Carson’s Financial Planning Head Brings Together 401(k), Wealth Advisement

Erin Wood of Carson Group discusses the organization’s recent push to provide financial planning resources across plan and individual advisement.

Erin Wood of the Carson Group believes 401(k) plan advisement and individual financial planning are headed, “like a freight train,” toward an intersection.

Her position at Carson Group certainly gives her a good vantage point. About three years ago, she took the role of senior vice president for financial planning and advanced solutions, and she now oversees those services across Carson’s wealth and newer 401(k) practices.

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“The wellness programs have been a huge focus for employers as they’re trying to figure out how to help their employees, not just with their health, but [with] their financial health,” Wood says. “Through me having both departments, I was able to see this real crossover and this genius happening on both sides. It hasn’t quite hit the mainstream yet, but I believe it is coming very quickly.”

Erin Wood

Wood says the idea of bringing in a 401(k) practice came from clients with businesses that wanted help with their retirement plans. Through that demand, the 401(k) group was expanded, and now, Wood says, the departments share planning and education resources.

“We’ve now been able to cross-function a lot of our team members from the retirement planning side and the wealth side to help boost the resources our advisors have access to,” she says. “We’re building everything into our [client relationships management system] so that advisers have access to the wellness programs and offerings. … It has been a big focus to tighten those up.”

In January 2023, Carson Group expanded its 401(k) services via a partnership with retirement plan provider Vestwell. The two firms created Carson Complete 401(k), giving Carson-affiliated advisers access to a proprietary plan offering. In December 2023, the firm acquired Oakeson Steiner Wealth & Retirement, which includes retirement consultancy services.

The Omaha, Nebraska-based firm currently has an advisory network of more than 150 partner offices overseeing a combined $38 billion in client assets.

Managing Wealth

Some in the retirement industry have been critical of advisories mixing 401(k) advisement and wealth management. In a report issued in August, the Government Accountability Office stated it is looking into potential conflicts of interest, including when advisers recommend participants roll over into an individual retirement account.

When asked about the potential conflict of interest in offering participants coaching and planning that might move to individual, paid advisement, Wood says that while some firms may approach it differently, Carson operates with a strict fiduciary standard.

“Every firm is going to have to make a decision on where they stand, on what rules they’re going to make their advisers follow,” Wood says. For Carson, “it’s been very clear that when [a participant] start[s] going outside of the plan and the resources we offer to the plan, then that individual needs to know exactly what they’re getting and what they are paying for and why are they doing it.”

At Carson, Wood says, 401(k) advisement and wealth management teams work together to ensure there is not a “tug of war,” but the business is looking at outcomes and fiduciary responsibility from both sides.

“I have been both on the financial planning and the retirement side, and [at other firms,] they frequently don’t talk to each other at all,” she says.

Wood says artificial intelligence is driving planning and advice forward quickly by offering things such as AI coaching to participants. That can get close to financial advice, she says, which the industry needs to manage carefully. One positive of the innovations, Wood says, is that they will make financial education and planning available to more people.

“It’s the idea that you can raise all boats just by helping give this information,” she says. “The whole economy gets better if we can help retirement plans get this right.”

Wood says a challenge comes when advisers operating with an assets-under-management pay structure are not incentivized to work with some of the clients. Some advisers, particularly younger ones, are working with a fee-based model of payment, better for this new system and, to Wood, a promising development.

A fee-based system may also work better for younger investors, who are interested in help with broad financial advice concerning investments, taxes and insurance, Wood says, whereas the Baby Boomer generation was more solely focused on investment management.

Job Movers

Wood is also focused on the savings risks for the more mobile workforce, a trending retirement topic. Recent Vanguard research highlighted the concern that, when workers move jobs, they often reset to a lower contribution rate or go long periods without contributing at all. Wood sees this as an opportunity for workplaces to step in—with the assistance of an advisory—to educate and communicate with participants on the correct contribution rate.

“This is where I think retirement planning and wealth crossing over becomes so important,” Wood says. “What we’ve been working on with our advisers is to make sure that when [an employee switches jobs], we’re talking with them about how much they were saving … and here’s what your new percentage should be, particularly as job moves often result in higher pay.”

Technology can also help employers—and advisers—get employees’ attention in times when workers need advice, she says.

“Giving advice on demand when someone needs it is the most important thing any of us can do,” she says. “Financial decisions can happen in an instant. Most people aren’t sitting around going, ‘Oh, six months from now, I’m going to have this emergency.’ But when it happens, they need that advice.”

