IRA rollover analysis that gives every rollover a specific, cited best-interest rationale
Every rollover file carries a specific, cited best-interest rationale, ready in minutes.
See one case, screen by screen ↓IRA rollover analysis compares the all-in cost and services of staying in a 401(k) or 403(b), rolling it to an IRA and moving it to a new employer's plan, and documents why the recommendation is in the client's best interest. IRA Rollover Analysis gives advisors and supervisors seven agents that read the plan's fee disclosure, price every path, flag what the client gives up and draft a cited PTE 2020-02 rationale, while a different principal decides and signs.
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IRA rollover analysis is the work behind every recommendation to move a client's 401(k) or 403(b) to an IRA. PTE 2020-02 stayed in force after the 2024 Retirement Security Rule was vacated on March 17, 2026, so the firm must still document specific reasons, the costs of staying, rolling and moving to a new employer's plan, and give the client a disclosure to sign. Today the advisor chases the 404(a)(5) fee disclosure for weeks, re-keys fund expenses from a PDF into a calculator, and writes a reason from a template.
Examiners test the substance. The SEC's FY2026 exam priorities and FINRA's 2026 oversight report both name rollover and account-type recommendations, and a reason like “more investment choices and greater flexibility” would fit any client. The service differences that matter most — a stable value fund, the Rule of 55, plan-only withdrawal rules — are written from memory or missed. Supervisors approve under volume pressure, and the annual retrospective review is a sample, due six months after the year ends.
Estimated split for one rollover file, in hours, by hand and with the solution.
Seven agents read the plan's fee disclosure, price every path, flag what the client gives up and draft a cited rationale; a critic argues against it, and a supervisor decides.
Dana Whitfield, 58, left Kestrel Ridge Manufacturing on August 28, 2026 after 22 years, with $612,400 in its 401(k). Her advisor at Quillfield Wealth, Jordan Kessler, CFP, recommends rolling it to a Quillfield Advisory IRA. Here is what happens to that recommendation, screen by screen, in the working solution.
Renee is a registered principal in New York. Her Today screen shows 26 files waiting for her, 4 due today and 1 overdue, out of 142 in the team queue. Overnight the agents read 214 documents for 58 new files, extracted 1,962 fees, priced 61 files three ways and drafted 61 rationales. First in her list: Dana Whitfield, with 4 Critic notes open.
Rationale Critic, 7:31 a.m.: “Questioned 11 drafts: 2 reasons would fit any client, 6 alternatives missing, 3 services not addressed.”
Staying in the Kestrel Ridge plan costs 0.31% a year all-in, $1,898. The Quillfield Advisory IRA costs 0.95%, $5,818 — $3,920 more a year. The Brightwater Medical Group 401(k), where Dana now works part-time, accepts roll-ins at 0.27%, $1,653. At one stated 6.0% rate for every path, after 20 years the ribbons end at $1,845,836, $1,622,714 and $1,860,668.
“Illustration only: 6.0% a year before costs for every path, costs taken yearly. Not a forecast; the value of services is not shown.”
The Fee Reader read 4 documents, 63 pages — the 404(a)(5) fee disclosure of Aug 14, 2026, the Q3 statement, the plan rules and Brightwater's fee disclosure — and found 14 fees, each at 0.93 confidence or higher. Fund expenses are weighted to her 5 holdings. A pin on the plan administrative fee opens page 3, line 3.2, with the working: 0.06% × $612,400 = $367.44 a year.
“Values below 0.90 confidence wait for a person before any agent uses them.”
Renee asks why the stable value fund is a problem. The Services agent answers that $148,200 — 24% of the balance — sits in the Kestrel Stable Value Fund crediting 3.10% at book value, and the fund is not available outside the plan. She asks whether the Digital Advice IRA would fit: the Cost agent says it costs 0.43%, $2,633 a year, but includes no planning, tax or Roth conversion work.
Services agent: “The rationale must say she gives this up and accepts it.”
The Services agent compared 10 things Dana keeps or gives up on each path, from the plans' own rules. Five matter: the stable value fund, the Rule of 55 (penalty-free withdrawals end in an IRA until she is 59½ on September 12, 2027), Roth conversions, partial withdrawals and advice. Rationale v1 addresses none of them.
“The Services agent flags differences; it does not give legal or tax advice.”
The Rationale Critic passed v1 on 4 of 7 checks. Sentence 3 — “An IRA will give you more investment choices and greater flexibility to meet your goals” — holds for 1,288 of 1,612 September files; stable value, the Rule of 55 and the Brightwater plan are missing. Against what PTE 2020-02 and Reg BI ask for, 5 of 8 are met. The agents suggest SB-02; Renee decides, writes her note and e-signs.
