Tag Archives: Social Security

Generation X: Savings, pensions, and Social Security

pink-lesleyThis is the second blog in a three-part series exploring the economic history and future of Generation X. The series also focuses on what this generation can do to prepare for retirement. In the first installment, we highlighted some of Generation X’s financial predicaments.

Generation X faces major retirement challenges.

Besides the issues of job security and stagnant wages, there is the topic of cold hard cash—saving enough, having enough, allocating enough.

Some Gen Xers know that they started saving too late and wouldn’t be able to make up the difference. Others were worried because they’d been saving since they got their first jobs—20+ years ago—and felt that that money still wouldn’t be enough when they reach retirement age. And others just couldn’t save. As one fellow Gen Xer put it, “My wife and I don’t make enough together to save for retirement and the kids.” And let’s not fool ourselves—“retirement age” no longer has a firm definition.

We Gen Xers aren’t alone. According to the 2015 Retirement Confidence Survey published by the Employee Benefit Research Institute, “Almost two-thirds of workers (64 percent) say they feel they are behind schedule when it comes to planning and saving for retirement.” This survey also notes that cost of living and day-to-day expenses top the list of reasons why workers don’t save (or don’t save enough) for retirement.

Pensions, often referred to as defined benefit (DB) plans, used to be a mainstay. But they are not as common as they once were, and this, too, is affecting Generation X. In fact, according to Jennifer Leigh Parker on CNBC.com, Generation X is the first generation to see its pension leg replaced by 401(k) savings plans, which were increasingly adopted during the 1980s. The 401(k) plans are portable but aren’t designed as a monthly “pension paycheck.” The owner of the account balance has to take significant action to understand and convert any or all of it to that pension paycheck. Gen Xers , in general, will find that its collective savings plan account balances are woefully deficient and for many, sitting in a tax-deferred account. And the Internal Revenue Service (IRS) can’t wait for us to start cashing them out.

Additionally, we Gen Xers, who have been paying Social Security payroll tax for years, may not receive full benefits upon reaching retirement age.

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Retirement, social security, and health benefit limits for 2016

With the release of the September 2015 Consumer Price Index (CPI) by the U.S. Bureau of Labor Statistics, the Social Security Administration (SSA) and the Internal Revenue Service (IRS) have announced the 2016 figures for, respectively, the Social Security program and tax-qualified retirement plan benefits. In most cases, the figures are unchanged from 2015. The 2016 adjusted figures for high-deductible health plans (HDHPs) and health savings accounts (HSAs) included in this Client Action Bulletin were released by the IRS earlier this year and are provided here for convenience.

When to begin Social Security: The conundrum

Bradley_JeffIn retirement planning, especially in discussions involving those who retired early or are thinking of retiring early, this question usually comes up: When do you plan to start taking Social Security?

To answer this question, we have to look at two alternatives:

1) If one defers payment to age 70 (currently the latest permissible date for increased benefits) or some other age, a higher monthly benefit is payable.
2) Instead, if one decides to commence payment early, say at age 62, the question then becomes how many years it takes to come out ahead by deferring. In other words, how many years does it take to reach the “break-even” point?

For example, a maximum earner, retiring at age 62 in 2015 could expect a monthly benefit of approximately $2,014. Instead, if he or she defers to age 70, that amount is estimated to be $3,544 (in 2015 dollars).

If we assume 2% CPI, the total benefits received from age 62 through age 78 are approximately $484,000. If deferred to age 70, the total benefits received from age 70 through age 78 are approximately $486,000. Thus, the breakeven point is somewhere between 16 and 17 years from age 62.

Why is it difficult to pick one or the other? Let’s examine the issues.

Many financial advisers suggest that a retiree would always be better off deferring commencement as long as possible as this maximizes the benefit. However, this may not always be the case and is really a decision that depends on several factors, many of them personal.

