Only a few people paid any attention to Section 401(k) until the early 1980s. The old plan design it reauthorized had never been popular and wasn’t likely to become popular. But a few benefit plan experts recognized what everyone else, including Congress, seemed to have missed, that there was no material difference between promising an employee a retirement plan contribution that he or she could choose instead to receive in cash, and the converse, of promising the employee cash, but with the right to choose instead to have the employer make a retirement plan contribution to the employee’s account. The only difference was which one was the default option. These pioneering experts realized that, by flipping the default option from receiving a contribution to receiving cash, employees for the first time could in substance contribute to retirement plans on a pre-tax basis by making 401(k) contributions, contributions that technically are employer contributions.