ticket Program supports career development for people ages 18 through 64 who receive Social Security disability benefits (SSDI/SSI) and want to work. Monthly WISE webinars provide information about Social Security programs, Work Incentives and other resources that may help you, or someone you know, succeed on the path to financial independence through work.

Email: support@choosework.ssa.gov
Call: 1-866-968-7842 or 1-866-833-2967 (TTY)
Visit their website: choosework.ssa.gov 

Social Security Administration, www.ssa.gov, November 3, 2020.

13.    RETIREMENT SECURITY; OTHER COUNTRIES' EXPERIENCES WITH CAREGIVER POLICIES:
Family caregivers play a critical role in supporting the elderly population, which is growing rapidly. However, those who provide eldercare may risk their own employment, income, and retirement security.

We looked at other countries' approaches to supporting family members who provide eldercare, and the U.S. Department of Health and Human Services' efforts to develop a U.S. family caregiving strategy. The 3 nations we examined sought to help caregivers stay attached to the workforce, supplement lost income, and save for retirement.

For over a decade, Australia, Germany, and the United Kingdom (UK) have developed and implemented national approaches--including strategies, laws, and policies--to support family caregivers, according to experts GAO interviewed. Specifically, experts noted that these efforts could help caregivers maintain workforce attachment, supplement lost income, and save for retirement. As a result, their retirement security could improve. For example, experts said:

Care leave allows employees to take time away from work for caregiving responsibilities. Australia's and Germany's policies allow for paid leave (10 days per year of work or instance of caregiving need, respectively), and all three countries allow for unpaid leave though the duration varies.

Caregivers can receive income for time spent caregiving. Australia and the UK provide direct payments to those who qualify. Germany provides indirect payments, whereby the care recipient receives an allowance, which they can pass on to their caregiver.

Other Countries' Policies to Support Caregivers
Other Countries' Policies to Support Caregivers
Experts in all three countries cited some challenges with caregiver support policies. For example, paid leave is not available to all workers in Germany, such as those who work for small firms. In Australia and the UK, experts said eligibility requirements for direct payments (e.g., limits on hours worked or earnings) can make it difficult for someone to work outside their caregiving role. Experts in all three countries said caregivers may be unaware of available supports. For example, identifying caregivers is a challenge in Australia and the UK.

As required under the RAISE Family Caregivers Act, the Department of Health and Human Services (HHS) convened the Family Caregiving Advisory Council (FCAC)--a stakeholder group that is to jointly develop a national family caregiving strategy. As of July 2020, HHS and the FCAC reported limited information on other countries' approaches, and neither entity had concrete plans to collect more. In September 2020, HHS officials provided sources they recently reviewed on selected policies in other countries, and they further noted that HHS staff, FCAC members, and collaborating partners have subject-matter expertise and bring perspectives about other countries' efforts into their discussions.

Why GAO Did This Study
Family caregivers play a critical role in supporting the elderly population, which is growing at a rapid rate worldwide. However, those who provide eldercare may risk their own long-term financial security. Other countries have implemented policies to support caregivers. In recognition of challenges caregivers face in the United States, Congress directed HHS, in consultation with other federal entities, to develop a national family caregiving strategy. GAO was asked to provide information about other countries' efforts that could improve the retirement security of parental and spousal caregivers.

This report examines (1) other countries' approaches to support family members who provide eldercare, (2) challenges of these approaches, and (3) the status of HHS' efforts to develop a national family caregiving strategy. GAO conducted case studies of three countries--Australia, Germany, and the United Kingdom--selected based on factors including rates of informal care (i.e., help provided to older family members or friends) and the types of policies they have that could improve caregivers' retirement security. GAO interviewed government officials and experts and reviewed relevant federal laws, research, and documents.

GAO's draft report recommended that HHS collect additional information about other countries' experiences. In response, in September 2020, HHS provided an update on its efforts to do so. As a result, GAO removed the recommendation and modified the report accordingly.   U.S. Government Accountability Office, www.gao.gov, GAO-20-623, Published:September 30, 2020, Released: October 30, 2020.

14.    IRS MAKES IT EASIER TO SET UP PAYMENT AGREEMENTS; OFFERS OTHER RELIEF TO TAXPAYERS STRUGGLING WITH TAX DEBTS:
The Internal Revenue Service today announced a number of changes designed to help struggling taxpayers impacted by COVID-19 more easily settle their tax debts with the IRS.

The IRS assessed its collection activities to see how it could apply relief for taxpayers who owe but are struggling financially because of the pandemic, expanding taxpayer options for making payments and alternatives to resolve balances owed.

“The IRS understands that many taxpayers face challenges, and we’re working hard to help people facing issues paying their tax bills,” said IRS Commissioner Chuck Rettig. “Following up on our People First Initiative earlier this year, this next phase of our efforts will help with further taxpayer relief efforts.”

“We want people to know our IRS employees are committed to continue helping taxpayers wherever possible, including offering many options for those struggling to pay their tax bills,” said Darren Guillot, the IRS Small Business/Self-Employed Deputy Commissioner for Collection and Operations Support. Guillot discussed the new relief options in a new edition of IRS “A Closer Look.”