Obviously, to make the best decision, retirees will need to know if they (and their spouses, if applicable) will be alive at the “breakeven” point(s). Because no one knows the answer to this question, one possible approach would be to look at the present value of the two options at age 62. Using the current mortality table to calculate minimum lump sum distributions under the Internal Revenue Code and a 2% real interest rate assumption (note that the actual real rate of interest used will vary based on individual expectations), the present value of the benefit payable at age 62 to a single person is approximately $430,000 and the present value of the deferred benefit is approximately $452,000. However, if a 4% real interest rate is used, the present values are $347,000 and $327,000, respectively. Thus, the present value depends on the underlying assumptions which will vary by individual, making it somewhat subjective.

What about the “utility” of the immediate cash? In this regard, you should consider cash needs, both immediate and long-term. This would mean no Social Security cash now but more in the future versus some Social Security cash now but less in the future. We should note that it doesn’t do any good to have more money in the future if we aren’t alive or aren’t able to enjoy it. To assess cash needs, you will have to run the numbers because everyone’s situation is different.

Also, many proponents of delaying Social Security note that deferring it is a significantly lower-cost alternative than buying commercial longevity insurance. The key decision point here is that it shouldn’t matter which is a lower-cost alternative. What matters is whether longevity insurance is needed or wanted in the first place. If so, then deferring Social Security may be the right move. If you don’t want longevity insurance, deferring Social Security may not be the right move.

Don’t forget taxes! Social Security can be taxable to some individuals and can affect Modified Adjusted Gross Income (MAGI) which is used to determine eligibility for Federal tax subsidies under the Affordable Care Act.

And then we have the latest Social Security Trustee’s Report. Here’s an excerpt:

“The theoretical combined OASDI trust funds have a projected depletion date of 2033, unchanged from last year’s report. After the depletion of reserves, continuing tax income would be sufficient to pay 77 percent of scheduled benefits in 2033 and 72 percent in 2088.”

So what does this mean? Taking Social Security early may be the bird in the hand. Modeling a 23% haircut may be the deciding factor on whether Social Security should be taken as soon as possible. On the other hand, 2033 is a long way out, and we will have to wait and see.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

IRS issues guidance expanding preapproved determination letter program
The Internal Revenue Service (IRS) has issued Revenue Procedure 2015-36, which expands the scope of the preapproved program to include defined benefit plans containing cash balance features and defined contribution plans containing employee stock ownership plan (ESOP) features and extends the deadline for submitting on-cycle applications for opinion and advisory letters for preapproved defined benefit plans to October 30, 2015.

In addition, this revenue procedure updates Rev. Proc. 2011-49 to reflect changes made to the determination letter program in 2012. Rev. Proc. 2011-49 is superseded.

Revenue Procedure 2015-36 will appear in IRB 2015-25 dated June 22, 2015.

To read the entire Revenue Procedure, click here.

SSA issues final rule on 60-month period of employment requirement for government pension offset exemption
The Social Security Administration (SSA) has issued a final rule that adopts, with clarifying changes, the proposed rule previously published in the Federal Register on August 3, 2007. This final rule revises the SSA’s Government Pension Offset (GPO) regulations to reflect changes to the Social Security Act (Act) made by section 9007 of the Omnibus Budget Reconciliation Act of 1987 (OBRA 1987) and Section 418 of the Social Security Protection Act of 2004 (SSPA). These regulations explain how and when the SSA will reduce the Social Security spouse’s benefit for some people who receive federal, state, or local government pensions if Social Security did not cover their government work.

To read the entire final rule, click here.

IRS updates listing of required modifications for cash balance and employee stock ownership plans
The IRS has published a collection of information packages designed to assist sponsors who are drafting or redrafting plans to conform with applicable law and regulations related to cash balance and employee stock ownership plans.

Document release: ERISA Form 8955-SSA, 2-D Barcode Standards
This document covers only the 2D barcode on ERISA Form 8955-SSA, valid for plan years 2009 to 2011. The 2D barcode is intended to represent the information on the paper form. Barcodes for this form are generated from two sources:

  • The IRS Form 8955-SSA Fill-able PDF produces a barcode after printing the form in Adobe.
  • The approved software vendors for Form 8955-SSA produce a barcode when printing their forms from their software packages.

