CITs May Be the New Mutual Funds of DC Plans: Have They Earned It?

Low-fee collective investment trusts, already popular among large plan sponsors, may be moving down-market to smaller plans.

Art by Lars Leetaru


Collective investment trusts have taken the defined contribution investment world by storm in the past decade.

The pooled investment vehicles, which are held by a bank or trust, have overtaken mutual funds as the most prevalent investment vehicle in defined contribution savings plans, according to consultancy Callan’s most recent DC Index. In addition, analysts at Morningstar say CITs are poised to become the most used target-date-fund strategy in 2024, a potentially watershed moment for the “set-it-and-forget” retirement savings tool.

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CITs, known for taking more paperwork and setup for a plan sponsor than adding a mutual fund to a plan lineup, appear to be making up for that friction by offering lowering fees. But what kind of savings does a CIT really provide when compared with mutual funds, previously the most popular investment vehicle in retirement plans due to their diversity and ease of use?

Using a CIT can save, on average, 15 basis points, or 0.15%, due to lower administration, marketing and management fees, says Toby Cromwell, senior director for CIT funds product management and development at Broadridge Financial Solutions.

“Historically, one of the selling the points of a CIT is that you have a lot less shareholder noise and, with that, lower fees,” Cromwell says. “There is a lot more asset movement in a mutual fund, whereas a CIT is much more sticky, with money staying invested there for a longer period of time once it’s invested.”

When comparing a fee of 50 bps (0.50%) to one of 35 bps (0.35%) on $100,000 over 20 years, the savings do not look like much. For example, assuming an 8% annual growth rate, a participant is pocketing about $700 more by choosing a CIT. But multiply that potential savings by thousands of participants in a plan, as well as the raft of excessive fee lawsuits going after plan committee and adviser choices, and the CIT becomes a compelling option for plan sponsors, says Megan Pacholok, a senior manager research analyst at Morningstar Research Services.

“A larger plan sponsor can negotiate their fees, and that larger base can bring a lower cost than mutual funds,” Pacholok says. “As they weigh in the excessive fee lawsuits around more expensive TDF options, CITs are a compelling option.”

Those lawsuits often include plaintiff allegations that a plan sponsor or fiduciary adviser stuck to one mutual-fund-backed TDF without exploring lower-fee options.

Steven McKay, head of global defined contribution investment only and institutional management at Putnam Investment, says demand for CITs has grown in part due to that fee pressure. But there is also “tremendous growth” due in part to increased transparency and the ability to benchmark CIT options against each other.

“We live in a world of benchmarking options against the competition or against the best,” McKay says. “It’s very important to the fiduciary advisers or the plan sponsors to have access  to benchmarking to compare options.”

The broadening uptake of CITs has created a somewhat virtuous cycle, McKay notes, as increased use has mostly done away with minimum asset requirements for CITs, which further broadens both the demand and case for innovation.

“We’ll continue to look at growing our CIT suite and strategy as client demand continues to grow,” he says. 

Moving Down Market

While large plans have started the CIT trend, the ease of use and increased transparency of the investment offerings are making them more compelling for mid-market and even smaller plans as well, says Julie Wimer, director of client service and product at Great Gray Trust Company, the new company formed from Wilmington Trust NA’s former CIT division, which was purchased by private equity firm Madison Dearborn Partners LLC.

“We are starting to see more plans in the small and midsize market take advantage of CITs,” Wimer says. “From a fiduciary standpoint, they are tasked with the overall prudence of the investment lineup, and part of that is to not only look at investment strategy, but also the fees as well.”

Great Gray, which can act as the trust on its CIT offerings, looks to make CITs an easier-to-use option for plan sponsors with a digital onboarding process. In the past, that onboarding could be onerous, as the sponsor had to sign a participation or adoption agreement to invest in a CIT.

“We need to make sure we are only putting qualified money into the CIT—the second that you put in a plan that is not eligible, it won’t work,” Wimer says.

