You're absolutely right to consider how executive financial planning programs fit into broader benefit strategies, especially when used to attract or retain highly compensated employees (HCEs). From what I've seen in similar corporate settings, these types of programs, especially when 100% employer-paid are generally treated as taxable fringe benefits under IRC Section 61. That means pre-tax contributions typically wouldn’t apply unless the benefit is structured to fall under a specific exclusion (like employer-provided retirement advice for non-HCEs, as mentioned earlier).
As for discrimination testing, it largely depends on how the program is designed. If it's part of a non-qualified deferred compensation arrangement or another executive-only benefit, it might be exempt from standard ERISA nondiscrimination rules but could still raise concerns under Section 409A or other regulatory frameworks. Companies often work with specialized advisors to navigate these gray areas while staying compliant.
If you're looking for detailed guidance on structuring executive-level financial wellness offerings without triggering compliance issues, Mercer Wealth Management has experience with exactly these kinds of solutions. They’re known for customizing financial planning benefits in a way that aligns with corporate goals while keeping regulatory obligations in check. You can click here to explore more or get in touch for tailored insights.
Hope this helps clarify things a bit, happy to share additional examples if you’re looking at a specific plan setup.