Have any of you looked at the paper FAFSA form (for what you actually have to report), and the FAFSA calculations booklet (for how they figure the EFC)?
Retirement account balances are NOT included in assets. They are invisible to the FAFSA. Current year retirement contributions and pension contributions are added back to AGI, as well as nontaxed pension income.
The only imbalance I see is the scenario of parent A has a pension fully funded by the employer (no out of pocket) vs parent B contributes to a 401k with no employer match at all (saves everything themself). Are fully funded pensions common? I only know of teacher pensions, and they have to contribute.
It's a bit murky for me. I can't find a .pdf on the FAFSA website (
https://fafsa.ed.gov/index.htm) that would let you see how they use retirement savings and other assets to calculate need.
Here is what I pulled from simpletuition.com's website (
http://www.simpletuition.com/fafsa/the-calculations-behind-the-fafsa/)
"The first step in the EFC calculation is to determine what portion of the parents’ income is available to contribute to the costs of college. It includes total income but then subtracts taxes paid, child support and basic living expenses, and an employment allowance (basically a percentage of the income of the parent who earns less, or of the single parent’s income). This number is the available income. Then, parental assets are analyzed. The value of cash, savings, checking accounts, the net worth of a business or farm, and investment and real estate net worth (
excluding the family’s primary residence) are added together. From that total, specific savings for education and an asset protection allowance (a portion of assets dependent on structure of the family and the value of assets) are subtracted. A part of this total is used to determine the available contribution from assets.
"The needs analysis is based on a few principles. First, the parents have the primary responsibility for the cost of higher education. Second, the student is responsible for some contribution to educational costs. Third, families should only be evaluated in their present financial situation. And lastly, the family’s contribution should be determined consistently and equally for all families with children attending institutions of higher education."
Here's an interesting .pdf on the need calculation process:
http://r.search.yahoo.com/_ylt=A0LEVxPA1FNU8yoAz1xXNyoA;_ylu=X3oDMTByZDBpbXI5BHNlYwNzcgRwb3MDNQRjb2xvA2JmMQR2dGlkAw--/RV=2/RE=1414808897/RO=10/RU=http%3a%2f%2fwww.fafsaonline.com%2fprintable-fafsa-form%2fFAFSA-Help-Guide-ebook.pdf/RK=0/RS=zEF0X7S4Oxt.4eQYonWz5ucKlYw-P. 94: "Certain types of untaxed income are counted by the federal need-analysis formula
despite not being included in adjusted gross income.
These types of untaxed income include:
• Pre-tax contributions made by the taxpayer to qualified retirement plans,
including deductions for pension plans, 401(k) plans, 403(b) plans, SEP,
SIMPLE and deductible contributions to tax-deferred IRAs and Keogh plans
• Tax-free contributions to a Health Savings Account (HSA)23"
Here's a doozy on p. 96 "Contributions to a 401(k), 403(b) or IRA, on the other hand, are
voluntary and must be reported as untaxed income on the FAFSA....Note that employer contributions to retirement
plans, health benefits and pension plans are not counted in untaxed income."
pp 102-103: "Reportable and Non-Reportable Assets
Assets include any property that is owned and which can be bought and sold (i.e., an
asset has exchange value).
Examples of assets that are reported on the FAFSA include:
• Cash29
• Bank accounts, such as checking and savings accounts
• Certificates of Deposit (CDs)
• Brokerage accounts
• Stocks, bonds, mutual funds, money market accounts, stock options, restricted
stock units (vested portion only), ETFs, hedge funds, REITs, private equity and
other investments
• Commodities and precious metals
• Businesses and investment farms (including the value of land, buildings,
machinery, equipment and inventory)
• Real estate
_ Filing the FAFSA 104
TABLE OF CONTENTS
• Installment and land sale contracts (including mortgages held)
• Custodial accounts, including Uniform Gift to Minors Act (UGMA) and
Uniform Transfer to Minors Act (UTMA) accounts (if owner, not custodian)
• Trust funds
• College savings plans, including 529 College Savings Plans, Prepaid Tuition
Plans (value is the refund value of the plan) and Coverdell Education Savings
Accounts
The following assets are not reported on the FAFSA:
• The family’s principal place of residence (the family home)
• A family farm, if it is the family’s principal place of residence and the student
and/or parents materially participate in the farming operation
• Any small businesses owned and controlled by the family. Small business have
less than 100 full-time or full-time equivalent employees. To be controlled by
the family, the family must own more than 50 percent of the business. Note that
family members are not limited to just those counted in household size on the
FAFSA, but may include relatives by birth or marriage.
• Qualified retirement plans, such as 401(k) plans, 403(b) plans, pension plans,
annuities, traditional IRAs, Roth IRAs, Keogh, SEP and SIMPLE plans
• Life insurance policies, including cash value and whole life insurance policies
• Personal possessions, such as clothing, furniture, a car, computer equipment
and software, television and stereo equipment
• Property received by Native American students under the Per Capita Act, the
Distribution of Judgment Funds Act, the Alaska Native Claims Settlement Act
or the Maine Indian Claims Settlement Act
Note that while qualified retirement plans do not count as assets, distributions
from a retirement plan (including tax-free distributions) do count as income to
the beneficiary on the FAFSA. (The only exception is for amounts rolled over into
another retirement plan in the same tax year.) Tax-free contributions to a retirement
plan by the taxpayer (not the employer) also count as income. Note that retirement
plan contributions from the employer, such as an employer match of 401(k)
contributions, do not count as income. Likewise, insurance settlements from a life
insurance policy do count as income."
More fun on p. 103: "If retirement money is not held in a qualified retirement plan, it must be reported
as an asset on the FAFSA, even if the asset owner has already reached the normal
retirement age. The intent to use the money to pay for retirement is irrelevant, since
there are no legal restrictions on the use of the money.
If the parents sell their principal place of residence, the net proceeds of the sale
must be reported as an asset even if the parents intend to use the money to buy a
new home."
It seems as if the system is skewed to steer a 401K family's income away from retirement saving (and possibly deplete taxable investment assets that could be used for retirement security ) by forcing parents to pay for college tuition, fees, room and board, etc. while their ADULT children attend college without regard to the total amount they have saved for retirement and their (and their children's) "need" for parental retirement security.