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Posted

Has some good ideas, but this one caught my eye as a HORRIBLE idea:

  • QDRO expenses—retirement plans of all types would be required to allocate QDRO expenses to the plan as a whole and not to the individual(s) involved in the specific domestic relations order.
If I'm an alcoholic and a drug addict and get divorced 4 times, why should other participants have to pay for my stupidity and obnoxious behavior? Presumably this is so ridiculous that even Congress should be able to figure it out, and strike this provision if this bill or any part of it passes...
Posted

Has some good ideas, but this one caught my eye as a HORRIBLE idea:

  • QDRO expenses—retirement plans of all types would be required to allocate QDRO expenses to the plan as a whole and not to the individual(s) involved in the specific domestic relations order.
If I'm an alcoholic and a drug addict and get divorced 4 times, why should other participants have to pay for my stupidity and obnoxious behavior? Presumably this is so ridiculous that even Congress should be able to figure it out, and strike this provision if this bill or any part of it passes...

Ah.... Some things old are new again!

(been in the business long enough to remember the DOL's position on this, where they were for this before they were against this).

Posted

Presumably this is so ridiculous that even Congress should be able to figure it out, and strike this provision if this bill or any part of it passes...

Does history support this presumption?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

Presumably this is so ridiculous that even Congress should be able to figure it out, and strike this provision if this bill or any part of it passes...

Does history support this presumption?

Not recent history!

Posted

This synopsis: http://www.americanbenefitscouncil.org/documents2013/rpsea_neal_113th-summary.pdf says "QDRO Expenses - Until 2003, it was DOL’s view that any expenses attendant to providing information to a beneficiary or making a QDRO determination must be allocated to the plan as a whole. However, in 2003, DOL reversed this longstanding position and allowed defined contribution plans to charge the participant and alternate payee for any QDRO-related expenses. The bill would require all types of plans to allocate QDRO-related expenses to the plan as a whole."

It's in a section headed "Providing Equity in Divorce". Doesn't make sense. Unless we operate under the assumption that the DOL is always wrong.

On the upside, I think some people will be very pleased to see: "The bill clarifies that safe harbor contributions must be nonforfeitable only at the time they are designated as safe harbor contributions, and therefore, forfeitures can fund safe harbor contributions."

Kurt Vonnegut: 'To be is to do'-Socrates 'To do is to be'-Jean-Paul Sartre 'Do be do be do'-Frank Sinatra

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