OMB Poised to Review Proposed Rule on Paper Statements and E-disclosures

Ironwood Retirement Plan Consultants • January 15, 2026

The regulatory follow-through on SECURE 2.0’s paper-statement mandate is now entering its next stage. The 2022 law includes provisions affecting how benefit statements must be delivered. In general, defined contribution (DC) plans will be required to furnish participants with at least one paper benefit statement each year, unless they affirmatively elect electronic delivery, for plan years beginning after December 31, 2025. An additional provision directs the Department of Labor (DOL) to update its electronic-delivery regulations so that participants and beneficiaries who first become eligible after that date receive a one-time paper notice before their required statements and related disclosures can be furnished electronically.


On September 30, 2025, the DOL’s Employee Benefits Security Administration (EBSA) agency submitted a proposed rule, “Requirement to Provide Paper Statements in Certain Cases — Amendments to Electronic Disclosure Safe Harbors,” to the Office of Management and Budget (OMB). The proposal would update 29 CFR 2520.104b-1(c), part of the DOL’s regulation governing the timing and method for furnishing ERISA disclosures, and 29 CFR 2520.104b-31, the DOL’s electronic-delivery framework often referred to as the “notice-and-access” safe harbor.


The OMB announcement signals that detailed rules are forthcoming on matters that may include formatting, timing and content requirements, delivery standards, and participant elections for statements. The proposed rule follows EBSA’s August 2023 Request for Information, in which the agency sought public input on SECURE 2.0’s various reporting and disclosure mandates.


Once the OMB completes its review, the proposal will be released to the public as a Notice of Proposed Rulemaking, which will subsequently open a formal comment period. OMB typically has up to 90 days (which may be extended) to review a proposal and decide whether to clear it for publication or send it back for revision, though there is no set minimum time frame for review. Plan sponsors may want to monitor the rule’s progress as it moves through the federal rulemaking procedures, and the industry and public comment period.


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By Ironwood Retirement Plan Consultants February 2, 2026
The start of a new year is a natural time to set fresh financial resolutions, but unfortunately most don’t last past February. One reason may be that our money goals often don’t align with the way we naturally think or how we stay motivated once the initial enthusiasm fades. A study of more than 2,400 individuals published by American Psychologist found that people tend to save more successfully when their savings goals fit their personality — specifically their “Big Five” personality traits. Here’s how higher levels of these traits may influence everyday saving behavior… Openness: You’re creative, future-minded, and receptive to new experiences. Goals tied to inspiration, growth, or meaningful exploration may feel more motivating. If this sounds like you, saving for retirement abroad, travel, or a hobby you’ve always wanted to try may help you keep your saving plan on track. Conscientiousness: You like plans, order, and follow-through. Practical, clearly defined goals (e.g., methodically paying down a credit card balance or making extra mortgage payments) might appeal to your disciplined nature. Extraversion: You gain energy from people and social interactions. Goals connected to shared experiences or exciting future plans that involve others — such as organizing a family reunion, group travel, or saving to move to an active retirement community — may help keep you on course. Agreeableness: You’re driven by connection, cooperation, and concern for others. Financial goals that benefit loved ones or reflect shared values, such as creating a legacy trust for future generations or prioritizing charitable giving, may feel more purposeful and motivating. Neuroticism: While this word may feel like something you’d hear in a Woody Allen movie, neuroticism is simply a measure of sensitivity to stress and negative emotions. So, goals that ease worry and create a sense of security, calm, or safety — such as building a rainy-day fund or reducing debt — might be particularly effective for you. Saver, Know Thyself Even without taking a formal personality test, you can still consider which traits feel like a match and choose goals with those tendencies in mind to achieve what the researchers called “person-goal fit.” Ask yourself: “Am I drawn more to new experiences, regimented plans and checklists, energizing social interactions, supporting others, or easing financial anxiety?” Ultimately, your likelihood of sticking with a financial goal often depends on what it truly means to you. What motivates one person may barely register for someone else. When your savings goals fit your personality, you may be surprised at how much easier the follow-through becomes. Sources: https://www.apa.org/pubs/journals/releases/amp-amp0001128.pdf
By Ironwood Retirement Plan Consultants February 2, 2026
