Well, that didn’t take long.
In what’s becoming a routine political tug-of-war, the Trump administration (yes, back again) has rescinded the Biden-era Department of Labor (DOL) guidance cautioning plan sponsors against offering cryptocurrency in 401(k) plans. To quote every compliance officer I’ve ever met: here we go again.
Now let me be clear—I love crypto. I believe in decentralization, innovation, and financial technology that isn’t stuck in the Stone Age of paper checks and fax machines. I think crypto has a role to play in the future of retirement planning. But like any shiny new object in the retirement space, it needs to be handled with a mix of curiosity, caution, and common sense.
Just because the DOL has backed off doesn’t mean you should go rushing to throw Bitcoin into your investment lineup like it’s a Target Date Fund. Fiduciary responsibility doesn’t vanish with a policy shift. ERISA didn’t change overnight.
If I were ever to offer crypto in a 401(k)—and I’m not saying I would, just if—I certainly wouldn’t do it through some fly-by-night crypto wallet company that promises the moon, charges you the stars, and stores your coins on a server in someone’s basement. No, I’d use a trusted custodian—someone with experience, infrastructure, insurance, and a track record of not disappearing when the market tanks.
Because let’s not forget: plan sponsors have a duty of prudence. That means understanding what you’re offering, why you’re offering it, and how it fits into the larger plan structure. Offering crypto in a plan isn’t inherently imprudent—but doing it with the wrong partner absolutely is.
So while the political pendulum swings, let’s remember our job hasn’t changed. We’re still here to protect participants, build smart plans, and avoid ending up as the cautionary tale at the next ASPPA conference.
Stay curious. Stay cautious. And please—if you’re going to offer crypto in a 401(k), don’t let a Reddit thread be your due diligence.
