A Pivô da Aposentadoria | Mercados Privados Entram em Planos DC dos EUA

Defined-contribution (DC) plans hold roughly $14.2 trillion in U.S. retirement assets. 401(k)s alone account for $10.1 trillion. For most of the past two decades, that pool of capital has been functionally walled off from private markets. A combination of fiduciary uncertainty, valuation complexity, fee-disclosure norms and daily-liquidity expectations kept private equity, private credit and other illiquid strategies off the typical participant menu.

That picture is now changing. The August 7, 2025 White House executive order directed the Department of Labor and the SEC to facilitate access to alternative assets within DC plans. On March 30, 2026, the DOL published a proposed regulation that gives plan fiduciaries a process-based safe harbor for selecting designated investment alternatives that contain private-market exposure. The comment period closes June 1, 2026, just days from now.

The proposed rule does not mandate inclusion of alternatives. It removes the most binding constraint on inclusion: fiduciary fear. It arrives at a moment when the supply side is unusually ready. Empower — the second-largest U.S. retirement-plan provider, with roughly 19 million participants — launched a private-markets program for DC plans in May 2025 with Apollo, Franklin Templeton, Goldman Sachs, Neuberger Berman, PIMCO, Partners Group and Sagard, and added Blackstone later in the year. The vehicles are collective investment trusts (CITs) engineered to embed inside target-date and other multi-asset options.

The wealth-channel parallel is already well underway. The wealth-focused evergreen universe sat at roughly $427 billion at year-end 2024 and is projected to exceed $1.1 trillion by 2029 at a compound rate above 20 percent. U.S. interval-fund AUM has grown from $2.8 billion to $96 billion over the past decade. BlackRock has estimated that a 10–20 percent reallocation from public to private markets across target-date vintages would add roughly 50 basis points of expected return. A 2 percent reallocation of DC assets to private markets would represent approximately $244 billion of new flow — more than the entire current wealth-channel evergreen base.

The Latin American parallel is also worth studying. Mexico’s AFOREs can allocate up to 30 percent to alternatives and now hold roughly $11 billion in CERPI structures. Chile’s 2025 pension reform replaces five risk-based multi-funds with ten target-date retirement funds from April 2027. Pension allocations to alternatives across Mexico and the Andean region rose from $46 billion in 2020 to more than $71 billion in 2023. The institutional channel in Latin America has already taught the industry several lessons the U.S. DC market will now need to absorb: how to price illiquidity inside a DC wrapper, how to value private assets on a cadence consistent with participant statements, and how to embed alternatives in default options without leaving participants exposed to redemption gates.

This paper examines the policy mechanics behind the U.S. shift, the supply-side response, the LatAm parallel, the operational frictions that remain, and what the convergence of institutional and DC retail capital implies for asset managers, wealth firms, the U.S. Offshore channel and platform infrastructure over the next three to five years.

The U.S. DC Pivot: Policy Mechanics

The August 7, 2025 executive order set a new policy direction: removing the legal headwinds that had kept alternative assets out of participant-directed retirement plans. On August 12, 2025, the DOL rescinded a 2021 supplemental letter from the prior administration that had narrowed the practical feasibility of alternative-asset inclusion in retirement accounts. The March 30, 2026 proposed rule then operationalized the executive order: it does not require plan sponsors to include alternative assets in their lineups, but it provides a process-based safe harbor for those that do.

The safe harbor identifies six factors that a fiduciary must “objectively, thoroughly, and analytically” consider when selecting a designated investment alternative that contains alternative-asset exposure: performance, fees, liquidity, valuation, performance benchmarks and complexity. The framing matters. Earlier guidance had treated alternative investments inside DC plans as either prohibited as a practical matter or so legally fraught that no rational fiduciary would offer them. The proposed rule reverses both presumptions and replaces them with a documentable selection process.

The vehicle of choice is the diversified pool — most commonly a CIT embedded within a target-date fund, balanced fund or other multi-asset designated investment alternative. Direct participant-level access to a single private-equity or private-credit fund is not the target of the rule and would face the same valuation, liquidity and fee challenges that have historically kept private assets off DC menus. The realistic distribution path is institutional in form: blended sleeves of private equity, private credit, real estate and infrastructure, packaged into multi-asset wrappers and selected by professional fiduciaries on behalf of participants.

