Retirement Savings Gap Widens Further Between High, Low-Income Employees

High-income households increasingly hold larger retirement account balances than lower income households and are more likely to reap tax perks associated with workplace plans, GAO research shows.

Retirement account balances of high-income households were drastically higher than low-income households in 2019 compared to 2007, exemplifying that disparities in retirement savings across socioeconomic class and race still persist, according to new data from the Government Accountability Office.  

The median retirement account balance for households aged 51 to 64 for the highest income group in 2019 was $605,000. This balance is nine times higher than that of middle-income households in 2019, which was $64,300, GAO found. 

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This retirement savings gap has widened significantly since 2007, when high-income households had a median retirement account balance that was about four times higher than middle-income households—which was $86,000compared to $33,000, respectively.  

In 2022, tax incentives for workers to save in tax-preferred retirement accounts cost the federal government nearly $200 billion in forgone revenue, according to the Department of the Treasury. As a result, Congress is concerned that federal tax incentives for workers in tax-preferred retirement accounts are going mostly toward higher income workers and are doing little to help lower-income workers save for retirement. 

Senator Sheldon Whitehouse, D-Rhode Island, and Senator Bernie Sanders, I-Vermont, asked the GAO to examine disparities in the distribution of retirement account balances across income class, age and race. 

Tax Breaks Benefit High Earners 

In its report, the GAO found that low-income households were less likely to even have a retirement account balance in 2019 than in 2007. Ten percent of low-income households had a balance in 2019, compared to 20% in 2007. For high-income households, 90% had a retirement account balance in both 2007 and 2019. 

“For those with a balance, the median balance was higher for high-income households over the period, while any chance for the other income groups was not statistically significant,” the report stated. 

Only about 23% of low-income workers have access to a workplace retirement account and many may not choose to participate if they have limited disposable income or expect Social Security to provide most of their income in retirement. Increasing contribution limits for workplace retirement accounts almost entirely benefits high-income workers, GAO argued, as about 23% of high-income compared with about 3% of middle-income older workers contribute up to the individual limit.  

Angela Antonelli, research professor and executive director at the Georgetown University Center for Retirement Initiatives, said via email that an estimated 57 million private sector workers lack access to retirement savings, and most of those workers are employed by businesses with fewer than 20 employees and earn less than $50,000 per year.  

“State-facilitated retirement savings programs are designed to reach these forgotten employers and workers and while significant progress is being made, we still have a long way to go,” Antonelli argued. 

GAO reported that “limited access to workplace retirement accounts continues to be an impediment to expanding the percentage of households with retirement savings.” 

GAO also found that high-income households are much more likely to benefit from tax perks associated with retirement plans, whereas low-income households are more likely to make hardship withdrawals, thus causing them to pay additional taxes.  

More than twice the share of low-income households than high-income households withdrew all the money from their workplace account when they left their employer between 2016 and 2018, the report shows. 

Other Factors and Disparity 

Besides income, job-related factors and race were strongly related to disparities in older worker households’ retirement account balances. As a whole, households with higher income, longer job tenure and a college education tended to have larger balances and received larger employer contributions, according to GAO’s analysis. 

In addition, non-white households and households with children had about 28% and 20% smaller balances, respectively.  

For example, about 63% of white households had a retirement account balance in 2019, compared to about 41% of households of all other races than white. For Black or African American households, GAO found a significant decline from 50% with a retirement account balance in 2007 to 35% in 2016. 

In 2019, white households had median balances of about $164,000, about twice that as households of all other races, where median balances were about $80,300.  

Low-income households are also more often divorced, widowed or separated and tend to experience unemployment more frequently. All the factors can impact overall retirement savings, the research found. 

Antonelli added that plan sponsors “can and should do more to boost plan participation, such as offering a plan and using auto-enrollment,” which GAO points out is highly effective.  

However, there are also powerful headwinds that make saving challenging for many lower income workers and disproportionately affect people of color, including the lack of employment opportunities and education and income inequality,” she said.  

What’s in the Window?

The Department of Labor’s March 2022 attempt to regulate cryptocurrency investments has left numerous outstanding questions about its effect on brokerage windows.

Defined contribution plans’ self-directed brokerage windows used to be a generally quiet component of plans’ investment offerings.

But in March 2022, regulators at the Department of Labor published the Employee Benefits Security Administration’s “Compliance Assistance Release No. 2022-01: 401(k) Plan Investments in ‘Cryptocurrencies.’” The release cited concern with the growing number of firms marketing cryptocurrency investments to 401(k) plans as potential investment options for participants as in-plan options or through brokerage windows.

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PLANSPONSOR’s 2023 Plan Benchmarking Report, which surveyed 2,562 plan sponsors from a broad variety of U.S. industries, found brokerage windows are not terribly widespread. Among survey respondents, 22.6% reported that their plan offers brokerage windows, and another 5.4% reported being offered a mutual fund window.

