The Good News: Most Retirement Funds Are Safe
Retirement accounts are among the most protected assets in bankruptcy. Congress and the courts have consistently held that people should not be forced to deplete their retirement savings to pay current debts. The protections come from multiple sources:
- ERISA (Employee Retirement Income Security Act) -- provides blanket federal protection for employer-sponsored plans
- Section 522(b)(3)(C) -- exempts retirement funds in tax-exempt accounts regardless of state opt-out
- Section 522(d)(12) -- the federal bankruptcy exemption for retirement funds (in non-opt-out states)
- Section 522(n) -- sets the IRA-specific cap at $1,512,350
The practical result: in almost every case, your 401(k), pension, and IRA are completely safe from creditors and trustees in bankruptcy.
Protection by Account Type
| Account Type | Protection Level | Dollar Limit | Source of Protection |
|---|---|---|---|
| 401(k) | Fully exempt | Unlimited | ERISA + 522(b)(3)(C) |
| 403(b) | Fully exempt | Unlimited | ERISA + 522(b)(3)(C) |
| Defined-benefit pension | Fully exempt | Unlimited | ERISA + 522(b)(3)(C) |
| 457(b) (government) | Fully exempt | Unlimited | 522(b)(3)(C) |
| Traditional IRA | Exempt with cap | $1,512,350 | 522(b)(3)(C) + 522(n) |
| Roth IRA | Exempt with cap | $1,512,350 | 522(b)(3)(C) + 522(n) |
| SEP IRA | Fully exempt | Unlimited | ERISA (employer contributions) |
| SIMPLE IRA | Fully exempt | Unlimited | ERISA (employer contributions) |
| Inherited IRA | NOT exempt | $0 | Clark v. Rameker (2014) |
ERISA Plans: Bulletproof Protection
Employer-sponsored retirement plans governed by ERISA -- including 401(k)s, 403(b)s, and defined-benefit pensions -- have the strongest protection. Under ERISA's anti-alienation provision (29 U.S.C. Section 1056(d)), these funds cannot be assigned or alienated. The Supreme Court confirmed in Patterson v. Shumate (1992) that ERISA-qualified plans are excluded from the bankruptcy estate entirely.
This protection is unlimited -- there is no dollar cap. A debtor with $5 million in a 401(k) keeps all of it. And because the protection comes from ERISA (a federal law outside the Bankruptcy Code), it applies in every state, including opt-out states.
Key point: ERISA protection means your 401(k) and pension are safe regardless of which state you live in, regardless of whether your state has opted out of federal bankruptcy exemptions, and regardless of the balance.
IRAs: The $1,512,350 Cap
Traditional and Roth IRAs do not have ERISA protection (because they are not employer-sponsored). Instead, they are protected under Section 522(b)(3)(C) and 522(d)(12), with a cap set by Section 522(n).
The current cap is $1,512,350 for all combined IRA balances (traditional plus Roth). This cap is adjusted every three years for inflation. For most people, this is more than sufficient -- the median IRA balance is well under $100,000.
Important: the cap applies only to amounts that are "retirement funds" within the meaning of the statute. Rollovers from ERISA plans into IRAs are generally protected without limit, because they originated as ERISA-protected funds. Courts in most circuits hold that the IRA cap does not apply to rollover amounts.
The Inherited IRA Trap
In Clark v. Rameker (2014), the Supreme Court unanimously held that inherited IRAs are not "retirement funds" within the meaning of the Bankruptcy Code. The reasoning: inherited IRA holders cannot contribute to the account, must take required distributions regardless of age, and can withdraw the entire balance at any time without penalty. These features make inherited IRAs more like a general savings account than a retirement vehicle.
This means: If you inherited an IRA from a parent, sibling, or anyone other than your spouse, that money is NOT protected in bankruptcy. The trustee can seize it to pay your creditors.
Exception: Spousal inherited IRAs are treated differently. A surviving spouse can roll an inherited IRA into their own IRA, which restores full protection. This rollover option is not available to non-spouse beneficiaries.
Common Mistakes to Avoid
- Do not withdraw retirement funds to pay debts before filing. The money is protected inside the account but becomes unprotected (and may not be exempt) once withdrawn. Cashing out a 401(k) to pay credit card debt before filing bankruptcy means you lose both the retirement savings and the debt relief.
- Do not borrow against your 401(k) to pay debts before filing. The loan repayment comes from your paycheck, reducing your disposable income. The original debt would have been discharged in bankruptcy.
- Disclose all retirement accounts. Failing to list a retirement account on your bankruptcy schedules is grounds for denial of discharge. The accounts are exempt -- there is no reason to hide them.
- Watch for IRA contributions made to defraud creditors. If you move large sums into an IRA shortly before filing specifically to shield them from creditors, the trustee may challenge those contributions as fraudulent transfers.
Legal References
- 11 U.S.C. Section 522(b)(3)(C) -- Retirement fund exemption
- 11 U.S.C. Section 522(d)(12) -- Federal retirement exemption
- 11 U.S.C. Section 522(n) -- IRA exemption cap
- 29 U.S.C. Section 1056(d) -- ERISA anti-alienation
- Patterson v. Shumate, 504 U.S. 753 (1992) -- ERISA plans excluded from estate
- Clark v. Rameker, 573 U.S. 122 (2014) -- Inherited IRAs not exempt
- 1328f.com -- Free discharge eligibility screening tool