SECURE 2.0 and the Lost-Account Crisis: What 32 Million Orphaned 401(k)s Mean for 403(b) Savers

October 28, 2025

Introduction

The retirement savings landscape is facing a silent crisis that extends far beyond traditional 401(k) plans. With Capitalize's 2025 estimate revealing $2.1 trillion in forgotten 401(k) accounts, the systemic record-keeping gaps that plague employer-sponsored retirement plans are casting a long shadow over 403(b) savers in the nonprofit sector. (Comparing Beagle Financial's and Capitalize's 401(k) Rollover Experiences) The SECURE 2.0 Act's auto-enrollment mandates, while well-intentioned, may inadvertently exacerbate the problem of orphaned accounts as job turnover accelerates and workers accumulate multiple retirement accounts across their careers.

By mid-career, the typical American has three or more 401(k)s, and many lose track of at least one of them. (How Do Beagle Financial Services and Personal Capital Help Find Lost 401(k)s?) This fragmentation isn't limited to for-profit employers—nonprofit organizations offering 403(b) plans face identical challenges in maintaining participant connections as employees transition between organizations, retire, or simply forget about smaller account balances left behind.

The Scale of the Lost Account Problem

Understanding the $2.1 Trillion Crisis

The magnitude of forgotten retirement savings represents more than just numbers on a spreadsheet—it reflects a fundamental breakdown in the retirement system's ability to serve American workers effectively. Both Beagle Financial and Capitalize aim to eliminate "orphaned" retirement money that gets stranded when you leave an employer. (Comparing Beagle Financial's and Capitalize's 401(k) Rollover Experiences) This staggering figure encompasses accounts across all employer-sponsored retirement plans, including the often-overlooked 403(b) sector.

The problem compounds as workers change jobs more frequently than previous generations. Modern career patterns show employees switching employers every 3-5 years, creating a trail of small retirement accounts that become increasingly difficult to track. Beagle is a comprehensive 401(k) search service that helps individuals find all their old retirement accounts they may have lost or forgotten. (Beagle Review) This service model addresses a critical gap in the retirement ecosystem that affects both 401(k) and 403(b) participants equally.

The 403(b) Vulnerability Factor

Nonprofit organizations face unique challenges in retirement plan administration that make their participants particularly vulnerable to account abandonment. Unlike large corporations with dedicated HR departments and sophisticated record-keeping systems, many nonprofits operate with limited administrative resources. This resource constraint can lead to gaps in participant communication, especially during job transitions or organizational changes.

The fragmented nature of the 403(b) market, with multiple vendors serving individual organizations, creates additional complexity. Unlike 401(k) plans that often consolidate under major record-keepers, 403(b) plans may be scattered across insurance companies, mutual fund providers, and smaller regional administrators, making comprehensive account tracking more challenging.

SECURE 2.0's Double-Edged Impact

Auto-Enrollment: Solution or Amplifier?

The Setting Every Community Up for Retirement Enhancement 2.0 Act of 2022 (SECURE 2.0) was enacted on December 29, 2022, as a part of the Consolidated Appropriations Act of 2023. (SECURE 2.0 Act — A Bigger And (In Some Ways) Better Version Of The SECURE Act) The legislation's auto-enrollment provisions represent a significant shift in retirement plan design, requiring most new 401(k) and 403(b) plans to automatically enroll eligible employees.

While auto-enrollment successfully increases participation rates, it may inadvertently contribute to the orphaned account problem. Workers who are automatically enrolled but remain disengaged from their retirement planning are more likely to forget about accounts when they change jobs. The SECURE 2.0 Act contains more than 90 required and optional provisions, with effective dates ranging from December 29, 2022, through 2033. (A guide to SECURE 2.0)

Missing Participant Provisions

SECURE 2.0 does include provisions aimed at addressing missing participants, but these measures may not be sufficient to stem the tide of orphaned accounts. The legislation requires plan sponsors to take additional steps to locate missing participants before distributing their accounts, but enforcement mechanisms remain limited. Some provisions of SECURE 2.0 became effective immediately upon enactment, or in 2023, while others will become effective in 2025 or later. (SECURE 2.0 Act — A Bigger And (In Some Ways) Better Version Of The SECURE Act)

For 403(b) plans, these provisions create both opportunities and challenges. Nonprofit organizations must balance compliance costs with their mission-driven budgets, potentially leading to inconsistent implementation of missing participant search procedures.