Many in the retirement plan industry did not expect the CAR’s specific inclusion of brokerage windows and challenged the release’s validity on that point.

“We were very surprised when we saw the guidance put out by the Department of Labor, which indicated that there was an obligation to review, for example, cryptocurrency investments, available under a brokerage window,” says Kent A. Mason, a partner in Davis & Harman LLP in Washington, D.C. “The law is clear that there is no obligation on behalf of a plan fiduciary to review the investments offered through a brokerage window. Essentially, a broad universe of investments can be made available through a brokerage window.”

One group of 11 trade associations, which included the American Bankers Association and the SPARK Institute, among others, wrote to the DOL in April 2022 claiming that the CAR “puts plan sponsors in the untenable position of having to choose between extending their fiduciary responsibility to such investments, contrary to longstanding guidance, or accepting the likelihood of a plan investigative audit, along with the very real expenditures, both in time and money, associated with such audits.”

Windows’ Status Remains Murky

The CAR’s impact on the availability of and investments allowed in brokerage windows remains unclear. Three companies—Bitwage, Digital Asset Investment Management and ForUsAll—were offering in-plan cryptocurrency options as of the CAR’s release date, and all three continue to do so. Additionally, Fidelity Investments launched its in-plan Digital Assets Account in April 2022. Bitwage, DAIM and Fidelity include cryptocurrency options as a diversifier within a plan’s lineup; ForUsAll uses a brokerage window.

ForUsAll sued the DOL in June 2022 and requested that the CAR be “vacated and set aside.” Among other points, the company cited the CAR’s business impact, claiming that approximately one-third of plans that had been discussing the crypto option with ForUsAll had put their plans on hold pending regulatory clarification. In Congress, Senator Tommy Tuberville, R-Alabama, in February reintroduced legislation to prohibit DOL regulation limiting the investments available in a 401(k) plan’s brokerage window.

Difficulties With In-Plan Crypto

Schwab’s Self-Directed Brokerage Account Indicator for the quarter ending March 31 shows how Schwab’s recordkeeping retirement plan participants were invested through their plans’ brokerage windows. According to the report, equities accounted for 33% of holdings, followed by mutual funds (29%), exchange-traded funds (22%), cash and equivalents (11%) and fixed income (4.4%).

Plan sponsors can limit participants’ investment options available through the brokerage window. Alight Solutions’ 2021 recordkeeping data survey found that 60% of sponsors offering windows allowed full brokerage options, while 40% imposed limits (31% allowed only mutual funds, and 9% allowed only mutual funds and ETFs). ForUsAll caps participants’ brokerage window cryptocurrency investments at 5% of the initial portfolio value, plus 5% of ongoing contributions.

Even with allocation and contribution limits in place, plan fiduciaries face operational challenges with crypto investments. The CAR mentions direct crypto investments plus “other products whose value is tied to cryptocurrencies.” In response, the trade associations cited previously highlighted the lack of available mechanisms “for identifying and excluding cryptocurrencies from brokerage windows, let alone explicitly defining cryptocurrency investments that could be problematic.”

The associations argued this is particularly true for “products such as mutual funds and exchange traded funds that offer exposure to cryptocurrencies but are not direct investment in cryptocurrencies per se.” As these types of investments proliferate, they believe it will be more difficult for plan sponsors to “identify, evaluate, and exclude such investments from brokerage windows.”

Going Forward

Tim Rouse, executive director of the SPARK [Society of Professional Asset Managers and Recordkeepers] Institute in Simsbury, Connecticut, believes that increasing fiduciary responsibility over brokerage widows due to the CAR would limit their benefit and take away a service that participants have come to value.

Despite the questions elicited by the CAR and the lack of clarity on what constitutes a crypto investment, neither Mason nor Rouse has seen any recent changes in plans’ use of brokerage windows. According to Vanguard, for example, at year-end 2022, 20% of the plans for which Vanguard serves as recordkeeper had a self-directed brokerage option. That result was unchanged from the previous year, before the DOL issued the CAR.

Several factors could explain the lack of immediate response to the CAR. First, the amount of assets in brokerage windows is small: just 1% of Vanguard plan participants’ assets at year-end for both 2021 and 2022, and other recordkeepers also report low-single-digit results.

Second, ForUsAll is the sole 401(k) provider to offer a dedicated cryptocurrency window. Plan participants with unrestricted windows at other recordkeepers could be investing in cryptocurrency via exchange-traded funds, for instance, but because there is no clearly defined asset class, recordkeepers cannot simply run a search to identify participants’ crypto holdings, Rouse notes.

A final factor could be the belief that the CAR does not align with past DOL guidance and the hope that it will be either modified or withdrawn. Per the trade associations’ letter: “At a minimum, it is critical that the [CAR’s] announcement of a new fiduciary standard with respect to brokerage windows be withdrawn.”

 

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