Michael Kreps on 2025's Quiet Retirement Revolution: Trump Accounts, Saver’s Match, and More
Michael Kreps doesn't just observe the retirement savings landscape—he helps us shape it. As Chair of Groom Law Group's Retirement Services Group, Kreps works with a diverse array of clients navigating some of the most complex retirement and health plan issues facing the industry today. His unique vantage point combines deep technical expertise with firsthand experience in the legislative and regulatory process, making him one of the go-to voices when Washington's policy shifts create ripples across the retirement ecosystem.
As 2025 draws to a close and we look toward 2026, we sat down with Michael to discuss the year's highlights, emerging opportunities, persistent challenges, and his big-picture vision for where the retirement savings system is heading—and where it should go.
TLDR: Executive Summary
In this wide-ranging conversation, Michael Kreps identifies several pivotal developments shaping retirement savings:
2025's Defining Shift: A fundamental change in how the Department of Labor regulates employee benefits, moving from aggressive enforcement of consumer protections to a more employer-friendly, innovation-focused approach that's markedly different from the Obama, Biden, and first Trump administrations.
2026's Make-or-Break Programs: Trump accounts (childhood savings accounts) and the refundable Saver’s Match face critical implementation years, with both requiring unprecedented public-private infrastructure that could transform the entire retirement system if done right.
Cautious Optimism: After 15-20 years of progress, lifetime income solutions may finally achieve broader adoption as consultants, record keepers, and plan sponsors reach critical mass in understanding and implementation.
Key Concerns: The intense politicization of plan investments diverts energy from substantive improvements, while the retirement system increasingly struggles with mission creep—being asked to serve as emergency savings, disaster relief, and everything in between.
Big Picture: The industry is finally taking coverage gaps, portability, and support for lower-income Saver’s seriously, but needs to decide whether 401(k)s should remain retirement-focused or evolve into comprehensive savings vehicles—and build appropriate infrastructure accordingly.
Michael, 2025 is drawing to a close. Your view – what are some highlights from the retirement savings space this year?
I think it's been a slow start with a new administration. It takes a while to ramp up and transition from one set of policies to another. But we are seeing a pretty fundamental change in the regulation of employee benefits this year—retirement and health, generally.
With the new administration has come a new way of viewing the world, and it has led to a pretty significant change in retirement policy. Beginning in 2010, the Department of Labor became increasingly proactive in enforcing ERISA’s consumer protections and trying to create new ones. The Department was more willing to take novel legal positions and leverage all the tools available to them, even if it strained relationships with sponsors and providers. The most obvious example of this approach is the fiduciary rule, but there are plenty of others, like missing participants and mental health parity. Over three administrations—including the first Trump Administration—the Department’s relationship with the industry became less collaborative and more adversarial.
We're now seeing a complete refocusing of the agency to prioritize innovation in the system by reducing risks and burdens for plan fiduciaries. I'm not saying they've lost focus on participants. Regardless of the administration, officials at the Department generally believe they're doing what's right for participants. But they clearly have a different vision for the Department’s role in the system.
It's a pronounced change.
Sometimes those sorts of changes create fresh air, a new way of thinking about things. Are you seeing some reflections of that in industry?
Yes, I think we're seeing a lot of that. There's a lot of product design and innovation happening right now, and there's a desire on the part of the administration to facilitate and encourage some of that, particularly around the use of private assets in defined contribution plans and incentives for lifetime income.
More generally, you see it on the enforcement side. You can already see the enforcement priorities changing, in pretty close to real time. Where there was deep skepticism in the last administration about things like cryptocurrency and private funds, this administration has the polar opposite view—it is actively encouraging those industries. You see that playing out in product development, in the direction the industry is headed, and where the energy is flowing.
Interesting! And what are you excited about in 2026 as you look forward?
There are two things that I'm excited about, or at least interested in, and they both have to do with savings accounts. One is the new Trump accounts, and the second is the refundable Saver’s Match. Both of those policies are intended to provide government subsidies for folks with lower incomes. I guess all kids are low income, right? I mean, you do start out that way—with negative income!
These are both intended to subsidize wealth creation, maybe for retirement, maybe for other things. These are federal policies to inject capital from the federal government into people's accounts to help them build savings. And it's going to be a make-or-break year in 2026 for both programs.
