diff --git a/JoshHeaps.Net/Content/Socialism/capital-accounts.md b/JoshHeaps.Net/Content/Socialism/capital-accounts.md
index 8449f18..15b4dec 100644
--- a/JoshHeaps.Net/Content/Socialism/capital-accounts.md
+++ b/JoshHeaps.Net/Content/Socialism/capital-accounts.md
@@ -36,7 +36,7 @@ Mondragon's original split was similar: 10% to education and the community, at l
 The members' share is then split again, between cash now and the account:
 
 - **At least 20% of it is paid in cash right away.** Members owe income tax on their whole allocation in the year it's made, including the part that goes into the account. The cash is there so they can pay that tax. This is how US co-op tax law works ([Democracy at Work Institute guide](https://institute.coop/sites/default/files/resources/Internal-Capital-Accounts.pdf)). The default is half in cash.
-- **Lower-income members can take it all in cash.** For a low-wage worker, being taxed on money they can't touch can cost them tax credits and health-care subsidies. So any member whose household income is under twice the poverty line can take their whole share in cash, or the standard split, with nothing in between, so nobody chooses how much to invest. They choose before the year starts, and one low year doesn't qualify. All cash is the default. Once the Labor Department has answered on pension law, those who take the standard split won't be taxed on the account part until it's paid out ([How a Locked Co-op Is Taxed](taxes.md#capital-accounts)).
+- **Lower-income members can take it all in cash.** For a low-wage worker, being taxed on money they can't touch can cost them tax credits and health-care subsidies. So any member whose household income is under twice the poverty line can take their whole share in cash, or the standard split, with nothing in between, so nobody chooses how much to invest. They choose before the year starts, and one low year doesn't qualify. All cash is the default, and like everyone they're signed up for a retirement plan outside the co-op ([below](#saving-for-retirement)). Once the Labor Department has answered on pension law, those who take the standard split won't be taxed on the account part until it's paid out ([How a Locked Co-op Is Taxed](taxes.md#capital-accounts)).
 - **The rest goes into each member's account.**
 
 Members can also raise their own salaries instead of taking profit, but that doesn't get around the reserve. It takes its share of pay above the going rate too (see [Investing for the Long Run](the-long-run.md#the-rules)).
@@ -87,12 +87,24 @@ A pension plan would break the account. Its money has to be held in a trust, apa
 - **The wait is short and the same for everyone,** at most seven years, not tied to age or retirement.
 - **Credits taxed later wait for the Labor Department.** Until the Department answers, co-ops don't offer them. Lower-income members choose between all cash, the default, and the standard split, taxed now ([How a Locked Co-op Is Taxed](taxes.md#credits-taxed-later-the-deferred-pay-rules)).
 - **Most of what's paid goes to people still working there.** The federation's software reports each year what share of a co-op's account payouts, in dollars, went to people who weren't working there, counting small balances and payments to heirs. It also reports the share paid to people at or near retirement age. If more than a third went to people who weren't working there, averaged over three years, the co-op shortens the wait for new credits to three years. If it's still over a third after that, it stops making new credits, and the members' share is paid in cash. A third is the model's own number, far looser than the 8% in *Milligan*, so the request to the Department asks where the line is. Stopping new credits doesn't change the status of old ones, which are still paid on schedule.
-- **The account isn't written or sold as deferred pay or retirement savings.** The bylaws describe it as members' capital under state co-op law. A co-op that wants to help members save for retirement does it the ordinary way, with a regular retirement plan held outside the business. Where accounts stop, the co-op signs members up for the federation's pooled retirement plan by default, paid from their own cash share if they don't opt out.
+- **The account isn't written or sold as deferred pay or retirement savings.** The bylaws describe it as members' capital under state co-op law. Retirement saving happens the ordinary way, in a separate plan held outside the business ([below](#saving-for-retirement)).
 - **The same rules apply everywhere.** Under ERISA a suit can be brought where the plan is run, where the breach took place, or wherever a defendant can be found ([29 U.S.C. 1132(e)(2)](https://www.law.cornell.edu/uscode/text/29/1132)). A former member who moves can take the case with them, so a rule based on where the co-op sits wouldn't protect it.
 - **The first pilot co-ops ask the Labor Department for an advisory opinion on their real bylaws, and the bank pays.** An opinion only covers the co-op that asked, on its own facts, so the bank also asks the Department for a rule any employer could use, for profit-sharing paid on a short fixed schedule. The Fourth Circuit held that the Department acted within its power to define the law's terms when it wrote its bonus rule ([29 U.S.C. 1135](https://www.law.cornell.edu/uscode/text/29/1135)). Other circuits don't have to agree. It doesn't ask Congress for an exemption only co-ops would get.
 