Another stumbling block for CITs had been transparency of the investments. Unlike mutual funds, which are publicly listed, CITs were often off the radar and only visible to the advisers, plan sponsors and participants.

The former Wilmington Trust division, now Great Gray, has worked to improve that transparency in the hopes of increasing market uptake. In 2019, the trust announced a partnership with the Nasdaq Fund Network to show searchable tickers for CITs—giving them six letters instead of the five usually used for mutual funds.

“That myth that was out there that it’s so hard to add a CIT to plan has gone away, and it has become more sensible in that small and mid-market,” Wimer says. “That is why we are starting to see growth there, and I would expect to see more growth in that area going forward.”

McKay of Putnam notes that the firm offers both in-house trust services for CITs as well as use of third parties depending on client need.

“This is important because we work with a lot of plan service providers and a lot of large intermediaries and aggregators,” he says. “Sometimes they want to have access to Putnam CITs, but while working with other trust companies.”

Advising the Advisers

Cromwell of Broadridge says he has seen more interest in CITs among smaller-and midsize plans. But he has also been in discussion with sub-advisers who manage funds that want to add CITs to their investment mix. Cromwell says subadvisers have the experience creating target-date funds, large-cap funds and mixed-income funds, and they see the CIT as a way to provide the same investments with lower fees.

“With the CITs, you’re going to see roughly whatever performance that manufacturer or investment manager can put up without those trustee fees or expenses,” he says. “Performance is key, because you get better outcomes for participants because of lower expenses and the compounding of accounts over long periods of time.”

Cromwell notes that the regulatory burden on CITs, once they are set up, is often less onerous than that shouldered by mutual funds, which are overseen by the SEC. CITs, instead, are overseen by state regulators and the Department of the Treasury’s Office of the Comptroller of the Currency because the investment vehicle sits within a trust or bank.

That said, plan sponsors and advisers should understand that CIT disclosures should have the same rigor as any other DC investment.

“We view disclosure as basically the same as the mutual fund in terms of fees for the plan sponsor and participant,” he says. “We need to make sure that we are catering to ERISA and the DOL, because by the the nature of the CIT, it can only be ERISA plans that use it.”

Like many trends in the retirement space, it has taken years for the CIT to take hold, and it is only recently that smaller plans have gotten access to the investment vehicle thanks to advances in technology and practices that have lowered the plan asset threshold for entrance, Cromwell says.

“Now you are seeing a democratization for the DC plan,” Cromwell says of CIT use. “I don’t think just because you work for a large plan, you should get a much bigger deal than someone with a smaller plan. That democratization is key and already starting to happen in the CIT space.”

NQDCs Have Never Been More Popular. Is There Room for Them to Grow?

Trying to attract and keep talent, firms offering nonqualified compensation plans may need more innovation than expansion.

Art by Anja Susanj


As the labor market remains tight across many sectors, employers have sought ways to attract talent and keep their top people. In recent years, one tool of choice has been nonqualified deferred compensation plans, valued for their flexibility and low cost. But with the pressing need for talent retention now going well beyond top Fortune 500 executives, what’s next for NQDCs?

“The Great Resignation and the decoupling of the physical location from the work has really created a higher demand for retention,” says Tony Greene, senior vice president at NFP Corp., an insurance broker and consultant that offers deferred compensation plans. “There’s a fluidity, and senior people are the most fluid. Highly-compensated people are the ones with the most ability to work flexibly. We spend a lot of money recruiting key talent.”

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NQDC plans first emerged as a way for high-paid employees to supplement their retirement savings with earnings held for a later date with tax advantages similar to a retirement plan. With IRS rules capping the amount that can be paid into a 401(k), those workers were unable to put aside enough money to be sure they would keep the same standard of living during retirement. The NQDC option was a way to increase that savings pool.

