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The Keep/Employer Plan Rollovers

What the Rollover Window Looks Like in 2026.

Rising layoffs, early retirements, and a shifting legislative landscape are concentrating one of the most consequential financial decisions into a very short window. Here’s what to know before the clock runs out.

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Something is concentrating in 2026 that doesn’t get enough attention in the retirement planning conversation: an unusually large number of people are being pushed through the employer plan rollover decision at the same time, under conditions that make it harder to think clearly. Layoffs across technology, healthcare, and financial services. Early retirement packages offered to reduce headcount without litigation. Voluntary departures driven by burnout, caregiving demands, or simple re-evaluation after a disorienting few years. The result is a cohort of people in their late 50s and early 60s arriving at one of the most consequential financial crossroads of their lives with less preparation time than they expected.

The employer plan rollover moment — what to do with a 401(k), a pension, or both when employment ends — deserves the same deliberate attention as any major financial decision. What makes 2026 different is the combination of a shifting legislative environment, higher interest rates that change the calculus on pension comparisons, and a market environment that has produced exceptional recent returns that may distort risk perception. Each of these factors affects what the right decision looks like — and none of them favor rushing.

What’s Different About This Moment

The SECURE 2.0 Act, signed into law in late 2022, made a series of changes to retirement account rules that are still being absorbed by both retirees and advisors. Required Minimum Distribution ages moved to 73 for those born between 1951 and 1959, and will move to 75 for those born in 1960 or later. Roth 401(k) accounts are no longer subject to RMDs during the owner’s lifetime — a change that took effect in 2024. Catch-up contribution limits increased. Rules around inherited IRAs were clarified in ways that significantly affect distribution planning for non-spouse beneficiaries.

“The rollover moment is where assets built under one set of rules must be reorganized for an entirely different purpose. Most people pass through this gate without stopping to look at what they’re walking into.”

For someone executing a rollover in 2026, these changes have direct implications. A Roth 401(k) that was subject to RMDs before 2024 can now be rolled to a Roth IRA without triggering a new five-year clock if certain conditions are met. A traditional 401(k) rolled to an IRA may have different RMD timing than the participant assumed. The rules are not dramatically different — but they are different enough that a rollover executed based on assumptions from three years ago may not be optimally structured.

The Pension Decision in a Higher Rate Environment

For employees who have a defined benefit pension available — either as a monthly annuity or a lump-sum option — the interest rate environment of 2025 and 2026 changes the comparison in ways that matter. Pension lump-sum values are calculated using interest rates specified by the IRS. When interest rates are higher, the present value of a future income stream is lower — meaning lump-sum offers are smaller relative to the monthly benefit than they would be in a low-rate environment. This is not intuitive for most retirees, and it is frequently misunderstood.

Before Making Any Rollover or Pension Decision

  • Confirm the deadline for your pension election — and whether it is truly irrevocable once submitted
  • Request the lump-sum calculation and ask which interest rate assumption was used
  • Model what an equivalent guaranteed income stream would cost on the open market at current rates — this is a direct comparison, not a theoretical one
  • Evaluate whether your 401(k) rollover destination has been reviewed against current investment options, fee structures, and your income plan
  • Confirm how the rollover interacts with your Social Security claiming strategy and projected RMD timing

The Clock Is the Variable Most People Underestimate

Employer plan decisions come with deadlines. Pension elections, once submitted, are often irrevocable. COBRA coverage for health insurance runs 18 months from separation, after which Medicare eligibility — or the lack of it for those under 65 — becomes an immediate practical concern. The window to execute certain rollover strategies efficiently may close as income changes, as new accounts are opened, or as the tax year turns. None of these deadlines are cause for panic. But all of them reward preparation over procrastination. The rollover window of 2026 is open right now. It will not stay open indefinitely — and the decisions made inside it will shape retirement income, tax exposure, and legacy outcomes for decades.

Chris Owens
About the Author

Chris Owens

Founder & President of Owens Financial Group and architect of the Retire REGAL® Process — a structured retirement planning framework built around the belief that retirement freedom is designed, not accidental. #1 Amazon Best Selling author of Retire REGAL®: The Holy Grail of Retirement (Financial Services Industry · April 2026). Chris serves as an Investment Adviser Representative with Foundations Investment Advisors, LLC, an SEC-registered investment adviser.

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This commentary reflects the personal opinions, viewpoints and analyses of the author, Chris Owens. It does not necessarily reflect the views of Foundations Investment Advisors, LLC (“Foundations”) and is provided for educational purposes only. The contents are solely maintained by and the responsibility of Chris Owens. This content is subject to change at any time without notice and does not represent an express or implied opinion or endorsement of any specific investment opportunity, investment strategy or planning strategy. Foundations in no way deems reliable any statistical data or information obtained from or prepared by Chris Owens in this commentary, nor does Foundations guarantee its accuracy or completeness. No legal or tax advice is provided or intended. Investment advisory services are offered through Foundations Investment Advisors, LLC, an SEC registered investment adviser. Investments in securities involve the risk of loss. Past performance is no guarantee of future results. The Retire REGAL® Process and REGAL Stronghold™ are proprietary planning frameworks developed by Owens Financial Group, LLC and do not represent specific investment products or guarantee outcomes.