Taxpayers who owe always had options to seek help through payment plans and other tools from the IRS, but the new IRS Taxpayer Relief Initiative is expanding on those existing tools even more.

The revised COVID-related collection procedures will be helpful to taxpayers, especially those who have a record of filing their returns and paying their taxes on time. Among the highlights of the Taxpayer Relief Initiative:

  • Taxpayers who qualify for a short-term payment plan option may now have up to 180 days to resolve their tax liabilities instead of 120 days.
  • The IRS is offering flexibility for some taxpayers who are temporarily unable to meet the payment terms of an accepted Offer in Compromise.
  • The IRS will automatically add certain new tax balances to existing Installment Agreements, for individual and out of business taxpayers. This taxpayer-friendly approach will occur instead of defaulting the agreement, which can complicate matters for those trying to pay their taxes.
  • To reduce burden, certain qualified individual taxpayers who owe less than $250,000 may set up Installment Agreements without providing a financial statement or substantiation if their monthly payment proposal is sufficient. 
  • Some individual taxpayers who only owe for the 2019 tax year and who owe less than $250,000 may qualify to set up an Installment Agreement without a notice of federal tax lien filed by the IRS.
  • Additionally, qualified taxpayers with existing Direct Debit Installment Agreements may now be able to use the Online Payment Agreement system to propose lower monthly payment amounts and change their payment due dates.

Additional details on the Taxpayer Relief Initiative
The IRS offers options for short-term and long-term payment plans, including Installment Agreements via the Online Payment Agreement (OPA) system. In general, this service is available to individuals who owe $50,000 or less in combined income tax, penalties and interest or businesses that owe $25,000 or less combined that have filed all tax returns. The short-term payment plans are now able to be extended from 120 to 180 days for certain taxpayers.

Installment Agreement options are available for taxpayers who cannot full pay their balance but can pay their balance over time. The IRS expanded Installment Agreement options to remove the requirement for financial statements and substantiation in more circumstances for balances owed up to $250,000 if the monthly payment proposal is sufficient. The IRS also modified Installment Agreement procedures to further limit requirements for Federal Tax Lien determinations for some taxpayers who only owe for tax year 2019. 

In addition to payment plans and Installment Agreements, the IRS offers additional tools to assist taxpayers who owe taxes:

Temporarily Delaying Collection — Taxpayers can contact the IRS to request a temporary delay of the collection process. If the IRS determines a taxpayer is unable to pay, it may delay collection until the taxpayer's financial condition improves.

Offer in Compromise — Certain taxpayers qualify to settle their tax bill for less than the amount they owe by submitting an Offer in Compromise. To help determine eligibility, use the Offer in Compromise Pre-Qualifier tool. Now, the IRS is offering additional flexibility for some taxpayers who are temporarily unable to meet the payment terms of an accepted offer in compromise.

Relief from Penalties — The IRS is highlighting reasonable cause assistance available for taxpayers with failure to file, pay and deposit penalties. First-time penalty abatement relief is also available for the first time a taxpayer is subject to one or more of these tax penalties. 

All taxpayers can access important information on IRS.gov. Many taxpayers requesting payment plans, including Installment Agreements, can apply through IRS.gov without ever having to talk to a representative.

Other requests, including this new relief, can be made by contacting the number on the taxpayer’s notice or responding in writing. However, to request relief, the IRS reminds taxpayers they must be responsive when they receive a balance due notice.

“If you’re having a tax issue, don’t go silent. Please don’t ignore the notice arriving in your mailbox,” Guillot said. “These problems don’t get better with time. We understand tax issues and know that dealing with the IRS can be intimidating, but our employees really are here to help.”

Throughout COVID-19, the IRS has continued to adjust operations to help ensure the health and safety of employees and taxpayers, including the extensive and temporary relief of the IRS People First Initiative. More information and background on the collection relief and procedures can be found in “A Closer Look.”

“While it’s been important for us and the nation to resume our critical tax compliance responsibilities, we continue to assess the wide-ranging impacts of COVID-19 and other difficulties people are experiencing,” Guillot said.  IRS Newswire IR-2020-248, www.irs.gov, November 2, 2020.

15.  FOR THOSE WHO LOVE WORDS:   
What's the difference between “Confident” vs. “Confidant” vs. "Confidante"? Learn the answer here.

16.  A THOUGHT FOR TODAY:  
"A life spent making mistakes is not only more honorable, but more useful than a life spent doing nothing." - George Bernard Shaw

17.  TODAY IN HISTORY:  
On this day in 1940, Franklin D. Roosevelt is re-elected President of the United States for an unprecedented third term, defeating Republican candidate Wendell Willkie. Roosevelt ran and won, yet a fourth term, taking office again on January 20, 1945.  Learn more here.

18.  REMEMBER, YOU CAN NEVER OUTLIVE YOUR DEFINED RETIREMENT BENEFIT.

Copyright, 1996-2020, all rights reserved.

Items in this Newsletter may be excerpts or summaries of original or secondary source material, and may have been reorganized for clarity and brevity. This Newsletter is general in nature and is not intended to provide specific legal or other advice.


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