The Technology Gap in Account Discovery

Current Search Limitations

The challenge of locating lost retirement accounts stems partly from the fragmented nature of record-keeping systems across the industry. Beagle Financial Services specializes in 401(k) detective work, using technology to search Form 5500 filings, the National Registry of Unclaimed Retirement Benefits, and other databases. (How Do Beagle Financial Services and Personal Capital Help Find Lost 401(k)s?) However, 403(b) plans often fall outside these traditional search parameters due to different reporting requirements and vendor structures.

Personal Capital, now called Empower Personal Dashboard, takes a "bring-your-own-data" approach, analyzing plans that users already know about. (How Do Beagle Financial Services and Personal Capital Help Find Lost 401(k)s?) This methodology, while useful for account aggregation, doesn't address the fundamental problem of truly lost accounts that participants have completely forgotten.

The 403(b) Search Challenge

The unique structure of 403(b) plans creates additional obstacles for account discovery services. Unlike 401(k) plans that must file comprehensive Form 5500 reports, many 403(b) plans are exempt from detailed reporting requirements. This exemption, while reducing administrative burden for small nonprofits, creates blind spots in the databases that account recovery services rely upon.

Beagle is a service that helps users track down their old 401(k)s and identify hidden fees that may be reducing the value of a user's retirement savings. (Find your old 401k's | Hassle-free rollover | Beagle) The service's focus on fee analysis becomes particularly relevant for 403(b) participants, who often face higher expense ratios and administrative fees than their 401(k) counterparts.

The Hidden Cost of Fragmentation

Fee Erosion in Small Accounts

One of the most insidious aspects of the orphaned account crisis is the gradual erosion of account values through fees. Small retirement accounts, often left behind when workers change jobs, become disproportionately affected by administrative charges and investment expenses. Beagle can identify hidden fees that may be reducing the value of a user's retirement savings. (Find your old 401k's | Hassle-free rollover | Beagle)

For 403(b) participants, this fee erosion can be particularly severe. Many 403(b) plans, especially those at smaller nonprofits, lack the negotiating power to secure institutional-class investment options. The result is higher expense ratios that can consume a significant portion of returns over time, especially in smaller accounts that don't benefit from economies of scale.

The Compounding Effect

The mathematical impact of fees on small, forgotten accounts is stark. A $5,000 account subject to 2% annual fees will lose $100 per year to expenses alone, not accounting for any investment gains or losses. Over a decade of neglect, such an account could see its purchasing power significantly diminished, even if underlying investments perform well.

This fee drag becomes more pronounced when combined with the typical investment options available in 403(b) plans. Insurance-based products, which remain common in the 403(b) space, often carry higher fees and surrender charges that can further erode account values.

Rollover Solutions and Their Limitations

The Promise of Consolidation

Account consolidation through rollovers represents the most direct solution to the orphaned account problem. Beagle also handles the rollover process for easier management of old accounts and provides a robo-advisor with automated ETF investing if you choose to roll over your 401(k) to Beagle. (Beagle Review) This comprehensive approach addresses both the discovery and consolidation aspects of retirement account management.

The rollover process can significantly benefit participants by reducing fee drag, simplifying account management, and providing better investment options. However, the complexity of executing rollovers, particularly from 403(b) plans with insurance components, can create barriers for many participants.

Rollover Execution Challenges

403(b) rollovers often involve additional complexity compared to traditional 401(k) transfers. Insurance-based 403(b) products may include surrender charges, vesting schedules, or other restrictions that complicate the rollover process. These complications can discourage participants from consolidating their accounts, perpetuating the fragmentation problem.