The comment period closes June 1, 2026. Industry groups have already requested additional clarification on valuation cadence, fee benchmarking, secondary-market liquidity expectations and the interaction between the safe harbor and existing ERISA fiduciary case law. A final rule, even on an accelerated timeline, is unlikely before late 2026 or 2027. The behavioral shift, however, is already underway. Plan sponsors that had treated alternatives as untouchable are now treating them as a 12- to 24-month decision.

The Supply Side Is Already Built

A common misreading of the executive order and proposed rule is that the supply infrastructure must now be built from scratch. It largely already exists.

The Empower program

On May 14, 2025, Empower — which serves roughly 19 million U.S. retirement-plan participants — announced a private-markets program for DC plans in partnership with Apollo, Franklin Templeton, Goldman Sachs, Neuberger Berman, PIMCO, Partners Group and Sagard. Blackstone joined later in the year. The vehicles are CITs with limited, diversified exposure to private equity, private credit and private real estate. The program is explicitly designed to dovetail with existing target-date funds and managed-account options rather than appear as a standalone participant-directed brokerage option. Five employers signed on in 2025 and adoption has continued.

CIT-wrapped private-market strategies

The collective investment trust is the workhorse of institutional DC investing. Its tax treatment, fee transparency and fiduciary-friendly governance have made it the dominant vehicle for target-date and stable-value strategies. Adapting it to hold private-market exposure has been the central engineering project of the last 24 months for the largest asset managers. The first generation of “DC-ready” private-markets CITs is deliberately conservative: 5 to 15 percent private-asset allocations inside a target-date sleeve, daily liquidity at the plan level, monthly or quarterly valuations on the private side, and a cash buffer to absorb participant cash flow.

The evergreen ecosystem

The wealth-channel evergreen market has matured into a roughly $427 billion universe at year-end 2024, projected to surpass $1.1 trillion by 2029 at a CAGR above 20 percent. The same wrapper technology — perpetual structures, defined liquidity windows, daily or monthly NAV, diversified asset pools — translates directly into the DC context. Hamilton Lane has forecast that evergreens will hold roughly 20 percent of all private-markets capital within a decade. MSCI has reported that wealth investors already represent about one-fifth of evergreen AUM.

Target-date funds as the on-ramp

BlackRock estimates that a 10 to 20 percent reallocation from public to private markets, blended across private equity and private credit, would add approximately 50 basis points of expected return averaged across target-date vintages. That is the central economic claim driving the DC pivot: the return uplift from a measured private-markets allocation is meaningful at the participant level and material at scale. A 2 percent private-markets reallocation across the $12.2 trillion DC asset base would represent roughly $244 billion of new capital — more than the entire current wealth-channel evergreen universe.

The Latin American Parallel

The United States is not running this experiment first. Latin American defined-contribution pension systems have been allocating to alternatives at meaningful scale for more than a decade, and the lessons learned in Santiago, Mexico City, Lima and Bogotá are now directly relevant to plan sponsors in Chicago and Atlanta.

Mexico — AFOREs

Mexico’s mandatory DC pension system permits AFOREs to allocate up to 30 percent to alternative investments. Combined assets reached roughly 7.5 trillion pesos (approximately $409 billion) by mid-2025. Foreign private-equity exposure is primarily channeled through CERPIs — locally listed certificates structured to comply with Mexican regulatory requirements. There are now 28 CERPIs in the market totaling approximately $11 billion, representing 4.8 percent of total AFORE AUM. The Mexican model has been studied closely by U.S. fiduciaries because it has solved several practical questions: how to value private assets on a cadence consistent with participant statements, how to maintain liquidity reserves to handle participant transfers between funds, and how to disclose layered fees inside a DC wrapper without overwhelming participants.

Chile — AFPs in Transition

Chile’s August 2025 pension reform restructures the system around a mixed contributory model and, beginning April 2027, replaces the existing five risk-based multi-funds with ten target-date retirement funds. The reform is one of the most significant institutional pivots in the region: a DC system that effectively pioneered the AFP model 40 years ago is moving to a target-date architecture explicitly designed to embed alternatives at the default-option level. For global GPs, Chile remains one of the most disciplined and longest-standing institutional buyers of private equity, private debt and infrastructure in the region.

