The PLANADVISER Interview: Fiona Greig, Global Head of Investor Research and Policy, Vanguard

Research and policy expert Fiona Greig discusses moving from consumer spending and saving patterns to the world of long-term retirement investments.

The PLANADVISER Interview: Fiona Greig, Global Head of Investor Research and Policy, Vanguard

Welcome to The PLANADVISER Interview, an online series bringing you the most influential people in the industry discussing the trends and issues of the day—in their own words.

As an economic research and policy expert, Fiona Greig has held roles such as consultant, university lecturer and deputy budget director for the city of Philadelphia. By the time the pandemic hit, she was leading JPMorgan Chase & Co.’s consumer research division, part of the JPMorgan Chase Institute, where she had access to the bank’s vast pools of data, including household finances, credit card use and home mortgages. Although the unprecedented times of the pandemic had the team working long hours to track trends, she enjoyed her time “being on the cutting edge of using proprietary client data in an anonymized way to do research that was having a real impact.”

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In the fall of 2022, Greig moved on from JPMorgan Chase to join asset management behemoth The Vanguard Group Inc. Now she is global head of investor research and policy for Vanguard’s Investment Strategy Group. In this role, Greig says she has a “window” into the massive world of 401(k) retirement investing. She is now bringing her expertise in household finance and the use of financial data to bring insights to policymakers, business leaders and Vanguard’s internal teams that create investment products and strategies.

We spoke with Greig recently about her new role and areas of interest in 2023.

PLANADVISER: You joined Vanguard in the fall of 2022. Can you talk about the new position and what you are working on?

GREIG: I had been with the JPMorgan Chase Research Institute for almost eight years, and I was thinking to myself, What can be next? It was around the moment that I was wrestling with this question when Vanguard called. I knew they had this incredible combination of big data, where I could leverage my academic background in the context of a private sector organization, but with a public goal. … From the start, I knew this was a company that advocates for all investors, and there was this clear alignment for me, personally, in terms of the mission.

What appealed to me specifically was Vanguard’s think tank. Of course, this means publishing research externally, but also working on Vanguard’s house view on any number of topics. For instance, the latest thinking internally for our businesses in terms of how to construct portfolios, the next best nudge for our investors, as well as how to advise them. … It was an opportunity not just to continue to use data for good externally, but also actually inform internal strategy.

PLANADVISER: Vanguard’s research and insights are widely cited and used by retirement plan advisers and others in the industry. What is the data that you want to delve into?

GREIG: The 401(k) is the largest asset after the home for most Americans. It’s an incredible source of wealth for families, and, coming into Vanguard, I get to peek into what the flows are in that data. It’s a window into how families are feeling financially. … We also have some really interesting surveys in terms of what people think is going to happen to the stock market or GDP over the next year or 10 years—both a short- and long-term horizon—and how those investor expectations connect to their behavior. 

Families are not usually trading [within 401(k) plans] even in these volatile markets, because the vast majority leave their assets in plan. But we can look at loans and hardship withdrawals, which, though small, are more about the trends you can draw from them. We’ve been watching those figures come up a bit in 2022 and 2023. Would I say that we are seeing financial distress writ large? No, absolutely not. So many of these indicators fell to a very low base [during the pandemic], and cash buffers were at a high-water level. So we enter this inflationary period with full coffers, good fundamentals and a very strong labor market.

PLANADVISER: What are some of the key themes you and the team are looking into?

GREIG: One of the net new themes my team is taking on this year is this idea of inclusive wealth-building. Vanguard has an amazing view into low-cost investment products and now also advice. Half of Americans don’t have a 401(k) plan. Of course, that is not the only door that people can invest through in the capital markets. We are looking at what are some of the other doors that we can allow for this engine of wealth over a long time to be accessible to more families and more workers.

Those are some of the themes that I am really interested in: assessing the long-term retirement readiness at a national level, regardless of whether someone is in in a plan or not. What are the financial needs of the bottom half of the income distribution? What are those needs for short-term versus long-term liquidity? What are the problems? What are the leaks in our system when people are falling out of a plan, or changing jobs, and how do we patch each of those leaks?

PLANADVISER: Vanguard is a leader in low-cost, long-term retirement saving vehicles that can build wealth over a person’s working life. But how important is not just the build-up, but also the spend-down, or decumulation, phase of using those assets for you?

GREIG: I do see it as crucial. The notion that you get to your target date, and you have saved pretty well, but then what? One of the first things we’re interested in is literally just describing the current state of how people are acting. What are people doing in retirement, whether in a DC plan or DB plan or not? How are they cobbling together different income sources? How are they transitioning from one glide path to another? By looking at the client data today, then one can really think through opportunities.

Whether that opportunity is something in portfolio construction—such as an annuity construction within the portfolio—or other solutions, those can all be on the table. At this point we are mostly at the starting line. We need to know what individuals are doing today to get to a well-designed decumulation plan. Our investment strategy group and our goals-based investing team are thinking about portfolio construction solutions. They’re creating an income stream in the decumulation phase and actively modelling it from a portfolio construction standpoint. It’s our job, on the research side, to see how clients are behaving and then help figure out what they need to live well in retirement.

