Klitzman Law Group, PLLC

How Does the SECURE Act Change Your Estate Plan?

“These changes are so significant that every such plan holders should review their wishes and how their estate plans may be affected.”

The SECURE Act has made big changes to how IRA distributions occur after death. Anyone who owns an IRA, regardless of its size, needs to examine their retirement savings plan and their estate plan to see how these changes will have an impact. The article “SECURE Act New IRA Rules: Change Your Estate Plan” from Forbes explains what the changes are and the steps that need be taken.

Some of the changes include revising wills and trusts which include provisions creating conduit trusts that had been created to hold IRAs and preserve the stretch IRA benefit, while the IRA plan owner was still alive.

Existing conduit trusts may need to be modified before the owner’s death to address how the SECURE Act might undermine the intent of the trust.

Rethinking and possibly completely restructuring the planning for the IRA account may need to occur. This may mean making a charity the beneficiary of the account, and possibly using life insurance or other planning strategies to create a replacement for the value of the charitable donation.

Another alternative may be to pay the IRA balance to a Charitable Remainder Trust (CRT) on death that will stretch out the distributions to the beneficiary of the CRT over that beneficiary’s lifetime under the CRT rules. Paired with a life insurance trust, this might replace the assets that will ultimately pass to the charity under the CRT rules.

The biggest change in the SECURE Act being examined by estate planning and tax planning attorneys is the loss of the “stretch” IRA for beneficiaries inheriting IRAs after 2019. Most beneficiaries who inherit an IRA after 2019 will be required to completely withdraw all plan assets within ten years of the date of death.

One result of the change of this law will be to generate tax revenues. In the past, the ability to stretch an IRA out over many years, even decades, allowed families to pass wealth across generations with minimal taxes, while the IRAs continued to grow tax tree.

Another interesting change: No withdrawals need be made during that ten-year period, if that is the beneficiary’s wish. However, at the ten-year mark, ALL assets must be withdrawn, and taxes paid.

Under the prior law, the period in which the IRA assets needed to be distributed was based on whether the plan owner died before or after the RMD and the age of the beneficiary.

The deferral of withdrawals and income tax benefits encouraged many IRA owners to bequeath a large IRA balance completely to their heirs. Others, with larger IRAs, used a conduit trust to flow the RMDs to the beneficiary and protect the balance of the plan.

There are exceptions to the 10-year SECURE Act payout rule. Certain “eligible designated beneficiaries” are not required to follow the ten-year rule. They include the surviving spouse, chronically ill heirs and disabled heirs. Minor children are also considered eligible beneficiaries, but when they become legal adults, the ten year distribution rule applies to them. Therefore, by age 28 (ten years after attaining legal majority), they must take all assets from the IRA and pay the taxes as applicable.

The new law and its ramifications are under intense scrutiny by members of the estate planning and elder law bar because of these and other changes. Speak with your estate planning attorney to review your estate plan to ensure that your goals will be achieved in light of these changes.

Reference: Forbes (Dec. 25, 2019) “SECURE Act New IRA Rules: Change Your Estate Plan”

Great Tips for 401(k) Savings in 2020

“A 401(k) is an employer-sponsored account that allows you to defer the taxes on your investments until retirement, which meanw that you can roll up more money faster.”

The New Year is a great time to take a look at your retirement savings accounts and make 2020 a better year for setting yourself up for success. The 401(k) is the account that most employers offer their employees, and many contribute matching funds to encourage workers to save, which is free money for doing something that you should be doing anyway. Investing may be a challenge, but investing in your 401(k) is the easiest way to do it, says Bankrate in the article “Your 401(k) plan: 5 smart moves to make in 2020.”

Start today. Even if you are only making a modest contribution to your 401(k), starting now is better than procrastinating—again. Most Americans understand the importance and value of investing for their futures, even those who don’t do it. Millennials are focused on buying homes, raising families and paying college loans. They are less focused on saving for retirement, which could lead to issues in their futures. Boomers, on the other hand, regret not starting to save sooner for retirement.

Don’t leave free cash on the table. Take a closer look at your benefits package. If your company offers an incentive match, whatever they match, put that percentage into your retirement fund. Some employers match as much as 50% of your contribution, while others don’t match at all. If you are lucky enough to work for a company that matches, don’t leave that free money behind.

