Data & Research May 9, 2014

Provider Websites Face Off in Corporate Insight Report

Whether their plan is soliciting requests for proposals (RFPs) or not, plan officials have the fiduciary duty to understand how their service providers’ Web offerings match the competitions’.
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A new report from financial intelligence and consulting firm Corporate Insight suggests the plan sponsor’s duty to analyze their participants’ online experience is critically important in the modern defined contribution (DC) retirement planning context. The report argues that shortcomings in participant websites should be a compelling case for switching service providers or demanding more from existing provider relationships, especially as younger generations of participants expect more of the 401(k) account management experience to be delivered online.

Drew Maresca, a senior analyst at Corporate Insight who helped develop the report, “Engaging Participants: Best Practices for Plan Sponsors,” tells PLANADVISER the competitive landscape among DC service providers has become vastly more complex in recent years. Not only have the various data tools and transaction resources offered online to participants become more sophisticated—there has also been a move among the leading providers to make web-based processes simpler and accessible across a variety of electronic devices. 

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This has resulted in a new set of best practices that plan officials must consider when analyzing participant web offerings, he says, adding that sponsors are often surprised to how their web offerings differ from other plans with similar size and expense characteristics.

Maresca describes a good participant website as one that features powerful income calculators, data visualization tools and a full-service account management platform through which participants can easily initiate change in their savings rates and investment portfolio. It’s also important, he says, for this information to be presented with compelling education materials and next-best-step education that can guide participants through actual financial planning decisions, such as when to start drawing Social Security or what asset allocation is best.

“One distinguishing feature of the top websites is the convenience factor,” he says. “It’s becoming more important to make interacting with your plan easier and to make the participant’s financial lives simpler to manage, whether online or through in-person meetings. The data shows convenience online can lead to better outcomes.”

Corporate Insight has been auditing DC service provider websites since 2006, Maresca explains, and refocused the effort in 2012 with the launch of the Retirement Plan Monitor, which tracks the online participant experiences offered by 17 large DC plan service providers.

“In that time we’ve seen that the digital experience of participants varies greatly depending on the capabilities of the provider, so much so that it leads to vastly dissimilar participant experiences in plans that would otherwise look a lot alike,” he says. “Even in our list of the largest DC providers, we see a lot of disparity in the online offerings. Some do much better than others, to be frank.”

There are websites that are very communicative and go the extra mile in terms of online training and supporting investors at all levels, especially the novice investors, Maresca says. Other sites just present the bare-bones information, the account balance and the investment options without teaching the participant about how to set savings goals or how to optimize investment performance based off personalized age, health, wealth and salary considerations. These are the features sponsors should be demanding, Maresca explains.

For guidance on assessing current and prospective web offerings, Maresca says sponsors and consulting resources should ask themselves, “Does our website promote or hinder participant engagement?” There will always be a wide spectrum of persons with varying degrees of financial acumen and interest within a given plan, he says, so answering this question won’t be easy without solid plan demographic data and a good understanding of the goals and aspirations of participants.

Additionally, plan officials must consider ease of use and whether their website promotes holistic financial wellness. Both are important characteristics that a DC plan’s participant website must have in order to improve outcomes, he says. Participants should be able to take corrective action easily, if necessary. Presenting retirement scenarios in a graphical way is another best practice to engage participants, he says.

Maresca pushes back against the notion that robust web resources may be prohibitively expensive to develop and maintain among smaller plans or those with few extra resources.

“I think both low fees and powerful web resources can be a part of the same plan,” Maresca says. “There is no reason why you can’t work with your service provider to at least explore the steps it would take to streamline and improve the web offerings. I don’t think it’s as challenging as one might expect to start moving in the right direction.”

A summary of the report, as well as information on how to purchase the full results, is available here.

Compliance May 9, 2014

Do You Recommend a Fee Policy Statement?