The Trump accounts go live next year, and every kid born from 2025 through 2028 will get $1,000. Treasury has a lot of work to do and not much time to do it.
For the Saver’s Match, there's a little more time. The Saver’s Match passed in 2022 as part of SECURE 2.0, and it's just really hard to implement. It's going to require a public-private partnership between the federal government and all the participating plans in the country. There are over 600,000, maybe even 700,000 plans out there, not including all the IRAs that are eligible. It's just a monumental task to build the infrastructure to deliver that money from the federal government into people's accounts while protecting against fraud, protecting people's privacy and data security, and coordinating with dozens and dozens of record keepers and other financial institutions.
I'm excited to see how that rolls out. I'm hopeful the federal government will embrace building more of a clearinghouse-type infrastructure to support both activities and support the retirement system more broadly. This is a really important year coming up.
Two connected questions. On the Trump account side, recently someone said to us they're just not seeing any action there. And secondly, I've heard people say there's crossover in many of the infrastructure elements associated with both types of accounts—for example, getting federal funds in. Can you give a quick take on what you're seeing?
I think there’s actually a lot of energy around Trump accounts. Senior administration officials, including the Treasury Secretary, are publicly touting the accounts, and Treasury is prioritizing implementation. There's a lot of thought from the research world, the academic world, and some in industry about how to structure these accounts as well.
I think folks in the retirement industry might be seeing less activity because the Trump accounts are less attractive for the financial services industry than other types of savings vehicles. Plus, the Trump accounts are, at the end of the day, just IRAs, so a lot of the infrastructure already exists.
I completely agree that there is also a lot of overlap between the infrastructure we need to facilitate the flow of money from the federal government into a Trump account and the flow of money from the government into plans and accounts for the Saver’s Match. The administration has a real opportunity to build an infrastructure that not only supports these two programs but supports the entire system.
Think of it this way: if you wanted to ship materials from Philadelphia to New York, you might build a road to do that, or a canal or a train track. But then lots of stuff can go down those roads, right? You might build it to ship beds, but couches and fruit can go down those roads too. If we could build a clearinghouse-type structure to facilitate these two programs, we'd have the ability to use that infrastructure to do lots of stuff—facilitating portability, finding missing participants, reuniting people with their accounts. There's all kinds of cool stuff we could do, and it could meaningfully improve retirement security for everyone, even if you don’t have a Trump account or aren’t eligible for the Saver’s Match.
We were just talking with someone this morning about how many retirement accounts they have.
(Laughing) Fourteen. I have fourteen accounts. I've barely had any jobs—I've had like three professional jobs in my life—and having fourteen accounts is crazy. But once you start to say, well, I've got a 401(k), I've got my TSP, I've got a cash balance plan, I've got FERS, I've got a Roth IRA, I've got a traditional IRA, I've got a brokerage account, an HSA…you start to add them all up, and all of a sudden you're like, wow, I have a lot of accounts. A lot of personal record keeping.
Maybe it'll be simpler in the future. That leads to our next question: What are you cautiously optimistic about?
There's a lot of talk about private funds in 401(k)s and things like that. I think that needs a little bit of time, and there's good work happening there. But the thing I'm most optimistic about is probably lifetime income—the distribution phase of retirement.
We've just made so much progress over the past 15 or 20 years in product design, record keeper support, and general knowledge about ways to help people generate income in retirement. I think we're on the precipice of it becoming more widely adopted. I realize folks have been saying that for a while, but I do start to see the dam break a little bit here and there.
The retirement industry moves slowly, and everyone kind of wants to be in the herd because it’s safer. But eventually the herd moves. I think we had some folks out there in front doing interesting, creative things, and the lessons they learned in those earlier days, people have taken up. Consultants understand lifetime income better. Record keepers understand it better. Plan sponsors understand it better. We're starting to see some real movement.
Taking the cautious side, is there anything concerning you at the moment where plan and program sponsors should be especially thoughtful?
One thing that troubles me a bit is the politicization of plan investments. There seems to be a perception that lots of fiduciaries either don’t understand their legal duties or are flouting the law by subordinating the interests of participants to some other political, corporate, or social goal. But the truth is that the vast majority of folks who invest ERISA money—whether they're selecting investments for a pension plan or picking investment options for a 401(k) lineup—take their jobs seriously, and they're focused on doing the best thing for participants. They don’t need new rules, more guidance, or to be micro-managed by regulators.