As the benefit became popular at larger firms, it made its way downstream to smaller ones and to nonprofit organizations. 2022 data from PLANSPONSOR (which, like PLANADVISER, is owned by Institutional Shareholder Services Inc.) show that the assets held in NQDC plans has ballooned to $172 billion in 2022, up from $73 billion in 2013. The number of plan participants has also risen, topping 741,786 last year, compared with 714,242 a decade ago. Industry experts say the push is continuing this year, particularly as workers move between companies.

Pre-Pandemic Push

In the years before the COVID-19 pandemic, the aging of the workforce helped drive some of the take-up for NQDCs, but so did an increasing appreciation of key employees—a consideration that only became more acute as the job market tightened.

Employers are “very thoughtful about the fact that the people they’re doing this for have been important to the company, so they want to do something for them,” says Patti Bell, assistant vice president of advanced solutions at Principal Financial Group.

Greene, of NFP, notes that key people are worth more because they drive measurable value. In a small business, he says, losing one key person can mean losing a year’s worth of work. What’s more, replacing a highly-compensated employee can cost as much as two to four times each $100,000 of that employee’s compensation.

To some extent, the urge is felt more keenly at smaller firms than large ones, and even felt more at nonprofits than for-profits, experts say. While key employees may not fall prey to the same labor market whims as less senior people, the pandemic likely prompted a widespread reckoning.

“Key people aren’t going to go across the street for $10,000 more, but there is a concern that if their needs aren’t met, they might start to look around,” says Mark Ritter, a senior director with RSM US, an audit, tax, and consulting firm.

Ritter and others say the bespoke, customizable nature of NQDC plans is by far one of their bigger draws.

Principal’s Bell offers a few examples of the more creative versions she’s seen: a lump-sum payment offered after a year or two of employment that can pay down student debt for a sought-after attorney or physician; a similar arrangement that allows a second-in-command to buy the company from the owner, or to pay for a partnership stake. But with so much recent take up, could the recent rush into NQDC adoption be nearing a saturation point?

Some experts say it’s possible. Jason Stephens, senior director of the executive benefits practice at CAPTRUST, says interest has waned a bit for the benefit. He sees some of the big macro drivers, including the tightness in the labor market, starting to ease.

“You have to be considerate: When the market shifts, can you put these things back in the bottle?” Stephens says. “If you make a plan overly attractive in the current market, could it be richer than you intended? When we’re talking to plan sponsors, we always tell them to consider all that.”

Ritter echoes that, pointing out that NQDC plans, by definition, cannot be adopted widely, because once a certain threshold of employees is enrolled, it will no longer be considered a nonqualified plan, but instead be subject to ERISA guidelines.

An Evolving Benefit

While some experts are more focused on creative plan designs, Stephens thinks future progress will come from helping employees make better use of the plans they’re receiving.

“The challenge is [in not] designing a plan that might be too flexible for a participant to understand,” he notes. “Plan sponsors want to offer the flexibility, but also the education, to show the employees the value of the benefit.”

That means the next iteration of NQDC enrollments might include something like financial planning advice or access to a consultant who can help the employee manage the benefit, Stephens says. He also notes the broad wave of consolidation sweeping the employee benefits industry, impacting NQDC plan administrators in particular. Now, Stephens says, many administrators may have started as qualified-benefit shops and added a somewhat streamlined nonqualified practice along the way.

“Anecdotally, we’ve heard a lot of feedback about that: Is it a watering-down of the service model? It’s caused a little bit of consternation,” Stephens says. Some service providers are “not as robust as the original nonqualified specialists would have been.”

For his part, Ritter thinks there may start to be more explicit linking of the payout of the deferred benefit with some form of performance metrics, which he calls a “sensible best practice.”

Ultimately, though, he believes deferred compensation for key employees will always be a need: “You want to design these kinds of plans to excite people, not just to get them not to quit. I think they’re going to keep evolving as long as corporate cultures keep evolving.”

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