DOL Extends Disaster Relief Timeline for Plans Impacted by Hurricanes

Relief ends on May 1, 2025, for areas impacted by hurricanes. 

The Department of Labor’s Employee Benefits Security Administration announced extended deadlines and guidance for employee benefit plans, plan sponsors and participants who have been affected by the recent disasters of Hurricane Helene and Hurricane Milton.

The Disaster Relief Notice 2024-01 covers the major disasters declared by President Joe Biden; it begins on the first day of the incident period and ends on May 1, 2025. The Federal Emergency Management Agency established incident periods for different affected areas.

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For disaster areas in Florida, the incident period for Hurricane Helene began on September 23, and for Hurricane Milton, the incident period began on October 5.

For disaster areas in North Carolina, South Carolina and Virginia, the incident period began on September 25, and for disaster areas in Georgia, the incident period began on September 24. For disaster areas in Tennessee, the incident period began on September 26.

The guidance applies to employee benefit plans, plan sponsors, labor organizations, plan fiduciaries, participants, beneficiaries and plan service providers subject to the Employee Retirement Income Security Act who were located in a county, tribal area or other geographic area identified for individual assistance by FEMA because of the devastation caused by the covered disasters.

In addition to the relief provided by the notice, the DOL announced an extension of deadlines for furnishing other required notices or disclosures to plan participants and beneficiaries so that employers, plan fiduciaries and plan sponsors have additional time to meet their obligations under Title I of ERISA as a result of the covered disasters.

Plan fiduciaries will not be in violation of ERISA for failure to timely furnish a notice, disclosure or document by May 1, 2025, if the plan and responsible fiduciary act in “good faith” and furnish the notice as soon as administratively practicable under the circumstances. Acting in good faith includes using electronic alternative means of communicating with participants and beneficiaries who the plan fiduciary believes have effective access to electronic means of communication, which includes email, text messages and continuous access to websites, the DOL stated.

Plan Loans and Distributions

According to the DOL notice, if an employee pension benefit plan fails to follow procedural requirements for plan loans or distributions imposed by the terms of the plan, the DOL will not treat it as a failure if:

  • The failure is solely attributable to a covered disaster;
  • The plan administrator makes a “good-faith, diligent effort” under the circumstance to comply with those requirements; and
  • The plan administrator makes a reasonable attempt to correct any procedural deficiencies, such as assembling any missing documentation, as soon as administratively practicable.

Under the SECURE 2.0 Act of 2022, a qualified participant with a plan loan can delay repayment of their outstanding loan by up to one year if the due date would otherwise occur during a period that begins on the first day of the incident period and ends 180 days after the last day of the incident behavior.

The DOL has advised the Department of the Treasury and the IRS that it will not treat any person as having violated Title I of ERISA solely because they complied with these special rules for plan loans.

According to the DOL, it recognizes that some employers and service providers may not be able to forward participant payments and withholdings to employee pension benefit plans within prescribed timeframes due to a covered disaster. In such instances, the DOL will not take enforcement action with respect to a temporary delay in forwarding such payments or contributions to the plan due to a covered disaster.

“Employers and service providers must act reasonably, prudently, and in the interest of employees to comply as soon as administratively practicable under the circumstances,” the notice stated.

PLANSPONSOR’s Ask the Experts column on November 5 addressed the question of whether IRS disaster relief extends to plan sponsors with affected service providers. PLANSPONSOR is a sister publication of PLANADVISER.

Blackout Notices

The DOL has made an exception for administrators of individual account plans who are typically required to provide 30 days’ advance notice to participants and beneficiaries whose rights under the plan will be temporarily suspended, limited or restricted by a “blackout period.”

The regulations provide an exception to providing advanced notice when the inability to provide the notice is “due to events beyond the reasonable control of the plan administrator and a fiduciary.” As a result, the DOL will not require the written determination by a fiduciary pursuant to the regulation for blackout notices, as natural disasters are by definition beyond a plan administrator’s control.

Form 5500s, ERISA Fiduciary Compliance Guidance

The IRS is also providing Form 5500 annual return/report filing relief. Guidance for those impacted by both Hurricane Helene and Hurricane Milton can be found on the IRS website.

In addition, the DOL reminds plan fiduciaries to make “reasonable accommodations” to prevent the loss of benefits or undue delay in benefits payments due to a covered disaster. According to the DOL, fiduciaries should attempt to minimize the possibility of individuals losing benefits because of a failure to comply with pre-established timeframes.

The DOL will continue to monitor the effects of the covered disasters and may respond to the situation as appropriate, which may include providing additional relief, according to the notice.

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