Would further requirements for electronic-funds-transfer affect employee-benefits practitioners?

[Peter Gulia]

President Trump’s Executive Order Modernizing Payments To and From America’s Bank Account calls for payments to the US government to be made only by electronic-funds-transfer. https://www.govinfo.gov/content/pkg/FR-2025-03-28/pdf/2025-05522.pdf

Is there a situation in which lacking an opportunity to pay—one’s own payment, or a client’s payment—by a paper check would be a hardship for a retirement, health, or other employee-benefits practitioner?

[Paul I]

A very large portion of business-to-business transactions are electronic payments.  This differs from plan participants we serve.  The FDIC provides a survey of unbanked or underbanked households https://www.fdic.gov/household-survey which has some surprising numbers.  For example, in Mississippi 9.4% of households are unbanked.

It can be challenging to make payments to this segment of the population.  Many within this segment use non-bank money orders, check cashing services or non-bank money transfer services.  As an industry, we need to be mindful of the needs of the populations we serve.

[Peter Gulia]

The order’s § 4(a)(1)(i) directs the “Secretary of the Treasury [to] review and, as appropriate, revise procedures for granting limited exceptions where electronic payment and collection methods are not feasible, including exceptions for: (i) individuals who do not have access to banking services or electronic payment systems[.]”

For an employer organization’s payment to the US Treasury, would a new electronic-only requirement make work difficult for a retirement-plans practitioner?

[Paul I]

Generally, I would say an electronic-only requirement would not be onerous for the vast majority of practitioners.  Most already use EFTPS for transmitting taxes and Pay.Gov for other types of payments.