The 401k start-up tax credit promises to slash costs of offering a retirement plan, yet few companies are claiming it. What deeper problem is at play?
Posts From Christopher Carosa, CTFA
When too many moving parts are introduced at once, decisions slow down. Employers may delay action while trying to understand their options, or they may default to inaction when the path forward is not clear.
Roth catch-up mandate errors are already occurring—and not where most fiduciaries expect. When payroll systems break down, who carries the risk?
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401k 3(38) delegation sounds like a clean handoff, but what if the liability never really leaves the room?
That is the line committees cannot afford to miss. They cannot interfere, but they also cannot ignore. Those two verbs define the narrow lane that fiduciaries must stay in if they want delegation to work as intended.
401k participant understanding is no longer optional. Fiduciaries may do everything right—yet still face risk when participants make uninformed decisions.
Fiduciaries can follow every step of a prudent process and still end up with outcomes they did not anticipate. That’s not how fiduciary risk is supposed to work. Or at least, not how it used to work.
Saver’s Match fiduciary risk is arriving faster than the rules meant to govern it. Plans must decide how to respond before the system is fully built.
Once the regulatory gaps are acknowledged, the issue quickly shifts from theory to action. Plan sponsors are not just waiting for guidance. They are being forced to decide whether to engage with the Saver’s Match at all.