New data suggests individuals’ decisions to take 401(k) loans are driven less by discretionary spending needs and more by day-to-day cash-flow constraints. A December 2025 study conducted by the Employee Benefit Research Institute (EBRI) and J.P. Morgan Asset Management sheds light on what drives participants to take out 401(k) loans and how those funds are used. The research links 401(k) records with Chase household spending data to see who takes defined contribution plan loans and where that money effectively goes. Housing, Healthcare, and Revolving Credit Approximately one in 10 private-sector 401(k) participants with a loan option took a new loan in plan years 2021-2022, the study found. Loan activity tended to rise and peak for participants in their 40s before tapering off in later years. The research also shows that new 401(k) loan use strongly increases as credit card utilization rises: just 6.9% of households with no card balance borrowed from their plan, compared to 19.8% of those using 80% or more of their available credit. This pattern indicates a link between borrowing behavior and tighter household cash flow. Additionally, high credit-card-use households contribute a smaller share of income to their plans and have lower plan account balances, further reinforcing the long-term drag elevated debt levels can place on retirement preparedness. When participants take a new plan loan, the only spending category that reliably shows an increase of more than 10% compared with non-borrowers is healthcare. A second lens, changes in the share of total spending, reveals that housing and unspecified cash spending are more likely to claim a bigger slice of the budget for loan-takers. The data also shows that, for a subset of households, new mortgages and plan loans often start around the same time. Notably, the decision to borrow from the plan appears largely independent of household income. Releasing Financial Pressure Valves for Participants The overall pattern suggests 401(k) borrowing tends to align with major medical and household expenses, as well as markers of financial stress, rather than with discretionary spending on travel, entertainment, or other purchases that might signal luxury consumption. This points to the role plan sponsors can play in helping influence loan behavior. Access to emergency savings and budgeting tools and mortgage education programs may help reduce reliance on plan loans while better aligning plan features with household cash flow needs and the financial demands of key life stages. Sources: https://www.ebri.org/docs/default-source/pbriefs/ebri_ib_647_dcloansprivsec-4dec25.pdf?sfvrsn=77bf052f_1
By Ironwood Retirement Plan Consultants February 2, 2026
It’s been widely reported that the marriage rate among Americans has declined sharply in recent decades. According to the Census Bureau, 60.8% of households were headed by married couples in 1980. By 2024, that figure had fallen to 47.1% Divorced, widowed, or never partnered singles can face retirement planning challenges that differ from their married or partnered peers. Findings from Nationwide’s latest Advisor Authority study highlight some of these potential challenges. Nationwide’s survey suggests single investors are acutely aware of the added pressures they face. More than a third say they contend with greater financial strain than married or partnered peers. Moreover, nearly one in five said they wonder if they’ll ever be able to retire. That concern is reflected in the state of their retirement savings: only 23% reported that they have at least $250,000 saved for retirement, and only 18% said they have $500,000 or more. According to Nationwide, the challenges single savers face tend to surface across several key areas. Emergency funds It can be more challenging to build an emergency fund on a single income. Not having backup savings in place can make it more difficult to manage the unexpected and adhere to retirement savings strategies. Long-term care: Singles are less likely to have a clear caregiving solution in place, so long-term care solutions should be considered early in the planning process. Taxes: Singles could face higher tax rates compared to married couples, which can affect their savings abilities and goals. Social isolation: The research highlights the importance of a strong support network in a single person’s retirement planning strategy and suggests loneliness can take a toll on emotional well-being – both before and during retirement – which in turn can impact financial decisions. Without a partner to share the responsibilities of retirement planning and financial decision-making, single workers may benefit more from in-depth, one-on-one guidance and planning conversations with a financial advisor. Sources: https://news.nationwide.com/single-in-retirement-looking-for-love-and-financial-security/ https://www.cnbc.com/2025/12/11/single-income-households.html https://usafacts.org/articles/state-relationships-marriages-and-living-alone-us/
By Ironwood Retirement Plan Consultants January 29, 2026