Be more aggressive, if you are years from retirement. If you have a long time until retirement, you may be better off with a portfolio that has more stocks and fewer fixed equities, like CDs and bonds. Many 401(k) plans have target date funds, which automatically shift from an aggressive portfolio into less risky ones, as the owner approaches their retirement date. These are excellent solutions for investors who don’t want the headache of managing their portfolios.

Don’t be too aggressive. Retirees and almost-retirees need to be cautious, shifting to asset preservation rather than playing catch-up in markets, which can be risky. Many people take more risks than they realize.

Consider rebalancing. Various positions in a portfolio change over time, as investments grow at different rates. Target allocations can change, and that means it’s time for a rebalance. For example, if you started with a target allocation of 50% bonds and 50% stocks a few years ago, it’s likely that this ratio has changed. Rebalancing allows investors to take some of their appreciated assets and use them to buy underappreciated assets, selling high and buying low.

One last thought: the Roth 401(k). You put after-tax money into a Roth 401(k) and withdrawals are tax-free. Tax rates now are relatively low, so this might be a good time to fund a Roth 401(k) rather than a traditional 401(k). The new tax laws are set to sunset in 2025, and taxes are likely to rise in the future.

Reference: Bankrate (December 16, 2019) “Your 401(k) plan: 5 smart moves to make in 2020”

Jumbo Reverse Mortgages Making a Return

If you are a senior with serious digs in places like California or the New York City area or other markets where many homeowners are house-rich and cash-poor, you might be able to secure these funds with only your home.

The market for jumbo mortgages is back, which means cash-strapped seniors with valuable real estate have an option for retirement funding, says Barron’s in the recent article “Reverse Mortgages Can Help House-Rich Seniors Free Up Cash for Retirement. Here’s How They Work.” A reverse mortgage, where owners tap the equity in their homes through mortgages that aren’t paid back until they leave the house, sell the property or pass, used to be considered a last resort. However, things have changed.

Financial experts began publishing research several years ago showing how the use of a reverse mortgage—strategically, not casually—could actually help retirement portfolios do better in times of down markets or as a way of delaying taking Social Security benefits.

Here’s the most simplified version: if the market is going up, use retirement accounts for income. If the market goes down, use the reverse mortgage.

After the research papers were published, it looked like reverse mortgages were going mainstream. However, in 2017, the federal government raised the initial mortgage-insurance premiums and lowered lending limits for federally insured reverse mortgages. The reverse mortgage sector took a dip.

Lenders have now begun rolling out proprietary jumbo loans that are not subject to these new federal regulations. They’re growing in popularity in areas where retirees have hefty amounts of home equity but are income short. For the most part, these jumbo reverse mortgages are now all about big sums of money. A new product is also starting to show up: jumbo mortgages that include a line of credit, in addition to a lump sum.

Some seniors are using the jumbo reverse mortgages to pay off conventional mortgages, or to raise funds for long-term care or living expenses. Boomers are more comfortable with holding debt than their parents. Other seniors are still better off using the federally insured reverse mortgage with a line of credit, to make their retirement funds last longer.

In the past, people waited until they were completely out of funds, before taking a reverse mortgage. The new strategy is taking a reverse mortgage early in retirement and using the money to protect retirement portfolios during market downturns. Even with the higher fees than traditional mortgages, this provides seniors with access to money immediately.

The cost of long-term care is expected to continue to drive the growing popularity of reverse mortgages. If the home is located in an area where it will continue to grow in value, that growth could offset the interest costs. If the market takes a tumble, the loan isn’t impacted.

Reference: Barron’s (December 16, 2019) “Reverse Mortgages Can Help House-Rich Seniors Free Up Cash for Retirement. Here’s How They Work”

From Gentle Persuasion to a No-Nonsense Approach, Talking About Estate Plans

“Few families, of course, enjoy talking about money. Introduce the idea of estate plans and inheritance—who gets what and why—and conversations often never get off the ground.”

Sometimes the first attempt is a flop. Imaging this exchange: “So, do you want to talk about what happens when you die?” Answer: “Nope.” That’s what can happen, but it doesn’t have to, says The Wall Street Journal’s recent article “Readers Offer Their Advice on Talking to Aging Parents About Estate Plans.”

Many people have successfully begun this conversation with their aging parents. The gentle persuasion method is deemed to be the most successful. Treating elderly parents as adults, which they are, and asking about their fears and concerns is one way to start. Educating, not lecturing, is a respectful way to move the conversation forward.

