Peter Gulia Posted April 1 Posted April 1 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? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
Paul I Posted April 1 Posted April 1 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 1
Peter Gulia Posted April 1 Author Posted April 1 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? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
Paul I Posted April 1 Posted April 1 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. Peter Gulia 1
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