Vol.12, June 2026

June Benefits Rundown: Nondiscrimination testing + the outsourcing landscape

This is a big month for our family. One of my sons is moving halfway across the country for a great job opportunity. We’re thrilled for him, but we’re really going to miss having him closer to home.

Life is full of trade-offs. Even the things you’re excited about often come with considerations to weigh.

In the benefits world, that’s nothing new. Nearly every decision involves some level of trade-off. Offering a lump-sum window to pension participants can reduce plan costs, but some participants may not make decisions that best support their long-term retirement security. DC plan features like auto enrollment, auto escalation, and target date funds help participants build stronger balances, but they also require less engagement with the fundamentals of financial decision-making—skills participants will need when it’s time to draw down those savings.

There’s rarely a single right answer. The goal is to understand the trade-offs, make thoughtful decisions, and be clear-eyed about the outcomes they’re likely to produce.

‘Til next time,

Mindy Zatto, FSA, EA, FCA, MAAA, MSPA
Founding Principal, SBA

This Month at SBA

A quick look at what’s new, noteworthy, or just plain useful from our team.

401(k) plan nondiscrimination testing after an acquisition for a supermarket corporation, featuring a grocery store worker checking inventory on a shelf while holding a tablet.

Case study: 401(k) Nondiscrimination Testing After an Acquisition

When one supermarket corporation acquired another, it was left managing two 401(k) plans across separate recordkeepers—both of which failed nondiscrimination testing and were on track to trigger more than $180,000 in corrective refunds. SBA stepped in to evaluate whether a compliant, more favorable outcome was possible, combining participant-level data across both plans to perform aggregated testing. SBA’s work reduced required refunds by 97%, preserved the majority of employee contributions, and ensured timely compliance with IRS requirements.

Game strategy drawn with white chalk on a blackboard.

Keeping up with all the players in outsourced benefits administration

This older piece we developed for PLANSPONSOR is seeing renewed interest as plan sponsors revisit their outsourcing relationships—and for good reason. While the vendor landscape has continued to evolve since this article was first published, the core challenge remains the same: keeping track of who does what and how to evaluate potential partners in a rapidly changing market. This article offers a useful framework for thinking through those decisions, and reflects the perspective SBA continues to bring in helping clients navigate an environment that never stands still.

Ask the Principals

Our leadership team tackles tough questions from plan sponsors like you.

Close-up of hands holding an open, lined spiral notebook and a pen at a wooden desk.

If we got serious about termination today, how long would it take?

A: Most plan terminations take 12 to 18 months once officially underway, but the timeline can vary widely depending on how prepared the plan is at the outset. Factors like data quality, funding status, the number of missing participants, and the desire for an IRS determination letter all affect how soon a plan can be terminated.

SBA starts by helping plan sponsors pinpoint what’s ready and what’s not—from benefit data and participant communications to IRS and PBGC filings. We then build a project timeline that reflects both regulatory requirements and real-world logistics. When gaps are identified early and addressed proactively, sponsors avoid costly delays and keep the termination process moving forward.

Tags: DOL, lost participants/beneficiaries, plan management, plan termination

Submit Your Question