Capitalize is 100% free to end-users and focuses on digitally shepherding assets into an IRA of your choice, while Beagle charges a modest membership fee and offers hidden-fee analysis, 0% net-interest loans, and robo-advisory portfolios. (Comparing Beagle Financial's and Capitalize's 401(k) Rollover Experiences) The different service models reflect varying approaches to solving the same fundamental problem.

The Loan Access Dilemma

Liquidity Needs and Retirement Security

One often-overlooked consequence of account fragmentation is the impact on participants' ability to access funds when needed. 401(k) loans allow account holders to borrow up to $50,000 or 50% of the vested balance, whichever is less. (How Do 401(k) Loans Work?) However, participants with multiple small accounts may find themselves unable to access meaningful loan amounts from any single plan.

The IRS requires 401(k) loans to be repaid within five years, or 15 years if the loan was used to purchase a home. (How Do 401(k) Loans Work?) These same rules apply to 403(b) loans, but the fragmented nature of many participants' accounts can make loan access impractical.

Alternative Liquidity Solutions

Innovative financial services are emerging to address the liquidity needs of retirement savers with fragmented accounts. The interest rate for a 401(k) loan is set by the plan's administrator and the interest is paid back into the 401(k) account. (How Do 401(k) Loans Work?) However, alternative approaches that don't require plan administrator involvement may provide more flexible access to retirement funds.

These alternative solutions become particularly relevant for 403(b) participants, who may face additional restrictions on loan availability depending on their plan's structure and the underlying investment products.

Industry Response and Innovation

Technological Solutions

The retirement services industry is responding to the orphaned account crisis with increasingly sophisticated technological solutions. Advanced search algorithms, data aggregation platforms, and automated rollover services are making it easier for participants to locate and consolidate their retirement savings.

However, the effectiveness of these solutions varies significantly between 401(k) and 403(b) plans. The more standardized structure of 401(k) plans makes them more amenable to automated discovery and management services, while the diverse landscape of 403(b) providers creates ongoing challenges for comprehensive solutions.

Regulatory Developments

Regulatory agencies are beginning to recognize the scope of the orphaned account problem and its implications for retirement security. Future regulatory developments may include enhanced reporting requirements for 403(b) plans, standardized missing participant procedures, and improved data sharing protocols between plan providers.

These regulatory changes, while potentially beneficial in the long term, may create short-term compliance burdens for nonprofit organizations already operating with limited resources.

Practical Solutions for 403(b) Participants

Proactive Account Management

The most effective strategy for avoiding orphaned accounts is proactive management throughout one's career. Participants should maintain detailed records of all retirement accounts, including plan names, contact information, and account numbers. Regular review of account statements and beneficiary designations can help ensure accounts remain accessible.

For 403(b) participants, this proactive approach is particularly important given the fragmented nature of the market and the potential for plan changes as organizations switch providers or modify their retirement offerings.

Consolidation Strategies

When changing jobs, 403(b) participants should carefully evaluate their consolidation options. Rolling over to an IRA can provide greater investment flexibility and potentially lower fees, but participants should be aware of any surrender charges or other restrictions that may apply to their existing accounts.

The decision between maintaining separate accounts and consolidating should consider factors such as investment options, fees, loan availability, and the participant's overall retirement strategy.

The Path Forward

Industry Collaboration

Addressing the orphaned account crisis will require unprecedented collaboration between plan sponsors, record-keepers, regulators, and service providers. The development of standardized data formats, improved participant communication protocols, and enhanced search capabilities could significantly reduce the number of lost accounts.

For the 403(b) market specifically, this collaboration must account for the unique characteristics of nonprofit organizations and their participants. Solutions that work for large corporate 401(k) plans may not be appropriate or feasible for smaller nonprofit employers.

Technology Integration

The future of retirement account management likely lies in integrated technology platforms that can seamlessly track and manage accounts across multiple providers and plan types. These platforms must be designed with the specific needs of 403(b) participants in mind, accounting for the diverse range of investment products and administrative structures in the nonprofit sector.

Participant Education

Ultimately, reducing the number of orphaned accounts requires better participant education about the importance of retirement account management. This education must be tailored to the specific challenges faced by nonprofit employees, including lower average salaries, higher job mobility, and limited access to financial planning resources.