Renee's note: “Sentence 3 would fit any client. Address the stable-value fund, the Rule of 55 and the Brightwater plan, and give Dana's own reasons.”
Jordan asks the agents to cite Dana's Roth conversion plan and the consolidation of her three accounts, and to answer the Critic's notes. The Rationale Drafter reads his CRM planning notes and her other two statements, then writes v2: partial conversions of about $48,000 a year in 2027–2030 inside the 22% bracket, her three accounts, $742,400 in all, brought into one, and what she gives up, stated and accepted. Eight sentences, 17 citations.
Rationale Drafter: “Working on v2. I will not submit it — you will.”
Jordan submits v2. The Critic passes 7 of 7 checks, and v2 holds for 0 of 20 comparable files. All 8 of the PTE 2020-02 and Reg BI items are met. At +$3,920 a year and +0.64 points, the file sits under the $5,000 and 0.75-point thresholds, so one principal decides. Renee approves with reason code AP-01 and her electronic signature.
“I reviewed the sources behind this decision.”
The plain-English disclosure goes to Dana by e-signature: the four paths in percent and dollars, why the IRA is still recommended for her, what she gives up, and how the firm is paid. She signs the fiduciary acknowledgment at 10:06 a.m. Only then is the direct rollover of $612,400 from Northlake Retirement Services to her rollover IRA released, kept separate from her contributory IRA.
“Released automatically only when the file is approved and the client has signed.”
The Review & Evidence agent re-checks every file the day it closes: the 7 Critic checks, the cost arithmetic, and that what the client signed matches what was approved. In 2026 that is 13,402 closed files, 100%. Grace tests a sample of 40 a month by hand — 360 so far, 98.6% agreement. 47 findings, 8 still open. The Q3 interim report waits for Miriam Castellanos, the CCO, to certify.
“Re-checked by agents: 100% — 13,402 files, not a sample.”
The same rollover file, seen by four of the people who carry it — what the work looked like, and what it looks like now.
Seven agents read the plan's fee disclosure, price every path, flag what the client gives up and draft a cited rationale; a critic argues against it, and a supervisor decides.
Gathers the client's plan documents from the client's upload, the CRM, the plan document library and recordkeeper requests, classifies each page and chases what is missing.
Reads the 404(a)(5) fee disclosure, the statement, the plan rules and the investment menu, extracts every fee, weights fund expenses to the client's holdings and cites page and line.
Prices staying, the IRA, the new employer's plan and the firm's other IRA options all-in, in percent and dollars, with deterministic arithmetic, and draws the 20-year illustration.
Flags what the client keeps or gives up on each path: stable value, the Rule of 55, creditor protection, loans, Roth conversions, withdrawals, advice, required distributions, company stock and share classes.
Drafts the PTE 2020-02 and Reg BI rationale and the plain-English client disclosure from the costs, the flags and the advisor's planning notes, and redrafts when the advisor asks.
Argues against every draft with 7 checks: a swap test against 20 comparable files, costs in dollars and percent, every reasonable alternative, every flagged service, every fact cited, no promise, and conflicts disclosed.
Re-checks every closed file for the PTE 2020-02 retrospective review, drafts the report and builds exam packs with a SHA-256 manifest.
Approves, sends back or rejects with a reason code. The agents propose; a named person decides.
Ask about a file, a fee, a client or a rule — or tell the agents what to redraft. Every answer cites its source.
Why did the Critic flag Dana Whitfield's rationale?
Four notes on v1. C1: sentence 3 (“more investment choices and greater flexibility”) holds for 1,288 of 1,612 September files, so it would fit any client. C2: the Kestrel Stable Value Fund, $148,200 crediting 3.10%, has no IRA equivalent. C3: the Rule of 55 is not addressed. C4: the Brightwater plan takes roll-ins at 0.27% and was not compared.
Which files need a second approver this week?
Three in your queue: Marcus Lindqvist (+$7,194 a year, due today 4:30 p.m.), Henry Albrecht (age 72, $412,000 of company stock, +$10,104) and Walter Brandt (+$8,703). Each passes the $5,000 threshold; you approve first, then Victor Han.
Why is the stable value fund a problem?
$148,200 — 24% of her balance — sits in the Kestrel Stable Value Fund, crediting 3.10% at book value. The fund is not available outside the plan. In an IRA the nearest substitute is a 1–5 year Treasury ladder at market value, with no book-value guarantee. The rationale must say she gives this up and accepts it.
What did the retrospective review find this year?