To read the entire document, click here.

IRS explanation, worksheet (alert guidelines), and deficiency check sheets
The IRS has issued three explanations, worksheets (alert guidelines), and deficiency check sheets:

IRS posts nonqualified deferred compensation audit techniques guide
The IRS has posted a guide on nonqualified deferred compensation audit techniques. The guide provides:

  • An overview
  • Audit potential
  • Compliance focus
  • General audit steps

To access the guide, click here.

IRS issues latest Employee Plans News
The IRS has issued the June 10, 2015, edition of its newsletter Employee Plans News. The latest edition contains the following content:

  • Preapproved plan program expanded to include cash balance plans and ESOPs
  • Sample plan language (listings of required modifications) for ESOPs, and cash balance and 403(b) plans
  • Guidance for permanent program for late 5500EZ filers
  • IRS Nationwide Tax Forums begin in July
  • Changes to Forms 5500 for 2014
  • IRS names seven new members to Advisory Committee on Tax Exempt and Government Entities (ACT) panel
  • Updated Voluntary Correction Program fee chart

To read the newsletter, click here.

IRS updates 403(b) fix-it guide
The IRS has updated its 403(b) Plan Fix-It Guide. The document contains charts and explanations that address potential issues in plan administration. It includes how to find, fix, and avoid common plan errors, with hypertext links to online forms and guidance.

To access the fix-it guide, click here.

COLAs for retirement, Social Security, and health benefits for 2015

With the release of the September 2014 Consumer Price Index (CPI) by the U.S. Bureau of Labor Statistics, the Social Security Administration (SSA) and the Internal Revenue Service (IRS) have announced cost-of-living adjusted (COLA) figures for Social Security and retirement plan benefits, respectively, for 2015. The 2015 adjusted figures for high-deductible health plans (HDHPs) and health savings accounts (HSAs) included in this Client Action Bulletin were released by the IRS earlier this year and are provided here for convenience.

The end of SSA letter-forwarding service poses an obstacle for plan sponsors

The termination by the Social Security Administration (SSA) of its letter-forwarding service creates a hindrance for retirement plan sponsors. The service allowed sponsors to mail letters trying to locate missing participants regarding their benefits as required under ERISA.

In the latest issue of Milliman’s DB Digest, Alexandra Moen addresses the implications sponsors face in fulfilling their ERISA obligations. Here is an excerpt:

ERISA, IRS, SSA, and DOL regulations have consistently emphasized “reasonable methods” when attempting to locate participants. The SSA and IRS letter-forwarding services have historically provided fiduciaries great confidence that all appropriate steps had been taken. Free Internet search sites and social media can be unreliable and inaccurate. Are these methods “reasonable” if they fail to locate a participant? Several questions regarding these government agency announcements remain, but it seems certain that plan sponsors will now have to put more time, money, and effort into these required searches for plan participants and beneficiaries.

Many plan documents do not include wording about participants who are unable to be located. It is permissible to forfeit the benefit after all reasonable means have been exhausted, as long as the benefit would be reinstated if the participant makes a claim for it. Plan sponsors may also wish to consider adding wording to the Summary Plan Description or website telling the participant of their responsibility to inform the plan of address changes, especially if their benefit could be forfeited.

To read more DB Digest articles, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

Social Security published article on two benefits provisions
A new article published by the Social Security Administration (SSA) uses health and retirement study data to investigate the effects of the SSA’s Windfall Elimination Provision (WEP) and Government Pension Offset (GPO) on Social Security benefits received by households. The provisions reduce benefits for individuals or the dependents of individuals whose work histories include jobs for which they were entitled to a pension and were not subject to Social Security payroll taxes (“noncovered” employment).

To read the entire article, click here.