Instead of asking a series of rapid-fire questions, provide information. One family assembled a notebook with articles about how to find an estate planning attorney, when people might need a trust, or why naming someone as power of attorney is so important.

Others begin by first talking about less important matters than bank accounts and bequests. Asking a parent for a list of utility companies with the account number, phone number and if they are paying bills online, their password, is an easy entry to thinking about next steps. Sometimes a gentle nudge, is all it takes to unlock the doors.

For some families, a more direct, less gentle approach gets the job done. That includes being willing to tell parents that not having an estate plan or not being willing to talk about their estate plan is going to lead to disaster for everyone. Warn them about taxes or remind them that the state will disburse all of their hard-earned assets, if they don’t have a plan in place.

One son tapped into his father’s strong dislike of paying taxes. He asked a tax attorney to figure out how much the family would have to pay in estate taxes, if there were no estate plan in place. It was an eye-opener, and the father became immediately receptive to sitting down with an estate planning attorney.

A daughter had tried repeatedly to get her father to speak with an estate planning attorney. His response was the same for several decades: he didn’t believe that his estate was big enough to warrant doing any kind of planning. One evening the daughter simply threw up her hands in frustration and told him, “Fine, if your favorite charity is the federal government, do nothing…but if you’d rather benefit the church or a university, do something and make your desires known.”

For months after seeing an estate attorney and putting a plan in place, he repeated the same phrase to her: “I had no idea we were worth so much.”

Between the extremes is a third option: letting someone else handle the conversation. Aging parents may be more receptive to listening to a trusted individual, who is of their same generation. One adult daughter contacted her wealthy mother’s estate planning attorney and financial advisor. The mother would not listen to the daughter, but she did listen to her estate planning attorney and her financial advisor, when they both reminded her that her estate plan had not been reviewed in years.

Reference: The Wall Street Journal (December 16, 2019) “Readers Offer Their Advice on Talking to Aging Parents About Estate Plans”

Are There Other Benefits to Roth IRA Conversions Besides Taxes?

“For some savers, the appeal of moving assets to a Roth individual retirement account often stems from the tax-free income it will deliver in their golden years.”

Taking withdrawals tax-free during retirement is just one benefit of converting assets to a Roth, asserts CNBC in the article “Here’s how Roth IRA conversions can deliver some lucrative hidden benefits.” To understand the others, let’s first clarify the retirement benefits of a Roth IRA. Unlike traditional IRAs, where withdrawals are taxed as income, Roth IRA withdrawals are generally tax free, once the owner reaches 59½. There are also no required minimum distributions—the annual amount that other retirement accounts require be withdrawn starting at age 70½—as long as the owner is alive.

The downside? Contributions are not tax-deductible the same way they are with traditional IRAs or 401(k) plans. If you move pre-tax money from one of those accounts to a Roth IRA, you have to pay taxes on the amount that is moved.

However, federal taxes are now relatively low. If you were to do a conversion in the future, when federal taxes might be higher, it could cost more. It’s not likely that taxes are going down.

There are contributions and income limits that apply to direct contributions made to Roth IRAs.  However, those restrictions are not in place for assets transferred from other qualified accounts.  There may, however, be valid reasons not to move an entire retirement account to a Roth, or to limit how much is converted in any given year. Some of these rules can get confusing, so working with a professional is recommended.

Some situations where a Roth conversion makes sense:

When one spouse dies, the household income may not drop all that much. Being taxed as a single filer generates more in taxes than a joint return. A household income of $60,000 puts a married couple in the 12% bracket, while a single filer with that income is in the 22% bracket. The standard deduction for singles is also half that of marrieds: $12,000 vs. $24,400 in 2019. If the couple did a Roth conversion while both are living, the surviving spouse would have less of a tax burden.

If someone is planning on an early retirement, regular IRAs and 401(k)s have a 10% penalty for withdrawals before 59½. Roth contributions can be withdrawn anytime penalty-free, although the earnings must be left in the account to avoid penalties and taxes. For money that was converted to a Roth IRA, just don’t touch it for five years. In addition, only the contributions can be taken out, not the earnings.

