The Internal Revenue Service (IRS) has amended the two safe harbor explanations that can be used to satisfy the requirement that certain information be provided to recipients of eligible retirement plan rollover distributions.
The amendments and model notices are issued following the
IRS’ new guidance
for allocating pre-tax and after-tax amounts among distributions that
are made to multiple destinations from a qualified plan. The amendments to the
safe harbor explanations and attached model notices may be used for plans that
apply the guidance in section III of Notice 2014-54 with respect to the
allocation of pre-tax and after-tax amounts.
Amendments to the safe harbor explanations also address in-plan Roth rollovers and
certain other clarifications to the two safe harbor explanations.
Changing Jobs Can Be Hard on Millennial Retirement Balances
Millennials
change jobs more frequently, giving them more opportunities to cash out of
their 401(k) plans and cut into future retirement savings, says Spencer
Williams of Retirement Clearinghouse.
This demographic, ages 24 to 32, is looking for more
meaningful work, according to Williams, chief executive officer of Retirement
Clearinghouse, in Charlotte, North Carolina, which is part of the issue. While
previous generations came out of college with a clearer sense of where they
could build a career, Millennials change jobs a little more frequently while
they search for the right career path.
At the same time, the steadily increasing adoption of auto
enrollment in 401(k) plans means that by the time they are 30, they might have
been auto-enrolled in three accounts. “Three small account balances is not a
good thing,” Williams tells PLANADVISER. The problem is that each small account
(on average, the balance is $3,000) is like waving free money in front of the
Millennial plan participant.
Cash-outs of course are not unique to Millennials, points
out Warren Cormier, founder and president of Boston Research Group. They behave
similarly to other age groups. “The reason they have a particular problem with
hyperbolic discounting is that even if they change jobs because they want to,
they’re into a loss aversion,” he tells PLANADVISER. This means that the loss
of the job carries much more of a psychological impact than any potential
future gains.
When several thousand dollars is suddenly in front of them
at the time of this job loss, the emotional tendency is to reach for the cash
to offset the loss a plan participant has experienced, Cormier says.
Williams says that Millennials should be stopped from using
hyperbolic discounting to minimize the importance of this sum. Hyperbolic
discounting refers to the tendency for people to increasingly choose a smaller-sooner
reward over a larger-later reward as the delay occurs sooner rather than later
in time. The hyperbolic discount is a term used in behavioral finance to
explain how people view money or rewards: the tendency is to choose a smaller
reward that comes sooner over a larger one that takes place in the future.
In
other words, a small account balance that is immediately accessible is seen as
more desirable or more attainable than one that will be available decades in
the future, at retirement. Younger plan participants tend to see retirement as
an event so distant that it may hold little meaning.
Williams says the word “incubation” resonates with some
people. “What you’re trying to do is incubate the accounts,” he explains. Plan
sponsors and advisers should aim to give Millennials information about the
consequences of cashing out at the time of the job change, admittedly a
difficult time to get their attention.
Cashing out of the plan is about the worst thing Millennials
can do, Williams says. Second-worst is leaving a small balance in the previous
employer’s plan, because the money is still at risk of being cashed out. “By
far, 70% of the cash-outs happen within 180 days of someone changing jobs, but
there is a delayed effect,” he says. “If the money is not consolidated in a new
plan, it’s still at risk.” After the initial period, about 25% of cash-outs
occur in months seven through 18 (5% of cash-outs take place at random).
According to Williams, at the end of a first job, a
Millenial’s account balance is likely in the range of $3,000 to $6,000,
assuming three years on the job with a 3% deferral rate matched at 3%. This
amount could more than double after another three years if it is
consolidated and put it into the new employer’s plan, he says, assuming continued
contributions, matches by the new employer, some market growth and perhaps a
raise.
“We know there is a cash-out curve,” Williams says, with
small amounts most likely to be cashed out and large amounts the least likely.
“At $20,000, the cash-out rate drops in about half,” he says.
Using a two-punch approach, Williams explains that the first
punch is asking Millennials to assess how much the cash-out will cost them.
“Your $5,000 is really [worth] $3,000, because you’re going to pay taxes and
penalties,” he explains. “Second punch,” he says, “is that the $5,000 is really
$50,000 at retirement. For Millennials, those numbers really stand up to that
age group [because of their investing time horizon].”
Using
a trick of behavioral finance, Williams says that using a multiple of
10—equating $5,000 to a future $50,000—creates an aha! moment
for people contemplating a cash-out. “We stop them from discounting the value
of that $3,000,” he explains.
Unfortunately, the most effective way to break through the
tendency to make emotional decisions is also the most expensive, Cormier feels:
Direct intervention. “Put them in front of a live counselor or set them up with
a phone interview,” he recommends. “That is more labor intensive. But if you
leave it to rules of thumb or sending a paper document, it has less of an
impact.”
Adopting a point of view that wants to prevent cash-outs can
benefit everyone, Williams says. Plan sponsors might want to consider asking
how many new hires come to them with an account balance of zero? Usually, the
answer is 100%, he says. Wouldn’t plan sponsors be better off participating in
a system where new hires came with $5,000 to place in the plan? “Plan sponsors
get that in a New York second,” he says. It is to their benefit for separating
employees to roll over their small-account balances into a new plan. “The
balances are static, and the former employees are not going to tell you when they move.”
Williams feels that everybody loses in a cash-out: The
participant, the plan sponsor, the future plan sponsor and even the plan
itself, he contends. “We are involved in missionary work to help plan sponsors
understand that retaining those small balances in their accounts is a problem,”
he says. “A $5,000 balance is really not what they’re building those plans
for.”
Plan
sponsors that proactively help their separating employees roll over assets into
a new plan can participate in a system that benefits everyone, Williams says.
“It’s a win all the way around.”