When HR and Finance Get Together, DC Plan Results Follow

According to Josh Cohen, a big part of PGIM’s strategy as a DCIO provider is to foster conversations across plan sponsors’ own organizations, “presenting them with a framework for frank and practical discussions between the HR and finance functions.”

Since being hired from Russell Investments more than a year ago, Josh Cohen, managing director and head of institutional defined contribution for PGIM, has spent a lot of time meeting face-to-face with plan sponsor clients across the U.S.

In fact, one of his main roles as head of DC plan business is to sit down and strategize with the firm’s largest and most influential defined contribution plan clients—work Cohen described as “very gratifying.”   

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“The idea is that I am supposed to lead conversations with these clients that go beyond specific products to instead talk about strategic goals and the industry landscape,” he explained. “Needless to say, plan design questions having to do with retirement income are a hot topic these days out in the field, and fiduciary issues remain an ever-present priority for DC plan sponsors, large or small.”

Asked to talk frankly about what he sees unfolding in the DC plan marketplace, Cohen commented that a big part of PGIM’s own strategy as a provider has been to foster deeper conversations across plan sponsors’ own organizations, “presenting them with a framework for allowing frank and practical discussions between the HR and finance functions.”

“We are also working to tie in plan sponsors’ legal resources and fiduciary resources to really go beyond an investment discussion and to have a deeper strategy debate,” Cohen explained. “It sounds idealist, but it is worth spending time on as a provider. There is a lot of value in having conversations that are not just product driven. Our products have to start with the question of, what are our clients’ objectives and how can we help them get there?”

As Cohen sees it, the “whole retirement income conversation” is a good example of where a deeper discussion of objectives is sorely needed.

“Often when we go out into the marketplace to talk about this topic, there are immediately questions about what products are available right now,” Cohen said. “We know this is a pressing topic for plan sponsors, but we encourage them to first think about their objectives and their workers’ objectives. Only then can we have a constructive conversation about offering retirement income, either within or alongside the DC retirement plan.”

Opportunity in active fixed income

Another pressing topic out in the DC space that Cohen speaks to quite a bit is the fixed income picture—and how active management has excelled in this area in recent years.

“I would encourage plan sponsors to think more about this, and to reconsider the opportunities of using active management on this side of the portfolio,” Cohen said. “Often there is so much more focus on the active-versus-passive discussion on the equity side.”

Cohen cited the example of a recent client roundtable he hosted on the subject of actively and passively managed fixed income to show why more discussion of this topic is needed.

“We recently held a client roundtable of our largest plan sponsors, many of them tasked with running both DB and DC plan programs,” Cohen explained. “While use of active fixed income options on the DC plan menus is still emerging, we also asked them, how many of you use passive management for your fixed income portfolios for pension plan assets. Just a single one raised their hand, and that was a public plan with its own unique pressures to use passive management.”

According to Cohen, with the increased interest in retirement income on the DC side, both guaranteed and non-guaranteed, there is an expanding role for longer-duration fixed income to help individuals meet their specific retirement income goal.

“And just like a pension plan, an individual does not want to naively track a market-based fixed income benchmark that is not designed with an individual lifespan or spending needs in mind,” Cohen suggested.

DC plans on trial

Asked about the impact of the rush of retirement plan litigation, Cohen said this really cannot be overstated. Plan sponsor clients frequently suggest they are feeling constrained by the threat of litigation, “and sadly this feeling is not going to go away any time soon.”

“One of the biggest trends we are seeing, particularly in the large plan space, continues to be a concern about fees and making the plans less expensive and seemingly easier to use,” Cohen observed. “There are positive aspects to this trend, of course, but missing is the deeper consideration of what driving to the floor on fees means for the real value of what plan participants are receiving from providers. I think one of the core vexing issues here is that a lot of the decisions that plan sponsors are called on to make are very long-term in nature, and so they do not have a return that is immediately measurable or apparent. But at the same time, sponsors are beholden to the litigious environment in the here and now.”

The overall result is that plan sponsors broadly are doing whatever they can to reduce their perceived fiduciary exposure and other risks.