Fee policy statements are in the early stages, but they can help plan sponsors manage fees and help an adviser show he’s ahead of the curve.
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“We include a fee policy statement with all the plans we work with,” says James Holland, director of business development, MillenniuM Investment and Retirement Advisors LLC. Holland tells PLANADVISER that 408(b)(2) regulations brought the importance of fee disclosure to the forefront. Formal fee monitoring, however, dates to the beginning of the Employee Retirement Income Security Act (ERISA). Holland says the firm makes clear to partners throughout their network of 500 advisers that this is an essential building block to a healthy plan.

The Department of Labor (DOL) does not specifically require a plan to include such a document, but, Holland says, “I would argue they already have. They didn’t say put a fee policy statement in place, but ERISA says you have to have some sort of written guideline that shows you’re monitoring plan fees. You don’t have to call it that, but you have to have it.” Since ERISA was initiated, he says, the documentation and the idea have been a part of a workplace retirement plan, and they are an important piece.

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“You need some kind of guideline in place to show that you’re documenting,” Holland says. The fee policy statement is a linchpin that ensures a plan sponsor can prove that the firm is looking at all the providers who touch the plan. It can be used to show that the services are necessary, and the fees are reasonable, he says.

The scope of the document could be as simple as a statement that sets forth general guidelines for plan fiduciaries to evaluate and review plan fees, says Sarah Downie, a partner with the law firm Hughes Hubbard & Reed LLP. 

Aid to Compliance

Downie agrees that the statement, in its simplest form, can help a plan sponsor comply with ERISA as well as the fee disclosure regulations. “Or it may be a more elaborate document that helps plan fiduciaries better understand fee allocation among participants and service providers, as well as guidelines for evaluation of fees,” she tells PLANADVISER.

Downie recommends that plan sponsors consider adopting a fee policy statement, but cautions that plan fiduciaries should take care to make sure the document does not impose overly rigid or easily breached standards on plan fiduciaries. Downie says that one potential risk in a poorly constructed policy statement is that the plan fiduciaries could become the subject of litigation or be unable to act consistently with their fiduciary obligations under ERISA.

A fee policy statement can be helpful in meeting fiduciary duty, says Marcia Wagner, president of The Wagner Law Group. “A plan sponsor should explain to participants in advance the 404(a)(5) Disclosure Regulation and the type of information that will be provided,” she says. A fee policy statement can act as a reminder that the plan sponsor monitors and stays current with the plan’s costs and keeps participants informed about the complexity of plan costs and fees.

Holland points out that the fee policy statement can also benefit the adviser. “You’re showing you’re ahead of the curve,” he says. “You’re protecting the plan sponsor, your client.” The fee policy demonstrates the adviser’s value and expertise as it is used to track other covered service providers. Everyone who sees it understands that the adviser is adhering to a valid, prudent process, he explains, so it is a benefit to both plan sponsor and plan adviser.

Advisers and consultants are often engaged to assist plan fiduciaries with understanding plan fees and with creation of this statement, according to Downie. “These providers, as well as legal counsel, may be retained to assist plan fiduciaries with drafting and implementing fee policy statements,” she says.

The Adviser’s Role

According to Holland, the retirement plan adviser should take an active role in the fee policy statement. “Anyone who’s going to assume a fiduciary role in writing would want to help control the process,” Holland says.

Fee disclosure regulations have not yet celebrated their second birthday, and the industry is still in an evolutionary period, Holland says. Fee policy statements will likely become more prevalent for several reasons, he feels. “A lot of people feel 408(b)(2) didn’t do what it was supposed to do. But I think it has. One of the things it has brought about is more people asking questions, so fee policy will become more important. People are going to need to keep track and document fees.”

The use of the title “fee policy statement” has developed post-disclosure, according to Holland, and is now added to the investment policy statement. Fee disclosure regulations helped to push it along, but he says it is not necessarily a DOL initiative. As it is used now, Holland says the fee policy statement is an easy way for plan sponsors and plan fiduciaries to understand all the fees associated with the plan, rather than “some elongated ERISA term.”

Fee policy statements are essential, Holland believes. The statement is a way of being proactive, and it builds credibility. “Anyone who’s going to compete in this space needs to do this,” he says. “You’re talking about participant accounts, and money needs to be accounted for. It helps the plan sponsor understand the value that advisers and consultants bring.”

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