 **The cost is capital.** Money paid back after five years is money the co-op can't keep using for fifteen. So a co-op that wants to invest more has to keep more in its permanent reserve, and that weakens the model's answer to the horizon problem ([Investing for the Long Run](the-long-run.md#who-pays-for-an-investment-and-when)).
 
+### Saving for retirement
+
+Every co-op also offers an ordinary retirement plan, held outside the business, to everyone who works there, members or not. It's a normal benefit, not a replacement for the account. But it matters most for people who don't build savings in the co-op: members of co-ops that have stopped making credits, and lower-income members who take their share in cash. They're mostly the lowest-paid.
+
+- **A plan the federation doesn't run.** Employers that share "a common interest other than having adopted the plan" can't form their own pooled plan, and co-ops in one federation probably do ([29 U.S.C. 1002(43)](https://www.law.cornell.edu/uscode/text/29/1002)). So each co-op joins an open pooled 401(k) run by a provider registered with the Labor Department, which takes on most of the paperwork and legal duties. The federation compares providers and recommends one. No part of the federation, the bank or its software company is paid from plan money, and fees are a flat amount per person, published every year.
+- **Everyone is signed up, as the law requires.** A 401(k) plan started since 2023 has to sign up every eligible worker at 3% to 10% of pay, raised by a point a year to at least 10%, unless the worker chooses otherwise. For the first 90 days they can take their own contributions back ([26 U.S.C. 414A](https://www.law.cornell.edu/uscode/text/26/414A)). Co-ops under three years old or with ten or fewer workers are exempt but use the same rules. The default starts at 3%, and changing it or opting out takes one step. When one large company started signing new workers up automatically, 86% took part, against 37% before ([When People Don't Stay Long](high-turnover.md)).
+- **The co-op puts in 3% for everyone, not a match.** A match would come out of shared profit and go only to people who can afford to save, so members who opt out because they need the cash would pay for those who don't. Instead the co-op adds 3% of wages for every eligible worker, whether they save or not, and it's theirs at once. That's one of the law's standard "safe harbor" designs ([26 U.S.C. 401(k)(12)(C)](https://www.law.cornell.edu/uscode/text/26/401)). It also spares the co-op the yearly tests comparing what owners and other workers get, which matters because in a co-op with fewer than 20 members, each member holds more than 5% of the vote, and tax law may treat each one as an owner.
+- **The federal match.** From 2027, the Saver's Match adds 50% of up to $2,000 a year that a lower-income person saves for retirement, paid by the Treasury into a non-Roth account. It shrinks as income rises and is gone at $35,500 for a single filer, $53,250 for a head of household and $71,000 for a married couple, before inflation adjustments ([26 U.S.C. 6433](https://www.law.cornell.edu/uscode/text/26/6433)). It's paid the year after, only to people who file a tax return and claim it, so the co-op's [benefits check](taxes.md#benefits) includes help filing. Money taken out within about two years reduces it. The default is the ordinary pre-tax option. Many low-paid workers owe almost no income tax, so after-tax Roth savings would often suit them better, but the Treasury hasn't said yet whether Roth savings earn the match.
+- **No withdrawals or loans while working there.** SSI doesn't count a retirement fund as savings if the worker has to leave the job to get any of it ([SSA POMS SI 01120.210](https://secure.ssa.gov/poms.nsf/lnx/0501120210)). Hardship withdrawals or loans would probably make it count. So the plan allows neither, beyond the 90-day refund the law requires. Once someone leaves, their balance can be cashed out, so it counts for SSI then, and cashing out early costs a 10% tax penalty. A member on SSI can stop their own savings, though the co-op's 3% still goes in. Balances roll over directly to a new plan or retirement account unless the worker chooses otherwise.
+
+An example: a home care aide who heads a household and earns $30,000 saves 3%, or $900. The co-op adds $900, and the Treasury $450 the next year, so $2,250 goes into an account that nobody can take from her if the co-op fails. She's just under the income where the Treasury's match starts to shrink, so a raise or other household income would reduce it. The co-op's 3% is a cost, paid before any profit is shared, and in thin-margin work that's real money. But it counts as pay under the Medicaid rule for home care ([When People Don't Stay Long](high-turnover.md#when-medicaid-decides-how-much-goes-to-pay)), and it's within the 6% of pay that [the pay rule](the-long-run.md#the-rules) leaves alone.
+
 ### Are accounts securities?
 