IRS updates FAQ on 403(b) preapproved plan program remedial amendment period
The Internal Revenue Service (IRS) has updated a frequently asked question (FAQ) regarding the 403(b) preapproved plan program remedial amendment period. According to the IRS, by adopting a 403(b) preapproved plan by the deadline (to be established and announced by the IRS), the program allows an eligible employer to retroactively correct defects in the form of its written 403(b) plan back to the first day of the plan’s remedial amendment period, which is the later of: January 1, 2010, or the plan’s effective date.

The employer’s adoption of a preapproved 403(b) plan that has a favorable opinion of advisory letter automatically corrects any defects in its prior written 403(b) plan, but not defects in any documents incorporated by reference into the prior plan). Interim amendments are not required for a plan to be eligible for this remedial amendment period.

403(b) plans sponsors who didn’t adopt a written plan before December 31, 2009, can use the 403(b) Voluntary Program Submission Kit to correct this error.

The IRS also indicated that at this time it does not anticipate opening a determination letter program for individually designed 403(b) plans.

For more information, click here.

IRS updates guide to common qualified plan requirements
The IRS has recently updated its web page on common qualified retirement plan requirements. The list highlights some of the more important plan requirements to help employers in implementing practices, procedures, and internal controls to monitor plan operations.

For more information, click here.

JCT releases estimates of federal tax expenditures for fiscal years 2014-2018
The Joint Committee on Taxation (JCT) has released its latest summary of federal tax expenditures entitled “Estimates of federal tax expenditures for fiscal years 2014-2018” (JCX-97-14). The JCT says that the employer health exclusion will cost the government $785.1 billion in forgone revenue from 2014 to 2018 and that the next exclusion of defined contribution plans will cost $399 billion.

To download a copy of the report, click here.

IRS updates posting on Voluntary Correction Program fee schedule and Form 8951
The IRS has updated its web page in regards to the Voluntary Correction Program (VCP) fee schedule and Form 8951 (Compliance Fee for Application for Voluntary Correction Program [VCP]).

To access Form 8951, click here.
To view the updated VCP fee schedule page, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

IRS private letter ruling on lump sum window for those in pay status will not violate MDR
The Internal Revenue Service (IRS) recently released a private letter ruling (PLR 201431034) stating that a lump sum window for participants in pay status will not violate minimum distribution requirements (MDR).

According to the PLR:

Under the amendment, the Covered Individuals would have a specified limited window period of no more than 180 days during which they could elect to receive in lieu of their current annuity what Company A represents is the actuarial present value of their remaining benefits under the aforementioned Plans, in the form of a single lump sum payment. The window period may consist of multiple phases, such as an opt-in phase during which Covered Individuals would have the opportunity to proceed through the remainder of the window program and an election phase during which Covered Individuals could elect to receive, in lieu of their current annuity, the actuarial present value of their remaining annuity payments in the form of an immediate lump sum, and the extent the law requires, a qualified joint and survivor annuity (including a single annuity for retirees who are not married), or a qualified optional survivor annuity.

To read the entire private letter ruling, click here.

Social Security trustees retain projected year of trust fund reserve depletion
The Social Security Board of Trustees recently released its annual report on the long-term financial status of the Social Security Trust Funds. The combined asset reserves of the Old-Age and Survivors Insurance, and Disability Insurance (OASDI) Trust Funds are projected to become depleted in 2033, unchanged from last year, with 77% of benefits still payable at that time. The DI Trust Fund will become depleted in 2016, also unchanged from last year’s estimate, with 81% of benefits still payable.

To read the entire report, click here.

PBGC creates online resource guide on choosing between lump sum or annuity
The Pension Benefit Guaranty Corporation (PBGC) recently created an online resource that provides information to assist with “Making a choice: Lump sum or annuity?”

The new resource page allows the public to get some insight on key questions that should be answered when making this important decision and offers other hypothetical scenarios.

To read the entire guide, click here.