A December 2, 2025 hearing, titled “Pension Predators: Stopping Class Action Abuse Against Workers’ Retirement,” was convened by Subcommittee Chair Rick Allen (R-GA) before the House Education and Workforce Committee and the Subcommittee on Health, Employment, Labor, and Pensions. Expert witnesses claimed that, since a recent Supreme Court decision that may make it easier for plaintiffs’ firms to bring lawsuits alleging ERISA-prohibited transactions and survive motions to dismiss, the constant threat of lawsuits is reshaping fiduciary decision-making long before cases ever reach a courtroom. Among those testifying was Lynn Dudley, Senior Vice President of Global Retirement and Compensation Policy at the American Benefits Council, who highlighted how litigation fears can constrain sponsors’ ability to adopt innovative plan features that might benefit participants, such as decisions to offer lifetime income options. Witnesses also argued that plaintiff lawyers, not workers, are often the primary beneficiaries of these suits. They noted that many cases are brought repeatedly across the country by a small set of firms with nearly identical, “cookie-cutter” complaints. Other witnesses, including William Alvarado Rivera of the AARP Foundation, however, argued that rigorous ERISA enforcement and resulting lawsuits have historically improved plan practices and outcomes for participants by helping to ensure that fiduciaries meet their obligations. Rivera also contended that “[r]equiring that plan participants plead information that lies solely within the control of fiduciaries at the outset of a case improperly shifts the burden in ERISA cases.” He added that this requirement would effectively shut out potentially meritorious claims and enable fiduciaries to evade responsibility for ERISA violations. Sources: https://www.napa-net.org/news/2025/11/house-to-examine-pension-predators-as-erisa-pleading-standards-bill-unveiled https://fine.house.gov/news/documentsingle.aspx?DocumentID=109 https://www.congress.gov/bill/119th-congress/house-bill/6084/text https://www.jdsupra.com/legalnews/the-evolution-of-defined-contribution-6334019 https://www.plansponsor.com/house-members-spar-about-curbing-erisa-litigation https://www.asppa-net.org/news/2025/12/retirement-plan-innovation-stymied-by-erisa-litigation-say-witnesses/
By Ironwood Retirement Plan Consultants January 27, 2026
Most people don’t look forward to annual IRS announcements the same way they do the next season of their favorite Netflix show, but this one’s worth a look. Higher retirement plan contribution limits have been announced for 2026, and even a modest bump in your savings rate can make a big difference down the road. Here’s what’s new for 2026: 401(k), 403(b), and 457(b) : the elective deferral limit is increasing to $24,500 (from $23,500 in 2025) Catch-up contribution (for those aged 50+): the limit is increasing to $8,000 (from $7,500 in 2025) Super catch-up contribution (for those aged 60–63): the limit remains at $11,250 for 2026 Participants who earned more than $145,000 in 2025 will need to make any catch-ups as Roth (after-tax) contributions Consider Saving More Today. Your Future Self Will Thank You. Even a small bump in your annual contribution rate can result in a meaningful boost toward your retirement goals. Let’s consider Ann. She is 45 years old, earns $50,000 a year, has $150,000 in her 401(k), and contributes 10% of her paycheck annually to the plan. Raising her contribution to 12% (just $1,000 more per year) could yield more than $42,000 in additional savings for Ann over 20 years (assuming an average 7% annual investment return and no change in her salary). Add a 50% employer match on the first 6% of her contributions, and Ann’s overall savings and earning boost could reach approximately $63,000. Small Moves Can Make a Big Difference If you want to sock away that extra $1,000 – or any additional amount – to help build a bigger nest egg for your future self, consider one or more of these strategies: Adjust your budget. Even small changes, like reducing subscriptions or discretionary spending, can help create more space in your paycheck for retirement savings. Use gift money or other non-paycheck income to make room for savings. Money you get from outside your paycheck can’t go directly into your 401(k), but it can help you take care of other expenses and create an opportunity to bump up your retirement plan contribution rate. Maximize any employer match. Don’t go it alone. Depending on the formula, your employer match could cover a large share of the extra amount you want to save. Once you retire, any extra amount you’ve saved and earned could help you cover healthcare costs, create a travel fund, manage financial emergencies, or bump up your charitable giving — whatever future freedom means to you. If you’re eligible and capable, take advantage of catch-up contributions to increase your momentum and potentially make your 50s and early 60s some of your most impactful years for savings. Even if you’ve fallen behind on your retirement savings progress, there’s still time to make a significant difference. Forge a Brighter Retirement Reality So, if you’re catching up on Stranger Things over the holidays, remember that you don’t need to visit a parallel dimension to set your future self up for a more secure retirement. Consider what small adjustments today could mean for yourself and your retirement portfolio tomorrow. Sources: https://www.irs.gov/newsroom/401k-limit-increases-to-24500-for-2026-ira-limit-increases-to-750 https://www.aarp.org/money/retirement/401k-calculator/
By Ironwood Retirement Plan Consultants January 20, 2026