 Securities law covers far more than stock. Its definition includes any "note," any "evidence of indebtedness," and any "participation in any profit-sharing agreement" ([15 U.S.C. 77b(a)(1)](https://www.law.cornell.edu/uscode/text/15/77b)). An account credit is a promise to pay a set amount, with interest, on a set date. If credits counted as securities, a co-op would need an exemption from registering them, and anything misleading it told members about them could be grounds for a lawsuit.
diff --git a/JoshHeaps.Net/Content/Socialism/high-turnover.md b/JoshHeaps.Net/Content/Socialism/high-turnover.md
index d654e64..ff3f39d 100644
--- a/JoshHeaps.Net/Content/Socialism/high-turnover.md
+++ b/JoshHeaps.Net/Content/Socialism/high-turnover.md
@@ -89,7 +89,7 @@ Some things make it less harsh than it sounds:
 
 - **The vote doesn't ramp.** A member who stays one year has the same vote as one who stays thirty.
 - **Time on the ramp adds up.** Someone who leaves and comes back within a few years picks up where they left off, and protected leave, like parental or medical leave, counts as time worked ([Worker Ownership](worker-ownership.md)). That matters in care work, where many workers, most of them women, step out for a while to care for their own families.
-- **Whatever they built goes with them.** A member's account keeps paying out on its normal schedule after they leave, and small balances are paid all at once ([Member Capital Accounts](capital-accounts.md#how-its-paid-out)). But where most payouts would go to people who've left, pension law makes accounts risky, so co-ops with turnover this high almost always pay the members' share all in cash instead, and sign members up for a retirement plan outside the business ([Member Capital Accounts](capital-accounts.md#why-not-pay-it-out-when-you-leave)).
+- **Whatever they built goes with them.** A member's account keeps paying out on its normal schedule after they leave, and small balances are paid all at once ([Member Capital Accounts](capital-accounts.md#how-its-paid-out)). But where most payouts would go to people who've left, pension law makes accounts risky, so co-ops with turnover this high almost always pay the members' share all in cash instead. Everyone is still signed up for an ordinary retirement plan outside the business, with the co-op adding 3% of wages and a federal match for low earners from 2027 ([Member Capital Accounts](capital-accounts.md#saving-for-retirement)).
 - **In care work, the profit is small anyway.** At home care's thin margins, a full share is worth a couple of thousand dollars a year, and a typical member's is less ([Member Capital Accounts](capital-accounts.md)). For these workers, most of what matters is pay, hours and a say in how the work is done.
 