Thanks for reading The PLANADVISER Interview. Who in the industry would you like to hear from? Let us know at Editors@ISSgovernance.com.

Aon, Astellas Pay to Settle CIT Conflict of Interest Litigation

A 2020 case over the performance of proprietary CITs ends with a settlement.


Investment manager Aon Investment Consultants and plan sponsor Astellas Pharma US Inc. have settled a complaint brought by current and former participants in the pharmaceutical company’s 401(k) plan, according to a Friday court filing.

The deal brings to a close litigation brought in July 2020 in which the plaintiffs alleged that Astellas allowed 401(k) manager Aon to select its own proprietary collective investment trusts for the plan when cheaper, better-performing options where available. Terms of the settlement were not disclosed but should be filed before June 9, according to the filing in U.S. District Court for the Northern District of Illinois, Eastern Division.

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“The parties have engaged in settlement discussions to resolve all claims and potential appellate rights, among other items,” the two sides wrote in the filing. “The parties have now reached an agreement in principle on all salient terms of a settlement to fully and finally resolve all claims.”

The plaintiffs were represented by Jerry Schlichter, a partner at St. Louis-based law firm Schlichter Bogard & Denton.

“We’re seeing more CITs, presumably because of the lower cost, so they are in the mix,” says Schlichter, who is founder and managing partner of the firm. “CIT’s must be evaluated just as publicly traded mutual funds to determine if costs are reasonable and the investments are prudent. The analysis is the same, regardless of the structure of the investments.”

Aon and Astellas did not respond to requests for comment.

Both sides requested that Judge Ronald A. Guzmán cancel a pretrial conference scheduled for July 11 and a bench trial scheduled for July 17.

Investments in Focus

Investment structure and fees have risen to become a top area of focus for defined contribution retirement plan committees due to consistent litigation regarding fee monitoring and conflicts of interest, according to consulting firm Callan’s most recent DC survey. Among plan sponsors’ litigation concerns, plan governance and process ranked first among respondents, followed by investment structure evaluation and then investment fees, according to the survey of more than 99 large DC plan providers conducted in late 2022.

“CITs have become a tried-and-true platform for investment of retirement assets, including in the participant-directed arena,” Andrew Oringer, partner and general counsel for the New York office of the Wagner Law Group, said via email. “There are ‘prohibited transaction’ exemptions that may cover certain conflicts of interest that could arise when a fiduciary uses an affiliated CIT, depending on the investment structure. However, these exemptions do not help with fundamental prudence and loyalty requirements.”

Oringer, who was not involved with the Aon case, notes that the litigation shows that “fiduciaries using CITs are not immune from ERISA fiduciary suits.”

“Sometimes, the special rules governing exemptions in the CIT context could make it harder for the plaintiffs to pursue the claim, but, as this litigation shows, the possibility of litigation is there with a CIT,” he writes. “The litigation also highlights that there could be additional risk with where funds affiliated with a plan sponsor or manager are used, regardless of the form of the investment.” 

Menu Management

According to the initial class action complaint, London-based Aon allegedly replaced nine of the plan’s 10 mutual fund options with its suite of collective investment trusts just two months after becoming a plan fiduciary. The CITs selected, according to the complaint, had been in place for three years, which the plaintiffs alleged was not enough time to report sufficient performance to be seen as the best option for participants.

Guzmán in April 2021 had allowed to move forward claims made through the Employee Retirement Income Security Act against Astellas, its board of directors and its retirement plan administrative committee.

In addition to the use of proprietary CITs instead of other options, the plaintiffs alleged that Astellas failed to use the plan’s bargaining power to negotiate reasonable fees for investment management services.

Aon had argued that the plaintiffs’ comparisons of the Aon CITs to other funds were flawed because the funds used in the comparison had different investment strategies and asset allocations. Aon had also argued that a provision in its investment management agreement showed that its decision to offer its own CITs “could not have resulted in a penny of additional compensation” beyond its contractual fiduciary fee.

Guzmán rejected that claim in April 2021, noting that even if Aon did not receive direct compensation for its CITs from the plan, it would have gotten other benefits for the use of its own investment products. The case is filed under Miller et al v. Astellas US LLC et al.

In a separate case related to Aon and its CITs, Schneider Electric Holdings Inc. completed the terms of a settlement agreement with retirement plan plaintiffs, closing for $200,000 a 2020 fiduciary breach lawsuit, according to a judge’s order to approve the unopposed March motion from the plaintiffs. The lawsuit was brought by participants in the Schneider Electric 401(k) Plan, also represented by Schlichter Bogard & Denton, alleging that instead of acting in the exclusive best interest of plan participants, the defendants selected and retained proprietary Aon CITs.

U.S. District Judge Nathaniel Gorton, presiding in U.S. District Court for the District of Massachusetts, on Friday signed the order to allow the settlement agreement in Turner v. Schneider Electric Holdings Inc.

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