The Andean and Regional Picture

Pension allocations to alternatives across Mexico and the Andes rose from $46 billion in 2020 to more than $71 billion in 2023. Cerulli has documented a parallel surge in alternative-investment demand in the wealth channel: wealthy individuals in Latin America placed at least $1 billion into alternative products through U.S. Offshore-based wealth managers in 2023, with that figure expected to roughly double in 2024. Demand has been concentrated in private equity, private credit and real estate, distributed via Reg S feeders, UCITS structures, structured notes and locally registered certificates.

For the U.S. Offshore advisor and the Latin American local advisor, the institutional pivot has a direct distribution implication. Latin American institutional capital has been an early and credible buyer of evergreen and semi-liquid private-market strategies. The same wrapper innovations that enabled AFORE and AFP access — feeder structures, locally listed certificates, FX-hedged share classes, custodian integrations — are now the same wrappers being adapted for U.S. DC plans. Asset managers who built distribution into LatAm institutional channels over the last decade have, often without realizing it, prebuilt much of the operational infrastructure that the U.S. DC pivot will require.

Onde a Fricção Ainda Vive

The structural shift is real. The operational friction is real too.

Valuation cadence

DC plans have historically run on daily NAVs. Private-market assets are typically valued monthly or quarterly. Bridging that gap requires either embedding private exposure inside a diversified pool that smooths the valuation cycle, or accepting a slower valuation cadence at the participant level. Neither solution is fully resolved. Mexico’s AFORE experience suggests that a hybrid model — monthly private-asset valuations rolled into daily fund NAVs through an internal pricing committee — is workable, but only at scale and with substantial governance overhead.

Liquidity at the participant level

A participant who reallocates between funds expects same-day execution. A private-asset pool can deliver that only by holding substantial liquidity buffers, maintaining committed credit lines, or relying on incoming subscriptions to fund outgoing redemptions. The first compresses returns. The second adds counterparty risk. The third assumes flows that may not materialize when needed. Recent redemption-cap episodes in semi-liquid private-credit vehicles — and the parallel offshore episodes in LatAm-distributed private-debt funds — are a reminder that this engineering still has limits.

Fee disclosure and benchmarking

DC fee-disclosure regimes were built around mutual-fund expense ratios. Private-market vehicles carry management fees, incentive fees, and a complex web of fund-level expenses. Translating those into participant-level disclosures that are both honest and intelligible remains a work in progress. The proposed rule explicitly requires fiduciaries to consider fees and performance benchmarks but leaves operationalization to plan sponsors and their consultants.

Litigation risk

The proposed safe harbor is process-based. It reduces but does not eliminate fiduciary exposure. Plan-sponsor litigation in the United States — particularly excessive-fee class actions — has historically been the single largest behavioral constraint on DC innovation. Until a final rule is in place and a body of safe-harbor case law begins to develop, many plan sponsors will adopt a watch-and-wait posture even where the strategic case for alternatives is strong.

Education and conviction

Survey work in the wealth channel has consistently found a conviction gap: roughly 96 percent of advisors say alternatives provide client value, yet only about half describe themselves as confident in implementation. The DC channel is likely to face a parallel gap. Plan sponsors, consultants and recordkeepers are not yet uniformly fluent in private-market structuring, and most participant communication infrastructure is built around public-market product taxonomy. The training and content investments required to close that gap are non-trivial, and the firms that have already made them in the wealth channel hold a substantial head start.

A Snapshot of the Shift

The table below summarizes how the U.S. DC pivot and the Latin American pension parallel line up across the dimensions most relevant to distribution and platform strategy.

Implications for Asset Managers, Wealth Firms and Platforms

For asset managers

The DC pivot expands the total addressable market for private-markets strategies by an order of magnitude. The binding constraint is no longer fundraising. It is operational readiness. The managers winning DC mandates today are those who arrived with CIT-wrapped strategies, daily plan-level liquidity arrangements, integrated valuation pipelines, transparent fee architecture and credible recordkeeping integrations. Managers without those capabilities — even with strong underlying investment performance — are being passed over. The parallel for LatAm distribution is exact: locally registered feeders, FX-hedged share classes, custodian integration and platform compliance are the price of admission. Building once for institutional LatAm and reusing for U.S. DC has become one of the most efficient distribution theses in the industry.

