Bridges go both ways
The opportunity does not run in only one direction. Retirement convergence is too often described as a bridge from a 401(k) plan into an individual wealth account. Brian Brashaw, National Practice Leader for Employer Plan Solutions at Merit Financial Advisors, neatly frames it:
Wealth advisers already work with business owners, executives and human-resources leaders who may need help establishing or improving workplace plans. Retirement advisers, in turn, are well positioned to support participants whose needs extend beyond the plan. The strongest model is not built around extracting assets from one channel. It is built around serving a financial life across both.
That distinction matters because a rollover is not merely a transaction at the end of employment. It is often the consequence of a relationship built years earlier. Brashaw’s warning was direct:
“If you are meeting an employee at the moment of termination or distribution from an employer, you’re too late.”
The record keeper may have been the most visible financial institution in that worker’s life. Another adviser may already understand the household. Trust is rarely created at the precise moment money begins to move.
Rollovers now occur much before retirement
The data also challenges the assumption that rollovers are primarily retirement-age events. InvestorCOM platform data indicates that nearly half occur before traditional retirement age. The average rollover in the sample exceeded $300,000, and almost 60 percent involved more than $100,000. The opportunity therefore begins well before age 59½ or 65. It develops through job changes, consolidation decisions and the ordinary movement of a working life.
For many savers, however, the process remains needlessly difficult. Manifest has found that the average American holds roughly 2.8 old retirement accounts and that most people who begin a rollover struggle to complete it. Friction can lead to delay, abandonment or cashing out. A process intended to preserve retirement savings can instead become an obstacle course of paperwork, disconnected systems and unclear next steps.
Systems must be scalable, and durable.
The execution challenge was clear in a second InvestorCOM poll. Technology and workflow integration ranked as the leading constraint at 42 percent, followed closely by adviser training and consistency at 38 percent. The remaining responses were split between organizational policy around rollover advice at 13 percent and supervision and oversight capacity at 8 percent, with totals affected by rounding. In other words, 80 percent pointed to either systems or adviser consistency as the primary barrier.
Technology can remove much of that friction, but only if it supports the advice process rather than adding another isolated application. A scalable system must do more than initiate a transfer. It must help an adviser compare available options, document the basis for a recommendation, deliver the proposal, preserve the record and give supervisors a consistent way to review the decision. It must also adapt as regulations and firm policies change. Otherwise, digitization merely puts a faster interface on a fragmented process.
The regulatory uncertainty surrounding rollovers makes that consistency more important, not less. Rules and interpretations have shifted across administrations, but the direction of travel has been clear: recommendations involving retirement assets demand a defensible best-interest process. The 2024 fiduciary rule may have been vacated, but Prohibited Transaction Exemption 2020-02 did not disappear with it. Firms still need to understand when fiduciary status and conflicted advice trigger the exemption. They also need to follow their own policies, even when a headline suggests that a particular requirement has changed.
The practical answer is not to rebuild a compliance program every time Washington changes course. It is to establish a durable framework that compares alternatives, identifies conflicts, documents the reasoning behind a recommendation and can be applied consistently across the firm. A sound process can survive regulatory movement because it is rooted in the client’s best interest rather than the minimum demands of a single rule.
There is a similar lesson in the debate over retirement income. The industry has spent years designing in-plan income products, yet adoption has often lagged the ambition behind them. The problem is not the absence of need. Joshua Dietch, Head of U.S. Insights at NMG Consulting, captured the stakes:
“The purchase of guaranteed income is an incredibly personal decision that you have to take a lot of things into consideration.”