Agents re-checked all 13,402 files closed in 2026; Grace Liu checked 360 by hand, with 98.6% agreement. 47 findings: 14 late client acknowledgments, 11 cost inputs wrong, 9 alternatives not compared, 7 estimates used without confirmation and 6 generic rationales approved — 8 still open.
13 screens from the working solution, on its sample data. Pick one to see it large.
The thresholds, clocks and checks every rollover file runs against are settings. Only the administrator edits them, and compliance approves each change.
| Setting | Default | Choose from |
|---|---|---|
| Second approver: annual cost increase above | $5,000 | Against staying in the plan |
| Second approver: rate increase above | 0.75 points | Percentage points a year |
| Second approver: client age at or above | 70 | Company stock (NUA) or an estimated fee always takes two approvals |
| Document gathering | 10 business days | Reminders on day 3 and day 7 |
| Supervisor review | 2 business days | From submission; pauses when sent back; a late review escalates to the senior supervising principal |
| Client signature | 5 business days | Reminders day 3 and day 5 |
| Fee values sent to a retirement specialist | Below 0.90 confidence | A person verifies before any agent uses the value |
| Rationale Critic | 7 of 7 checks | Or a recorded override with reason code AP-02 |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (LIMRA via NAPA, July 2025 — an estimated $855 billion of retail IRA rollovers in 2025; Morningstar via InvestmentNews, October 2026 — advisors spend 53% of the week with clients against a 63% ideal; DOL PTE 2020-02 — retrospective review report certified within six months of the period end). Context: N.D. Tex. vacatur of the 2024 Retirement Security Rule, March 17, 2026; SEC Division of Examinations FY2026 priorities, Nov 17, 2025; FINRA 2026 Annual Regulatory Oversight Report, Dec 9, 2025. People, firms, plans and clients named on this page are fictional — characters and sample data in the working solution.
IRA rollover analysis compares the all-in cost and services of staying in a 401(k) or 403(b), rolling it to an IRA and moving it to a new employer's plan, and documents why the recommendation is in the client's best interest. IRA Rollover Analysis gives advisors and supervisors seven agents that read the plan's fee disclosure, price every path, flag what the client gives up and draft a cited PTE 2020-02 rationale, while a different principal decides and signs.
PTE 2020-02 asks for documented, specific reasons that the rollover is in the investor’s best interest, disclosed to the investor, with a written acknowledgment of fiduciary status and a description of services and material conflicts. Reg BI’s care obligation asks the firm to understand the costs and consider reasonably available alternatives, including the new employer’s plan and the firm’s own lower-cost options. The solution checks each rationale against both before a supervisor decides.
Yes. The 2024 rule was vacated on March 17, 2026, and PTE 2020-02 remains in force in its original form, so documented rollover reasons are still required. The SEC's FY2026 exam priorities and FINRA's 2026 oversight report both name rollover and account-type recommendations.
The Rationale Critic runs a swap test: a reason must fail for at least 19 of 20 comparable clients. In the sample file, “more investment choices and greater flexibility” held for 1,288 of 1,612 September files and was flagged. The Critic also checks costs in dollars and percent, every reasonable alternative, every flagged service and every citation, and cannot be switched off.
The Intake agent looks in the plan document library and requests the document from the recordkeeper, with reminders. If it still does not arrive, a Form 5500 estimate can be used, labeled “estimated” with its confidence, and only once a retirement specialist confirms it. A file with an estimated fee always needs two approvals.
It is the annual review a firm relying on PTE 2020-02 runs to detect and prevent violations of the Impartial Conduct Standards and of its own policies, in a written report a senior executive officer certifies within six months of the period end. Here the Review & Evidence agent re-checks every file the day it closes — the Critic checks, the cost arithmetic and that what the client signed matches what was approved — compliance tests a sample by hand, and the chief compliance officer certifies. An exam pack for any file or period exports with a SHA-256 manifest.
Yes. The agents draft, check and explain; they never approve or submit a file. The advisor submits, a different registered principal approves or sends back with a reason code and e-signature, and a second principal approves above the thresholds. The client disclosure goes out only after approval, and the custodian transfer is released only once the file is approved and the client has signed.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your rollover policy, IRA programs and fee schedule, reason codes and a sample of past rollover files — and it goes live once every quality gate has passed. Setup ends with the agents re-running 20 decided files so you can compare their result with your supervisors' decisions.
Accounts open the same day, and not-in-good-order stops before the custodian sees it.
1-min demoSource of Wealth VerificationEvery dollar of a client's wealth traced to cited evidence before the BSA/AML Officer signs.
1-min demoReg BI Compliance ReviewEvery recommendation reviewed overnight; every flag decided by a principal, with evidence.
1-min demoWe'll run IRA Rollover Analysis on a sample of your own past rollover files and the plan documents behind them.