 A co-op can choose the short end of the ramp. This page doesn't shorten it further, because the founding plan sets that range on purpose. A longer ramp was meant to let a co-op hire without every new member cutting into everyone else's share right away. Under tax law, it only does that if the co-op pays the difference as wages for years of service ([How a Locked Co-op Is Taxed](taxes.md#the-tenure-ramp)). Whether low-margin, high-turnover co-ops should be allowed a much shorter ramp is an open question ([Open Problems](open-problems.md)).
diff --git a/JoshHeaps.Net/Content/Socialism/open-problems.md b/JoshHeaps.Net/Content/Socialism/open-problems.md
index 2ba600b..9b7838b 100644
--- a/JoshHeaps.Net/Content/Socialism/open-problems.md
+++ b/JoshHeaps.Net/Content/Socialism/open-problems.md
@@ -13,7 +13,7 @@ An honest list of what the model hasn't solved yet, most dangerous first.
 
 2. **The horizon problem.** *(Mostly answered.)* Members near retirement have little reason to vote for investments whose payoff arrives after they leave. The evidence from France and Italy finds no underinvestment where co-ops must keep a reserve, and [Investing for the Long Run](the-long-run.md) closes the main routes around this model's reserve: pay above the going rate, sales of assets, development spending, high pay that turns into losses, and worn-out equipment still in use. A warning light shows when a co-op stops replacing its equipment, and big bets get an independent opinion before members vote. Still open: nothing forces a co-op to maintain what it has, a bad bet that fails after its backers leave falls on the people who came after, and it's unsettled whether 30% is enough and whether the account rate is right. Members' accounts now pay back within three to seven years ([Member Capital Accounts](capital-accounts.md#why-not-pay-it-out-when-you-leave)), so they help less with long-lived investments than accounts held until members leave. Letting members sell their places to incoming workers was rejected, because that is how the plywood co-ops ended up sold.
 
-3. **Members' savings sit inside their employer.** *(Partly answered.)* [Member capital accounts](capital-accounts.md) are capped at a year's pay, protected by a solvency test, and now insured by a pool the co-ops pay for ([Protecting Members' Savings](savings-guarantee.md)). It covers final wages, former members' payouts and a protected slice of current accounts. Premiums are now estimated from Europe's wage guarantee funds and US closure and default rates: at least 0.25% of payroll for final wages, and probably 2% to 3% a year of covered savings, which takes nearly all the interest on a protected slice. The reserve target is sized for a five-year wave of failures like 2008–2012, and cover for current members' savings waits until the pool has its own track record. Still open: the pool has no government backing, so a worse recession could outrun it; the estimates rest on rough data, not co-ops; the reserve takes about fifteen years to build; and it needs a federal charter to avoid fifty states' insurance laws. Also open: an account paid out when a member leaves would probably be a pension plan under federal law, which would forbid the co-op from using the money. So accounts now pay each year's credit back on a fixed schedule of three to seven years, whether or not the member has left. That's designed to stay outside pension law, but it isn't settled until the Labor Department answers, and federal appeals courts weigh programs like it differently. Because nobody loses their account for leaving, much of what's paid goes to people who've left, which weakens the case. So co-ops where more than a third of payouts go to people no longer working there shorten the wait, then stop making new credits, and credits taxed only when paid wait for the Department ([Member Capital Accounts](capital-accounts.md#why-not-pay-it-out-when-you-leave)). In high-turnover work, that almost always means no accounts, so the lowest-paid members lose the savings the model promises them. It gives up the trust, disclosure and fiduciary rules that pension law would bring, which the model only partly replaces, and it leaves the co-op less of its members' money to invest for the long run. State wage laws are a second risk: in some states, California likely among them, a credit in a member's account could count as wages, which can't be held back, charged with losses or paused. Co-ops in those states don't use accounts until the state changes its law ([Owners Are Still Workers](labor-law.md#is-the-profit-share-pay)), so members there build no savings in the co-op. A third: account credits look like the notes the Supreme Court has held to be securities, so the model keeps members from putting money in and asks the SEC for an answer ([Member Capital Accounts](capital-accounts.md#are-accounts-securities)). If the answer is no, the nearest exemption means calling credits pay, which works against the model's positions on tax, pension and wage law.
+3. **Members' savings sit inside their employer.** *(Partly answered.)* [Member capital accounts](capital-accounts.md) are capped at a year's pay, protected by a solvency test, and now insured by a pool the co-ops pay for ([Protecting Members' Savings](savings-guarantee.md)). It covers final wages, former members' payouts and a protected slice of current accounts. Premiums are now estimated from Europe's wage guarantee funds and US closure and default rates: at least 0.25% of payroll for final wages, and probably 2% to 3% a year of covered savings, which takes nearly all the interest on a protected slice. The reserve target is sized for a five-year wave of failures like 2008–2012, and cover for current members' savings waits until the pool has its own track record. Still open: the pool has no government backing, so a worse recession could outrun it; the estimates rest on rough data, not co-ops; the reserve takes about fifteen years to build; and it needs a federal charter to avoid fifty states' insurance laws. Also open: an account paid out when a member leaves would probably be a pension plan under federal law, which would forbid the co-op from using the money. So accounts now pay each year's credit back on a fixed schedule of three to seven years, whether or not the member has left. That's designed to stay outside pension law, but it isn't settled until the Labor Department answers, and federal appeals courts weigh programs like it differently. Because nobody loses their account for leaving, much of what's paid goes to people who've left, which weakens the case. So co-ops where more than a third of payouts go to people no longer working there shorten the wait, then stop making new credits, and credits taxed only when paid wait for the Department ([Member Capital Accounts](capital-accounts.md#why-not-pay-it-out-when-you-leave)). In high-turnover work, that almost always means no accounts, so the lowest-paid members lose the savings the model promises them. An ordinary retirement plan outside the business, with the co-op adding 3% of wages for everyone and, from 2027, a federal match for low earners, makes up part of that ([Member Capital Accounts](capital-accounts.md#saving-for-retirement)). It gives up the trust, disclosure and fiduciary rules that pension law would bring, which the model only partly replaces, and it leaves the co-op less of its members' money to invest for the long run. State wage laws are a second risk: in some states, California likely among them, a credit in a member's account could count as wages, which can't be held back, charged with losses or paused. Co-ops in those states don't use accounts until the state changes its law ([Owners Are Still Workers](labor-law.md#is-the-profit-share-pay)), so members there build no savings in the co-op. A third: account credits look like the notes the Supreme Court has held to be securities, so the model keeps members from putting money in and asks the SEC for an answer ([Member Capital Accounts](capital-accounts.md#are-accounts-securities)). If the answer is no, the nearest exemption means calling credits pay, which works against the model's positions on tax, pension and wage law.
 