If you think capitalization swings are getting wider and more frequent, you may be right. By the end of October 2025, there were 119 instances of individual U.S. stocks (mainly large technology firms) moving by more than $100 billion in market cap in a single day this year, according to the International Business Times. In 2025, there were only 42 such instances, and in 2020 there were fewer than 10. These dramatic single-day moves have captured headlines and contributed to a sense that markets are becoming more unpredictable. For retirement plan participants, these high-profile fluctuations can understandably raise questions and concerns about risk, diversification, and portfolio composition. Large swings in a handful of companies usually shouldn’t affect an individual’s long-horizon savings strategy or require short-term action. Clear communication can help participants understand how their investments are structured — and why a diversified, long-term strategy can continue to serve them well — and alleviate anxiety during periods of elevated volatility. Sources: https://www.ibtimes.com/elastic-market-effect-how-100-billion-swings-became-new-normal
By Ironwood Retirement Plan Consultants January 19, 2026
New research has revealed some telling patterns in employee retirement plan contribution rates. According to PLANSPONSOR’s 2025 Participant Survey, nearly 4 in 10 participants said that – when choosing their rate – they simply stayed with the plan’s default setting. What this means is that the default doesn’t always just start the retirement savings journey. For a significant portion of the workforce, it can end up defining it. The finding reinforces long-held notions around status quo bias and choice overload. That is, when a decision is complex or abstract, many people gravitate toward the path of least resistance. While auto enrollment and other plan design features have been successful in increasing participation, forward-thinking sponsors can consider doing even more. Plan Design is Key Plan sponsors have many design options available to them – beyond basic auto enrollment features – to further draw on the influence of behavioral economics. For example… Raising the initial auto enrollment deferral rate: Increasing the rate can help employees get a faster start on their savings journey. Enhancing automatic escalation settings: Sponsors can increase individuals’ contribution rates over time by adding or, if applicable, raising, the annual auto escalation increment and/or increasing the escalation cap. Stretching the match: Sponsors also can encourage higher employee contributions by stretching their match formula. For example, assume a sponsor currently matches 100% of participants’ contributions up to 3% of their salary. The sponsor could encourage people to double their own rate of savings – while holding the company’s match costs level – by instead matching 50% of contributions up to 6% of salary. Hands-on Guidance Can Play a Crucial (and Welcome) Role Too While plan design and automatic features can have a positive impact, there’s strong evidence that people also want additional, hands-on support as they make money decisions. Morgan Stanley at Work’s annual State of the Workplace Financial Benefits Study, for example, shows workers are looking for financial and retirement guidance. Of the options provided, respondents expressed the strongest preference for access to a financial advisor (47%) through their employer plan, with goals-based investment planning (45%) and retirement income solutions (43%) not far behind. From systematized plan design settings to hands-on guidance, sponsors and advisors may want to look for ways to help people move “beyond the default” and into paths that could set them on a better course for retirement readiness. Sources: https://www.plansponsor.com/surveys/2025-participant-survey/ https://institutional.vanguard.com/2025_How_America_Saves.pdf https://www.cnbc.com/2025/06/04/average-401k-savings-rate.html https://www.fidelity.com/learning-center/smart-money/average-401k-match https://www.psca.org/news/psca-news/2025/5/economic-uncertainty-has-reduced-employee-saving https://graystone.morganstanley.com/graystone-consulting-pacific-mountain.pdf https://www.psca.org/auto-enrollment-less-popular-with-small-plans-but-gap-is-narrowing/
By Ironwood Retirement Plan Consultants January 7, 2026
When you think of the benefits of your retirement plan, tax-deferred savings and matching contributions are probably top of mind. But there’s more to your workplace retirement plan than meets the eye. Beyond the basics, retirement plans can come with a number of lesser-known advantages that can help you protect, grow, and pass on your savings more efficiently. Here are six perks you might not even realize you have. Dollar Cost Averaging. Your retirement contributions go into your account on a regular schedule, regardless of fluctuations in the market. This means you buy more shares when prices are low and fewer when prices are high, evening out your average cost per share over time. This is known as “dollar cost averaging.” It’s a simple, steady approach that takes the guesswork and emotion out of investing, helping you stay consistent through market ups and downs. Greater Creditor Protection. Retirement balances are generally shielded from commercial creditors, adding an extra layer of security for your nest egg. This protection is built into federal law, offering a safeguard most personal investment accounts can’t match. Even