Relocating won’t make any changes in federal tax burdens, but it may make a difference for state taxes. If a couple plans on moving to a state with higher taxes in the future, the time to convert money to a Roth IRA would be before moving. If the future new home is in a low or no state tax state, then waiting until after the move would be better.

For a small business owner who can use the 20% deduction on pass-through income, that is, income that flows from the business to the personal tax return—then a Roth rollover may help reduce the amount paid in taxes. If the taxpayer is eligible, it applies to the lesser of either the taxable income (minus capital gains) or the qualified business income. Therefore, the more money to which that deduction may apply, the less will be owed in taxes.

References: CNBC (December 12, 2019) “Here’s how Roth IRA conversions can deliver some lucrative hidden benefits”

Key Health Document Most Americans Don’t Have but Should

“Regardless of one’s feeling on estate planning, there is one estate planning document that all Americans should have: A Health Care Directive.”

You may not like the idea of contemplating your own mortality, or that of a loved one. You may procrastinate all year long about putting your final wishes in place. However, this one document is important for yourself, your loved ones and your life. You shouldn’t put it off any longer. Forbes’ recent article titled “Two-Thirds of All Americans Are Missing This Estate Planning Document” explains why.

A health care directive is a legal document that an individual will use to give specific directions for caregivers, in case of dementia or illness. It directs end of life decisions. It also gives directions for how the person wishes their body to be cared for after their death.

This document is known by several different names: living wills, durable health care powers of attorney or medical directives. However, the purpose is the same: to give guidance and direction on making medical and end-of-life decisions.

This document itself is a relatively new one. The first was created in California in 1976, and by 1992, all fifty states had similar laws. The fact that the law was accepted so fast across the country, indicates how important it is. The document provides control when a person is impaired and after their death. That is at the heart of all estate planning.

Yet just as so many Americans don’t have wills, only a third have a health care directive. That’s a surprise, since both estate planning attorneys and health care professionals regularly encourage people to have these documents in place.

A key part of a health care directive is selecting an agent. This is a person who will act as the proxy to make decisions for another person, consistent with their wishes. They will also have to advocate for the person with respect to having treatment continue or shifting to pain management and palliative care. The spouse is often the first choice for this role. An adult child or other close and trusted family or friends can also serve.

The agent’s role does not end at death but continues to ensure that post-mortem wishes are carried out. The agent takes control of the person’s body, making sure that any organ donations are made, if it was the person’s wish.

Once any donation wishes are carried out, the agent also makes sure that funeral wishes are done according to the person’s wishes. Burial is an ancient tradition, but there are many different choices to be made. The health care directive can have as many details as possible, or simply state burial or cremation.

Having a health care directive in place permits an individual to state his or her wishes clearly. Talk with your estate planning attorney about creating a health care directive as part of your comprehensive estate plan.

Reference: Forbes (December 13, 2019) “Two-Thirds of All Americans Are Missing This Estate Planning Document”

The Many Responsibilities of Inheriting a Home

“Understanding what happens when you inherit a house, as well as addressing the tough financial and emotional decisions on what to do with the home, can be intimidating.”

When you inherit a home, there are three key factors to consider: the financial and legal responsibilities of the home, the tax liabilities of the home and what you’ll eventually do with the home. All of these different things relate to each other, explains Million Acres in “A Guide to What Happens When You Inherit a House.”

Let’s look at taxes first. There’s no federal tax associated with inheriting a house, but some states have inheritance taxes. For most situations, this inheritance does not lead to an immediate tax liability. When a property is inherited, the IRS establishes a fair market value for the property, which is the new basis for the property. This is a step-up basis. It is the valuation that is used to set future taxes, when the property is sold.

Capital gains are a tax relating to the profits generated from selling an asset, in this case, a house. The step up in basis means the heir only has to pay capital gains taxes, if the home is sold. The taxes will be the difference between the fair market value set at the time of the inheritance and the selling price.

If the property has a mortgage, heirs will need to know what type of mortgage it is and if it is assumable or due on sale. Most mortgage companies allow heirs to take over the payments, according to the original loan terms. However, if there is a reverse mortgage on the home, the unpaid balance is due when the person who took out the reverse mortgage dies. This usually requires the heirs to sell the home to settle the debt.

The condition of the inherited home often determines what heirs decide to do with the house. If it hasn’t been maintained and needs major work, it may be easier to sell it as-is, rather than undertake renovations. Heirs are responsible for taxes, insurance and maintenance. However, if the house is in good shape, it may make sense to keep it.