I think someone well-known said we should let the fiduciaries fiduce, since the fiduciary regulations and guidelines are already clear about what you have to do.
Exactly. We already know the rules. We don't need to be told what fiduciaries can and can’t consider when evaluating potential investments. If something's economically relevant, then fiduciaries should think about it, and they can use their best judgment to figure out how much weight to put on it. If something isn’t relevant from a financial perspective, then they don't consider it.
None of this is new. We've been having these debates for decades, and they're just not all that relevant to day-to-day plan administration. The energy that goes into debating and fighting over these issues is just wasted. It's not pushing the ball forward. It's taking away from something else we could do.
Final question, big picture: What are your thoughts on the evolution of the retirement savings space? What do you like, and what would you like to see us do differently?
I think we're taking seriously now, in a way we probably didn't 20 years ago, some of the legitimate criticisms of the system. Whether that's coverage—and you see the state auto-IRA programs filling a gap there, and a lot of talk at the federal level of expanding that—and almost more importantly, getting serious about portability and preventing leakage. A lot of the developments around auto-portability are pretty great. I love all the stuff that's happening there.
And then possibly one of the most important things happening is a renewed focus on supporting lower-income folks to save for retirement. All of that is really great. I think that's exciting.
On the other hand, I worry that we're increasingly asking the private retirement system to do too much. It was intended to provide income in retirement. That's the point of the tax preference. But we're increasingly demanding the system do more—provide emergency savings, finance a first home purchases, pay for college tuition, provide disaster support.
Some of that is fine. There are a lot of trade-offs that go into these considerations and issues. But the 401(k) is not a cure-all. It's just a savings program with some support from your employer and the federal government. If we're going to ask the 401(k) to do a whole bunch of other things, we probably need to build more infrastructure to support that.
Our policy seems a little manic in that it'll flip from "We've got to help people save for retirement"—very focused, let's give these low-income folks support, let's make sure everyone can be saving—and the next day we're like, "Go ahead and take all your money out because of COVID." There's a rationale for those choices, but if the 401(k) is just going to turn into an emergency savings program, then let's retool it to be a competent emergency savings program. Let's stop trying to make 401(k)s into everything for all people. Or if we want them to be everything for all people, then let's make them into a savings account that's better suited for that purpose.
You’re not wrong, Michael! The final word is yours –what is it?
The one thing I'll mention that I think is kind of cool is the current discussion about tontines. The Executive Order on alternatives in 401(k) plans has a little reference to longevity risk pools, and it's sort of reignited a debate that's been happening for a while on tontines.
All a tontine is, is just a non-guaranteed annuity—an annuitized system. It’s a pool of assets where, by the law of large numbers, we have enough people such that we can assume the average mortality experience. So everyone just has to save until the average mortality instead of to age 100. There are some real complexities, and there's also some real promise there. A number of other countries have worked through the challenge and come up with creative solutions around collective defined contribution and things like that, that may be worth discussing here. I think particularly for unionized workforces it might be a good spot to start.
There's a cool, robust conversation going on about tontines, and I'm here for it. I like it. I think it's kind of neat. I don't know if tontines are a good idea or not, but it's a great discussion. Other countries do it. We kind of grew up with a culture where we just said they're illegal, but they're not—you can do them. They're just really hard to do under the current regulatory structure. They're at least worth revisiting.
We need to make sure actuaries continue to have plenty of work as the DB world winds down, so cracking on the tontine side…
Exactly! They could be tontine actuaries. I think there's at least something new and interesting for us to talk about.
Michael – ending with a bang – we always appreciate your perspective and insights. Thank you!
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“If we could build a clearinghouse-type structure to facilitate these two programs, we’d have the ability to use that infrastructure to do lots of stuff—facilitating portability, finding missing participants, reuniting people with their accounts. There’s all kinds of cool stuff we could do….”
“Let’s stop trying to make 401(k)s into everything for all people. Or if we want them to be everything for all people, then let’s make them into a savings account that’s better suited for that purpose.”