if you face a lawsuit or bankruptcy, your retirement savings are generally off-limits to most creditors. While certain exceptions can apply — such as for federal income taxes owed to the IRS — this layer of protection can help keep more of your hard-earned savings dedicated to your financial future. Access to Exclusive Investments. Your retirement may include options not found in regular brokerage accounts, such as collective investment trusts (CITs). These pooled investment vehicles, maintained by a bank or trust company, are designed specifically for retirement plans and often offer lower costs and greater operational efficiency than mutual funds. CITs operate with fewer marketing and administrative expenses, and they’re managed in bulk for institutional investors like retirement plans. Lower costs can translate directly into higher long-term returns, which can help your balance grow faster over time. Easier Estate Planning. You can name beneficiaries directly on your retirement account, helping your savings transfer smoothly without probate delays. By naming your beneficiaries, you can help ensure that your savings pass directly to your chosen heirs, avoiding the time, expense, and complications of probate. Regularly reviewing and updating your beneficiary designations after major life events, such as marriage, divorce, or the birth of a child, can help keep your estate plan aligned with your wishes. Professional Oversight. Retirement plans have designated fiduciaries that are responsible for reviewing fund performance, keeping fees reasonable, and ensuring investment options meet the plan’s standards, giving you the benefit of built-in due diligence and expert oversight. These fiduciaries are legally obligated to act in your best interest, quietly working behind the scenes for your benefit. Potential Fee Savings. Many larger plans offer institutional share classes with lower fees. While the difference may seem small, perhaps just a few tenths of a percent, those cost savings can add up to tens of thousands of extra dollars over decades of compounding. Lower expenses mean a higher percentage of each contribution stays invested, allowing more of your savings to keep working for you. By understanding and taking advantage of these benefits, you can help make the most of your plan and strengthen your retirement readiness. A little knowledge can go a long way toward securing your financial future. Sources: https://www.equifax.com/personal/education/life-stages/articles/-/learn/protect-retirement-account-from-creditor https://www.kiplinger.com/personal-finance/the-basics-of-estate-planning https://www.ey.com/en_us/insights/financial-services/the-growing-popularity-of-cits-in-us-retirement-plans s
By Ironwood Retirement Plan Consulants January 2, 2026
The Problem: Cash Out Leakage and Lost Accounts American workers now hold an average of more than 12 jobs over the course of their careers. During job changes, many end up cashing out small 401(k) balances and not rolling them into tax-qualified retirement plans. Industry studies estimate this trend may be causing an annual savings “leakage” of more than $90 billion due to taxes, penalties, and the missed growth and compounding potential of those cashed-out dollars. “Forgotten” 401(k) accounts may also be slipping through the cracks, further undermining employees’ long-term financial wellness. Enter Auto Portability: Keeping Savings Connected to Their Owners To address the issue, members of the retirement industry are supporting an option called “auto portability.” A consortium of major recordkeepers launched the Portability Services Network (PSN) to automatically reconnect small retirement account balances with their owners’ new employer plans when they change jobs. The consortium’s intent is to have a process that is secure and easy for participants. Here’s how it works… If an employee leaves behind a 401(k) balance below a set level (typically $7,000), the network’s technology searches for that individual’s new employer plan and automatically rolls the old balance into the employee’s new plan account. Participants receive a notice and can opt out if they do not want the transfer. Otherwise, their savings automatically follow them to their next job. Participants pay a low, one-time fee (capped at around $30) when their account successfully transfers. Plan sponsors should conduct thorough due diligence to understand the terms, conditions, and implications of activating this option for their plans. Research estimates that if this new feature were adopted widely, it could preserve an extra $1.6 trillion in retirement savings over the next generation. By keeping those small accounts invested instead of being prematurely drained, even modest balances can grow over time and contribute to a more secure retirement.  Sources: https://www.bls.gov/news.release/pdf/nlsoy.pdf https://psn1.com/news/press-release-portability-services-network-jumpstarts-nationwide-adoption-of-auto-portability https://rch1.com/auto-portability/frequently-asked-questions https://rch1.com/blog/the-triple-crown-to-unlock-retirement-security-for-all https://fcwpol.files.cmp.optimizely.com/download/302392d88afc11ef969f5ed37da10eba
By Ironwood Retirement Plan Consultants December 18, 2025
Cybersecurity isn’t a “technology problem” — it’s a fiduciary imperative for retirement plan sponsors.