 4. **Is the lock too rigid?** A co-op that should be sold (a better operator exists, the members want out) can only go to another co-op. If the co-op sector is small, that buyer pool is tiny, and viable firms may be liquidated instead of rescued. The federation as buyer of last resort is a partial answer. Critics on the right add a sharper version: a lock that outlasts a repaid loan by generations is a permanent restriction on selling property, bought with one loan, and it binds members who never agreed to it. The lock is now built to hold in layers, including an independent lock share and rules against selling the business piece by piece ([The Lock](the-lock.md#how-the-lock-is-made-to-hold)). Its biggest legal gap is bankruptcy: federal bankruptcy law generally overrides limits on selling a bankrupt company's property, so the lock only holds in bankruptcy if Congress amends that law. [When a Locked Co-op Goes Bankrupt](bankruptcy.md) drafts that amendment. It's modeled on how bankruptcy law already treats charities. Only co-ops can buy a failed co-op whole, its workers can keep it running and bid with the wages they're owed, and creditors who never chose to lend are paid the lock's cost from the federation fund. It still needs Congress, a later Congress can repeal it, and while the co-op sector is small, some viable businesses will be broken up for lack of a co-op buyer. Italy offers a softer model: a co-op there can convert into an ordinary company, but its accumulated reserves go to the co-op development fund, not to the members ([Has This Been Tried?](precedents.md#italys-co-op-funds-coopfond-and-the-marcora-law)). That would keep the part of the lock that stops members cashing out what earlier generations built, and drop the part that stops a firm from ever changing hands.