What happens when siblings inherit a house together? That can get complicated, if each person has a different idea about what to do with the house. One may want to sell now for cash, while another may want to rent it out for income. What ultimately happens to the property, may depend on how well the siblings communicate and make decisions together.

Often the best option is to simply sell the home, especially if multiple heirs are involved. Note that there are costs associated with the sale of the house. This includes any outstanding debts, like a mortgage, the cost of fixing up the home to prepare it for sale, closing costs and fees and real estate agent commissions. If there is a profit on the sale of the home from the tax basis at the time of inheritance, the heirs may need to pay short-term or long-term capital gains tax, depending on how long they held the property.

Talk with an estate planning attorney about managing the sale of the family home. They will be able to guide you, advise you about taxes and keep the family moving through the process of settling the estate.

Reference: Million Acres (December 4, 2019) “A Guide to What Happens When You Inherit a House”

Social Security Service May Be Improving

“If you’ve ever experienced a long wait to get help from the Social Security Administration, the agency has some good news for you: the pace is about to pick up a bit.”

Congress has made so many cuts to Social Security in the last ten years, that the agency has had to close field offices and make staffing cuts that have led to backlogs in many areas. This has included long delays on an 800-number and a huge backlog of people applying for disability insurance claims. However, change is on the way, reports Next Avenue in the article “Expect a Little Better Service from Social Security Soon.”

Social Security Commissioner Andrew Saul announced his goals, including some steps that he expects will solve several problems. Starting on January 8, field offices nationwide will be open on Wednesday afternoons. They have been closed on Wednesday afternoons since 2012.

The agency will also hire more than a thousand new employees to work on the national 800-number and in processing centers, where the paperwork gets handled. More hires will also be made later in 2020.

The question of how the Social Security Administration will pay for the new hires and the additional hours of service is not yet clear, since Congress has not yet authorized funds to pay for this. Between 2010 and 2019, after adjusting for inflation, the agency’s budget has been cut by 11%. At the same time, the number of Social Security beneficiaries has grown by more than 16%. The House appropriations bill for 2020, as it stands now, will barely allow the agency to keep up with inflation. The Senate’s bill would cut the agency’s budget.

Saul is the first confirmed commissioner since 2013. All others since 2013 have been “acting” commissioners. He has the discretion to move funds, but it’s not clear exactly how his changes will be funded.

No government agency touches as many lives as the Social Security Administration. This year, the agency will pay more than a trillion dollars in benefits to 69 million Americans. As Boomers age, the expectation is that beneficiary rolls will increase by 43% over the next two decades.

It’s a budget crisis that experts say should not exist at all. The budget is funded through the same payroll taxes that fund benefits. Workers and employers share a 12.4% tax. Social Security benefits were removed from the federal budget under legislation enacted in 1990, but administrative costs are counted because of an interpretation of the legislation by the Office of Management and Budget. Since the Budget Control Act was passed in 2011, the SSA budget has been competing with other federal priorities.

Three former Social Security commissioners wrote to Congress this past summer, urging them to fix the budgeting process. This was an unusual step, but it’s going to take a lot more to get Congress to act.

Reference: Next Avenue (December 10, 2019) “Expect a Little Better Service from Social Security Soon”

How Estate Planning Keeps the Peace for Blended Families

“Even a close family can have quarrels and confrontations, but these conflicts tend to be more prominent within a blended family.”

With the IRS’s announcement that the first $11.58 million (in 2020) of a taxable estate is free from estate taxes, most people won’t have to worry about paying estate taxes. Therefore, what’s the biggest reason to have an estate plan?

Earlier this year, a survey was conducted at the 53^rd annual Heckerling Institute of Estate Planning, a prestigious legal and financial conference that attracts leaders in the field of estate planning. For the second year in a row, family conflict was identified as the biggest threat to estate planning, reports Investment News in the article “Reducing potential family conflicts.”

Statistics show that there are more blended families in the U.S. than ever before.

The increase in blended families has led to an increase in family conflicts. While open and honest communication is the key to any kind of conflict resolution, it’s particularly sticky when it comes to blended families. For most families, it’s a good idea to talk openly about estate plans, rather than waiting until one of the spouses has passed and explaining to the biological and stepchildren how the assets are being distributed. Discussing the estate plan before anyone dies, at the very least gives everyone a chance to voice their opinions, even if no changes to the spouse’s plans are made.