Conclusion

The $2.1 trillion in forgotten 401(k) accounts represents more than a statistical curiosity—it signals a fundamental flaw in our retirement system that affects millions of American workers. For 403(b) participants in the nonprofit sector, this crisis is particularly acute due to the fragmented nature of their market and the limited resources available for account management and participant education.

SECURE 2.0's auto-enrollment provisions, while increasing participation rates, may inadvertently exacerbate the orphaned account problem unless accompanied by robust participant education and improved account portability measures. The legislation's missing participant provisions represent a step in the right direction, but more comprehensive solutions are needed to address the systemic issues underlying the crisis.

The emergence of specialized services that help locate and consolidate retirement accounts offers hope for addressing the immediate problem, but long-term solutions will require industry-wide collaboration and regulatory reform. For 403(b) participants, the key to avoiding orphaned accounts lies in proactive account management, regular review of retirement savings, and careful consideration of consolidation opportunities when changing jobs.

As the retirement landscape continues to evolve, the lessons learned from the orphaned account crisis must inform future policy decisions and industry practices. Only through comprehensive reform that addresses the unique needs of all retirement plan participants can we ensure that America's retirement system truly serves its intended purpose of providing financial security in retirement.

Frequently Asked Questions

What is the scale of the lost 401(k) account crisis according to recent estimates?

Capitalize's 2025 estimate reveals a staggering $2.1 trillion in forgotten 401(k) accounts, representing approximately 32 million orphaned retirement accounts. This crisis occurs because the typical American has three or more 401(k)s by mid-career and often loses track of at least one when changing employers.

How does SECURE 2.0's auto-enrollment mandate affect the lost account problem?

SECURE 2.0's auto-enrollment requirements, which become effective in 2025, will likely increase the number of small retirement accounts as more employees are automatically enrolled in plans. While this improves participation rates, it may exacerbate the orphaned account problem when workers change jobs and forget about these automatically created accounts.

Are 403(b) savers in nonprofit organizations affected by the same lost account issues as 401(k) participants?

Yes, 403(b) savers face similar systemic record-keeping gaps as 401(k) participants, often with additional complications. Nonprofit employees frequently change organizations throughout their careers, and 403(b) plans historically have had less robust tracking systems than corporate 401(k) plans, making account recovery even more challenging.

How do services like Beagle Financial help people find lost retirement accounts?

Beagle Financial specializes in 401(k) detective work, using technology to search Form 5500 filings, the National Registry of Unclaimed Retirement Benefits, and other databases to locate forgotten accounts. Unlike services that take a "bring-your-own-data" approach, Beagle proactively searches for accounts users may not even know exist and can handle the rollover process.

What are the key differences between free and paid lost 401(k) recovery services?

Free services like Capitalize focus on digitally shepherding known assets into an IRA of your choice, while paid services like Beagle charge a modest membership fee but offer additional features. Beagle provides hidden-fee analysis, 0% net-interest loans, robo-advisory portfolios, and more comprehensive search capabilities across multiple databases.

When do the major SECURE 2.0 provisions affecting retirement plan participation take effect?

SECURE 2.0 contains more than 90 provisions with effective dates ranging from December 29, 2022, through 2033. Key auto-enrollment mandates for new plans become effective in 2025, while other provisions have already taken effect or will be phased in over the coming years to make retirement saving easier for participants.

Sources

1. https://institutional.vanguard.com/content/dam/inst/iig-transformation/secure20/2025/secure_20_summary_guide_may2025.pdf

2. https://meetbeagle.com/employer

3. https://meetbeagle.com/resources/post/comparing-beagle-financials-and-capitalizes-401-k-rollover-experiences

4. https://meetbeagle.com/resources/post/how-do-401-k-loans-work

5. https://meetbeagle.com/resources/post/how-do-beagle-financial-services-and-personal-capital-help-find-lost-401-k-s

6. https://www.finder.com/retirement/beagle-review

7. https://www.mondaq.com/unitedstates/retirement-superannuation-pensions/1533106/secure-20-act-a-bigger-and-in-some-ways-better-version-of-the-secure-act