Para empresas de investimento

The DC pivot is not a competitor to the wealth channel. It is an extension of the same trend: private markets being repackaged into wrappers that meet the operational requirements of broader investor populations. Wealth firms that have already built advisor education, model-portfolio integration and household-level reporting around private markets are precisely the firms best positioned to advise plan sponsors, family offices and high-net-worth participants on how to think about a private-markets allocation that now spans the full balance sheet — DC, IRA, taxable and offshore. The advisor’s role is shifting from access provider to allocation coach across wrappers.

For platforms and fintech infrastructure

The DC pivot increases the volume and the operational stringency of private-markets distribution. Subscription-document automation, valuation reconciliation, model-portfolio embedding, household-level reporting and tokenized feeder structures all become more important, not less. Wrappers designed to bridge institutional-grade strategies and broader investor wrappers — including private ETN-style instruments and CIT-wrapped semi-liquid structures — are increasingly relevant infrastructure for asset managers serving DC, wealth and offshore channels simultaneously. The platforms that succeed will be the ones whose plumbing serves all three.

For the U.S. Offshore channel

The U.S. Offshore advisor sits at the intersection of two pivots: U.S. DC plans opening to private markets, and Latin American pension and wealth systems continuing to deepen their alternative-investment allocations. The two trends share wrapper architecture, GP relationships and operational infrastructure. An Offshore advisor who is conversant in CIT mechanics, target-date construction and AFORE / CERPI structuring will be materially more valuable to a cross-border client than one who treats DC and pension as separate worlds. Multi-family offices and private banks serving Latin American families increasingly need to think about U.S. retirement-account allocations for U.S.-resident family members alongside offshore portfolio construction, and the convergence of wrappers across jurisdictions is going to be a defining theme of the next five years.

Conclusão: The Pool Just Got Bigger

For most of the past quarter century, private markets have grown by expanding into the institutional pool — public pension plans, sovereign wealth funds, endowments and foundations. That pool is now largely allocated. The next decade of growth depends on accessing capital that, until recently, was structurally closed: U.S. DC plans, individual retirement accounts, mass-affluent wealth channels and the analogous segments in Latin America and Europe.

The DOL’s proposed safe harbor will not, on its own, redirect trillions of dollars overnight. What it does is remove the binding constraint that has kept the U.S. DC market on the sidelines. The supply side is built. The wrapper technology is mature. The Latin American institutional channel has run a version of this playbook for a decade and has lessons to share. The wealth-channel evergreen market is already absorbing many of the same operational requirements DC will need.

The next three to five years will determine which asset managers, wealth firms and platforms have built the right infrastructure to absorb capital from a market that has just opened. As with the alternatives crossover that defined the wealth channel over the last five years, access will not be the differentiator. Execution will be.

Antecedentes e Leitura Adicional

• U.S. Department of Labor, Notice of Proposed Rulemaking on Designated Investment Alternatives Containing Alternative Assets (March 30, 2026); comment period closes June 1, 2026.
• Executive Order on Democratizing Access to Alternative Assets for 401(k) Investors (August 7, 2025); DOL rescission of 2021 supplemental letter (August 12, 2025).
• Investment Company Institute, Quarterly Retirement Market Data, Fourth Quarter 2025.
• Empower, press releases on Private Markets Investment Partnership Program (May 14, 2025; subsequent partnership additions through 2025–2026).
• BlackRock, Private Markets in Target Date Funds (2025).
• Hamilton Lane, Evergreen Market Outlook (2025).
• MSCI, “The Ascendance and Implications of Evergreen Funds in Private Markets” (2026).
• PitchBook, Evergreen Fund Forecast (2024–2029).
• Cerulli Associates, “Demand for Alternative Investments Rises in Latin America and U.S. Offshore Market” (2025), Latin American Distribution Dynamics.
• Bloomberg, “Mexico’s Pension Giants Eye Private Equity, Alternative Markets” (November 2025).
• SURA Asset Management, Pension Superintendence assessment of alternative-asset investment progress (2025).
• Lockton, “Chile Introduces Major Changes to Its Pension System” (2025).
• Morgan Lewis, Kirkland & Ellis, Morrison Foerster, Gibson Dunn, Arnold & Porter and Seyfarth Shaw legal alerts on the DOL proposed rule (March–April 2026).
• Private Equity International, “How Private Equity Could Reshape Latin America” (2025).