How do you minimize conflicts within blended families? One way is with a prenuptial agreement, which is executed before marriage and clarifies the financial rights of each spouse, in the event of divorce or death. This is especially useful, when there is a disparity in wealth or age between the couple.

However, not everyone is willing to have a prenup. And even if they do, family conflicts can still crop up. Let’s say Gary and Helen are married, each with children from a previous marriage. Gary wants to give his entire estate to Helen when he dies. If Gary dies first, there’s no legal reason for Helen to give any of Gary’s assets to his biological children.

There are any number of solutions. If Gary really wants to cut his children out of his will, he can talk with them and explain his thinking. He can also have an estate planning attorney include a “no contest” clause in his will. If any named beneficiary challenges the will, they will lose any inheritance and are treated legally, as if they have predeceased the decedent. Gary could also use a revocable living trust, which would avoid the estate being probated and deny the children an opportunity to challenge his will.

A better solution would be to craft an estate plan that benefits both Gary and Helen’s children. Harry’s children could receive a partial outright distribution when Gary dies, with the remaining estate passing to Helen. A trust could be created for Helen’s benefit, but the remaining trust assets could go to Gary’s children when Helen dies.

There are many different ways to resolve this issue with an eye to minimizing conflict among children in blended families. If the parents are truly invested in keeping their children together as a family, it is worth the effort to create an estate plan that cares for the spouses and all of the children. An estate planning attorney can create a plan to accomplish your goals for the entire blended family.

Reference: Investment News (December 9, 2019) “Reducing potential family conflicts”

Gig Workers, Don’t Forget Retirement Savings

“More than one-third of the American workforce is already part of this on-demand economy, and researchers predict these figures are likely to go up to 50% by 2027.

For better or worse, the gig economy is here to stay. It offers flexible hours, and participants have the option to choose their clients and projects, often enjoying the benefits of working remotely. However, freelancers and other gig workers miss out on the benefits offered by more traditional employment, says Forbes in the recent article “What Gig Workers Should Know About Self-Directed Retirement Accounts.” They are completely responsible for their own retirement savings, health care expenses and any other forms of long-term savings.

How can a freelancer build a nest egg? It sounds simple. Establish a retirement account early on and start contributing, no matter what the amount. There is no lack of retirement plans available today for self-employed professionals and part-time workers, including traditional IRAs, self-employed 401(k) plans, and simplified employee pension IRAs, among others. Having the income and the discipline to do this is the challenge.

IRAs: Freelancers may set up individual retirement accounts, contributing up to $6,000 annually. For those who are 50 and over, there’s an additional catch-up contribution of $1,000 permitted. A freelancer can go with a traditional IRA or a Roth IRA.

SEP IRAs: A plan participant may contribute up to a quarter of their income, up to $56,000.

Self-employed 401(k) or solo 401(k): This plan offers the most flexibility for retirement contributions. The person can contribute up to $62,000 each year. These plans also have a lower maintenance cost and investment options that go beyond the stock market, since there is no requirement that the plan have a custodian. The accounts can include real estate property, commercial property, private lending, tax liens or multifamily syndication.

The Good and the Bad of Self-Directed Retirement Plans

Self-directed retirement accounts allow participants to invest in alternative investments. That can be a good thing; if a self-employed professional wanted to leverage their industry experience to make long-term limited period investments, for example. For a self-directed IRA, the plan holder does need a custodian to act as a trustee of the account. That could be a bank, brokerage firm, insured credit union or a legal entity approved by the IRS. The custodian is not authorized to provide investment advice to plan participants.

The self-directed solo 401(k) is structured with a 401(k) trust, used as a vehicle to hold the assets. The account holder is the trustee and has total control over how the assets are used. Solo 401(k) plans allow post-tax Roth contributions to be made to a separate designated Roth account under the same plan. That lets investments grow tax-free, as well as tax-free qualified distributions.

However, with all this freedom comes risk. If investments don’t work out, there’s no safety net.  There are also many regulations around these self-directed accounts. Some transactions are prohibited and there are rules regarding withdrawals and participant loans.

Reference: Forbes (December 5, 2019) “What Gig Workers Should Know About Self-Directed Retirement Accounts”