401(k) plans: Improvements can be made to better protect participants in managed accounts
The U.S. Government Accountability Office (GAO) has issued the report “401(k) plans: Improvements can be made to better protect participants in managed accounts.” The report reviews eight managed account providers that represented an estimated 95% of the industry involved in defined contribution plans in 2013, showing that the providers varied in how they structured managed accounts, including the services they offered and their reported fiduciary roles.

To read the entire report, click here.

IRS posts three FAQs regarding EGTRRA determination letter program for preapproved plans
The IRS has posted three new frequently asked questions (FAQs) regarding the Economic Growth and Tax Relief Reconciliation Act (EGTRRA) determination letter program for preapproved plans.

Question #4: “If I file a determination letter application for my pre-approved defined benefit plan by April 30, 2012, and the Service determines that additional remedial amendments are needed, will I have time to adopt the amendments?”
Question #6: “I am an adopter of a volume submitter plan and I wish to make certain changes to the pre-approved document. When I file a determination letter application, must I incorporate these changes in the pre-approved plan document or may I make the changes as separate amendments to the plan?”
Question #8: “I am filing Form 5310 to terminate my EGTRRA-approved M&P or volume submitter plan. Must I include copies of interim amendments with my application?”

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

Social Security Administration defines policy for same-sex married couples
The Social Security Administration (SSA) has published new instructions that allow the agency to process more claims in which entitlement or eligibility is affected by a same-sex relationship. These instructions come in response to last year’s U.S. Supreme Court decision in U.S. vs. Windsor, which found Section 3 of the Defense of Marriage Act unconstitutional.

This latest policy development lets the agency recognize some nonmarital legal relationships as marriages for determining entitlement to benefits. These instructions also allow Social Security to begin processing many claims in states that do not recognize same-sex marriages or nonmarital legal relationships.

For more information, click here.

GASB’s OPEB proposals and related resources
The Governmental Accounting Standards Board (GASB) has published two proposed statements intended to significantly improve financial reporting by state and local governments of other post-employment benefits (OPEB), such as retiree health insurance. The GASB also published a third exposure draft that would establish requirements for pensions and pension plans that are outside the scope of the pension standards the GASB released in 2012.

To download the three exposure drafts, click here.

FASB issues guidance on stock compensation
The Financial Accounting Standards Board (FASB) has issued Update No. 2014-12, guidance intended for companies that award stock compensation that hinges on a performance target being met and allows vesting if the covered employee isn’t working when the target is hit.

The guidance is to be effective for annual periods and interim periods within those annual periods starting after December 15, 2015, according to the FASB. The rules prescribe the same effective date for private and public business entities.

To learn more about the FASB guidance, click here.

Thanks again, identity thieves!

Benbow-DavidOnce again, the bad deeds of a few are making it more difficult for many honest people to do their jobs. Remember the Social Security Death Index? It was a free and extremely useful site that allowed you to look up people and determine if and when they had died. A nice thing to know if you happen to pay pension benefits for life.

But security concerns caused the free lookup service to be taken offline. Searches can now be conducted for $10 each or an unlimited subscription to the “Death Master File” can be purchased for $995. For most pension administrators, the price tag is too steep (unless you’re aware that a few groups used their unlimited subscriptions to provide free lookup services again), but an identity thief can get enough information from the Death Master File for it to be a very profitable business model.

This situation caught the eye of U.S. Senator Bill Nelson (D-FL), who related the story of a child who died just before her 5th birthday, only to have her identity stolen from the Death Master File and used to file for a bogus tax refund. This led to a line item in the budget deal that was signed last month calling for further restrictions to the Death Master File.

The U.S. Commerce Department, which administers the Death Master File, has been tasked to create a process to certify individuals with legitimate needs for the file within three months. Meanwhile, all the pension administrators, insurance companies, and genealogy buffs who use the information legitimately can look forward to navigating the new certification process, and the identity thieves can figure out how to steal the identity of someone who’s already been certified.