“My warning after meeting with so many great plan sponsors is that anyone can get sued in this industry, even if you’re doing a good job by your participants, especially if you are a large plan sponsor,” Cohen concluded. “So you can’t be making decisions just based on fear of litigation. I’ve seen people get sued for having stable value and for not having stable value, for having custom target-date funds or for using off-the-shelf funds; and I’ve seen a plan sponsor that embraced a fully passive menu get sued not for fees but for performance issues. It’s a challenge, but I would just remind plan sponsors that the law requires you to have a prudent process and to follow that process. You can defend yourself quite effectively with a quality process and documentation.”

An update on the white labeling trend

Cohen also pointed to continued interest from some segments of the plan sponsor population on the topic of white labeling of investments, or what PGIM refers to as “building a multi-manager approach.”

“After meeting with many plan sponsors on the subject and facilitating conversations across their HR and finance functions, this interestingly one of the areas where there is somewhat more immediate buy-in and enthusiasm from the financial folks,” Cohen observed. “Often these finance professionals are used to working on the pension plan side where the idea of sponsor discretion and white labeling is more natural, compared with the world of DC plans, which is still coming out of the retail trends of the 1990s.”

As he sees it, Cohen said the HR side may not have as much appreciation of the opportunities of white labeling from the ease-of-investment perspective, and thus they may be more likely to view white labeling in the DC plan as taking something away from participants, because the reporting methods and requirements are different

“We have been collaborating with an increasing number of consultants who are serving as 3(38) outsourced investment managers,” Cohen said. “You can see why the 3(38) providers would favor this approach, because they can exercise their discretion faster and more efficiently. We are seeing more outsourced investment managers building their own multi-manager funds that can be used across their client base. It’s an interesting area of development.”

Simplification of Retirement Plan Disclosures Included in Trump Executive Order

The executive order regarding RMD rules and open MEPs, signed last week by the President, also asks the DOL and Treasury to simplify disclosure regulations for plan sponsors and participants.

President Donald Trump last week signed an executive order that states, “It shall be the policy of the Federal Government to expand access to workplace retirement plans for American workers.”

The order called on the Secretary of Labor to clarify and expand the circumstances under which U.S. employers, especially small and mid-sized businesses, may sponsor or adopt an open multiple employer plan (MEP) as a workplace retirement option for their employees, subject to appropriate safeguards; and increase retirement security for part-time workers, sole proprietors, working owners, and other entrepreneurial workers with non-traditional employer-employee relationships by expanding their access to workplace retirement plans, including MEPs.

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The President also ordered the Secretary of the Treasury to examine the life expectancy and distribution period tables in the regulations on required minimum distributions (RMDs) from retirement plans and determine whether they should be updated to reflect current mortality data and whether such updates should be made annually or on another periodic basis.

While Trump noted that expanding access to MEPs can reduce administrative costs for the establishment of a retirement plan, especially for small businesses, he also pointed out that reducing the number and complexity of employee benefit plan notices and disclosures currently required would ease regulatory burdens.

So, in the executive order, Trump calls on both the Labor and Treasury Departments to “complete a review of actions that could be taken through regulation or guidance, or both, to make retirement plan disclosures required under ERISA [Employee Retirement Income Security Act] and the Internal Revenue Code of 1986 more understandable and useful for participants and beneficiaries, while also reducing the costs and burdens they impose on employers and other plan fiduciaries responsible for their production and distribution.” He says the review should include an exploration for the broader use of electronic delivery of disclosures.

An American Retirement Association study found current regulations requiring paper delivery of participant defined contribution (DC) plan information can cost investors between $350 million and $500 million per year, which can reduce the average account balance by 2.4% over a 40-year work life. Five years ago, the Government Accountability Office (GAO) asked the U.S. Treasury and Department of Labor (DOL) to revise electronic disclosure rules governing employee-sponsored retirement plans to improve clarity and protect participant rights.

And, legislators continue to push for a bill that would allow retirement plan sponsors to automatically default participants into receiving plan documents and statements online.

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