Use these materials to help design legislative or regulatory proposals and inform retirement plan practices to improve lower- and moderate-income workers’ retirement security.

The Retirement Reform Group (RRG) is an informal, nonpartisan working group of more than 100 active and retired employee benefits lawyers focused on strengthening retirement security for lower- and moderate-income workers. As RRG members develop solutions, it is equally important to share our ideas with policymakers and other stakeholders working toward reforms. In this Solutions Library, we invite you to explore our research, analysis, and presentations.

These materials provide background and suggestions for practices and policy solutions for Individual Retirement Accounts (IRAs), defined contribution plans, and defined benefit plans to improve outcomes for workers, especially those with lower- and moderate-income levels. We also welcome questions, collaboration ideas, and discussion.

Research and Analysis

Section 530A IRAs: Trump Accounts Proposed Regulation (REG-117270-25), Comment Letter ID IRS–2026-0298-0047 to the IRS filed 5/8/2026, posted 5/12/2026

Cynthia A. Van Bogaert, William K. Bortz, J.S. “Chris” Christie, Russell A. Gaudreau, Jr., Israel Goldowitz, Ethan Lipsig, Maria O’Brien, W. Thomas Reeder, Jr., Ronald S. Rizzo, Robert F. Schatz, Andrew E. Staab, Richard J. Wickersham

• Notes that the new section 530A IRAs are a substantial public investment and that additional easy-to-navigate, non-conflicted support for financially inexperienced owners is needed to ensure that the intended retirement savings outcomes are achieved
• Explains how section 530A IRA issues also affect current IRAs and notes the need to update and adjust much of the IRA guidance taking into account the vulnerability to error, fraud, or exploitation especially as individuals age
• Describes many of the risks and pitfalls like conflicts of interest, high fees, prohibited transactions involving investments, tax reporting and required minimum distribution requirements, involuntary transfers to unclaimed property funds, and lack of ERISA fiduciary protections

Disparities Affecting Lower- and Moderate-Income Workers’ Retirement Savings–Creating an Incubator for Reform Proposals

Cynthia A. Van Bogaert, published in New York University Review of Employee Benefits and Executive Compensation 2025, Publisher Matthew Bender

• Explains the Retirement Reform Group and its work
• Provides examples of problems affecting lower- and moderate-income workers’ ability to save
• Offers numerous ideas and potential approaches to address these problems

Pooled Employer Plans: Big Plans for Small Businesses Regulation RIN 1210-AC10, Comment Letter #30 to the U.S. Department of Labor filed 9/29/2025

Cynthia A. Van Bogaert, David Certner, J.S. “Chris” Christie, Israel Goldowitz, Rhona S. Lyons, Joyce A. Mader, Jeffery Mandell, Bruce J. McNeil, Susan B. Niver, Maria O’Brien, Andrew L. Oringer, Bruce D. Pingree, David A. Pratt, Robert F. Schatz

• Discusses concerns about the lack of resources for small employers to understand the issues and risks involved in the proposed PEP safe harbor
• Describes the need to avoid conflicts of interest and to protect ERISA rights for workers