CFOs Say Auto Enrollment Biggest 401(k) Change after PPA

Nearly four in 10 (38%) of the chief financial officers (CFO) in a recent survey said their firms expected to add 401(k) automatic enrollment programs as a result of the recently enacted Pension Protection Act (PPA).

Nearly four in 10 (38%) of the chief financial officers (CFO) in a recent survey said their firms expected to add 401(k) automatic enrollment programs as a result of the recently enacted Pension Protection Act (PPA).

A news release reported that about 22% of the CFOs said they will be offering investment advice while a like number said they will add Roth IRA options. The “CFO Outlook Survey” is conducted quarterly by Financial Executives International (FEI) and Baruch College’s Zicklin School of Business.

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Eighty-nine percent of responding firms in the latest poll offer 401(k) plans. As a result of the PPA, 28% have made or plan to make changes based on the law’s provisions, while another 33% have not made a decision yet and 39% anticipate no change in the near term, the press release said.

According to the announcement, a third of the CFOs reported that the most common 401(k) default investment options for auto enrollment will most likely be money market funds (33%), though rebalancing asset allocation funds are a close second at 29%, the news release said. The Guaranteed Investment Contract (GIC) will be the most likely default option at only 4% of the companies. However, the survey, which included the responses of 171 corporate CFOs, was conducted during the week of September 18 – before the publication of the Department of Labor’s proposed regulations on qualified deferral investment alternatives (see DOL Unwraps New Default Investment Guidelines).

Automatic enrollment has been a major issue in the retirement planning community in recent months – particularly after the passage of the PPA and the recent release by the Department of Labor (DoL) of proposed rules governing default investment options.

Fidelity Research Launches with Retirement Strategies Perspective

A survey conducted by Towers Perrin immediately following President Bush's signing of the Pension Protection Act (PPA) found more employers are likely to maintain their defined benefit pension plans than freeze them in response to the Act's more stringent funding requirements.

A survey conducted by Towers Perrin immediately following President Bush’s signing of the Pension Protection Act (PPA) found more employers are likely to maintain their defined benefit pension plans than freeze them in response to the Act’s more stringent funding requirements.

Results of the survey show that plan sponsors for the most part anticipate only a modest change in required contributions to fund DB plans, and 63% categorized the financial risk imposed on their companies by their DB plans as still “manageable” after the PPA’s passage. Another 30% of respondents said the risk was “acceptable…and appropriate for the value we see in the program,” according to the survey report – findings that may be of comfort to advisers who currently support these type programs.

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When asked about the expected change in required pension plan contributions under the PPA, 44% of the 126 companies responding to the survey reported an expected 0% – 10% increase. Thirteen percent said they expect an 11% – 25% increase in required contributions, while 3% reported an expected increase of 26% – 50% and 7% said they expect an increase of over 50%.

Financial executives that responded to the survey did not seem intimidated by changes required by the PPA, as 39% said their organizations are well prepared to handle the complexity of the new funding rules and 53% said their companies are at least somewhat prepared.

Towers Perrin’s survey did not corroborate the view that the PPA will lead more companies to decide to freeze their DB plans. Almost half (49%) of respondents said they are likely to maintain their plan with the same or similar benefits. Nine percent said they would maintain their plan but reduce future benefit accruals. Of those saying they are likely to freeze their plans, 17% said they are likely to eliminate their plans for new hires and 5% said they are likely to freeze benefits for current participants. Twenty-eight percent said they were undecided.

Investment Strategy Shifts

Concern about contribution requirement volatility in response to changing capital market conditions is prompting pension plan sponsors to reevaluate their financial management strategies, Towers Perrin found.

Almost a third of respondents said they are very or somewhat likely to increase the level of bonds in their asset mix to help more closely match plan assets to liabilities. Only 5% of respondents said annuities were a potentially viable funding approach. However, 16% said they would consider transferring pension financial risks to outside parties at prices more favorable than annuities.

More than half (51%) of the executives surveyed said they need to do more analysis of investment approaches.

Towers Perrin’s analysis suggests that contribution amounts may not be more variable year after year though, since some provisions will help suppress the volatility expected to be increased by other provisions. While provisions of the PPA increase contribution volatility by decreasing the period of years for smoothing assets and liabilities and by restraining the use of credit balances, the new law enables more effective liability/asset matching strategies through the use of market values instead of averaged assumptions and provides more flexibility to advance fund DB plans during favorable economic periods, the report says.

Funding Levels Matter

However, the analysis suggests that DB plans will be affected by the PPA differently depending on current funding levels.

Plans with a current funding level of 100% or more can take advantage of the PPA’s permission to fund up to 150% in order to use surpluses for harder times, but they must be careful of the Act’s limits on what surplus funding can be used for and the fact that there is a restriction on the use of credit balances if the plan ever falls below 80% funded.

Plans currently funded near 90% on a solvency basis will face significantly higher contribution requirements than under existing law, according to the report. After a phase-in period, sponsors of these plans will be required to contribute until they reach the 100% funding target.

Additionally, if capital market conditions deteriorate, sponsors of these plans could face the 80% threshold that triggers limitations on the application of credit balances and an at-risk designation that can significantly ramp up funding requirements and Pension Benefit Guaranty Corporation (PBGC) variable premiums.

For poorly funded plans, the PPA provides a seven-year period to make up their funding deficiency, which may reduce the amortization amounts in the initial years. However, these plans will not be allowed to use credit balances until their funded status reaches 80%, and the “at-risk” designation is likely to be applied to these plans.

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