Smaller Plan Sponsors More Likely to Default to TDF that Moves to Managed Accounts

A hybrid QDIA solution that transfers participants from a TDF into a managed account can be a hard sell, say plan advisers, but there is traction among smaller plan sponsors with less litigation risk.

In recent years, retirement plan advisers have been discussing the potential benefit of dynamic qualified default investment alternatives that shift participants from target-date funds into managed accounts, but those conversations have not led to widespread plan sponsor adoption, according to advisers and recent data.

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Many advisers say they see value in a dynamic, or hybrid, QDIA that starts a participant out in a TDF and shifts them later in life to a more personalized managed account to help manage their retirement saving and income strategies. But having plan sponsors buy into that offering has been a challenge.

Mark Olsen, managing director of plan advisory PlanPILOT, says despite consistent education on the benefits of a dynamic QDIA, only about five clients are using the option. “I think we’ve done a good job educating people, but we haven’t seen very much adoption,” he says.

The plan consultant says the success of TDFs is without question, with 95% of defined contribution plan clients leveraging them. But when it comes to discussing the need for older workers to get more personalized—and more expensive—attention by being transferred into a managed account, retirement plan committees often balk.

“As with many things in the HR space, no one really wants to be the first one to do it,” he says.

According to consultancy Cerulli Associates, while hybrid QDIAs have not been going gangbusters, there has been some positive movement in recent years. In the latest data available from a survey of target-date product managers, 11% of assets were held in dynamic QDIAs as of year-end 2021, up from 2% in 2019.

In a separate survey of 23 defined contribution consultants by Cerulli in 2022, 5% of their plans are using a dynamic QDIA. Of that group, the ones most likely to use the product were retirement aggregators focused on mid-market plan sponsors, says David Kennedy, a senior retirement analyst for Cerulli.

“Managed accounts are one of those things that are a great idea on paper, but there’s a ton of complexity when actually implementing them,” Kennedy says. “I’m not sure if [adoption] is going got be up to plan demographics as much as it’s going to be up to the people running the plan at the plan sponsor level, and how good of a job the consultants do positioning it as well.”

Dynamic QDIAs, Kennedy notes, are still fairly early to the market, having come onto the scene about seven years ago but only getting attention in recent years.

Empower Retirement was an early mover, bringing an offering to market in 2017. More recently, Lincoln Financial and Stadion Money Management announced a dynamic QDIA in 2022, and both John Hancock Retirement and Principal Financial Group announced offerings in 2023.

Litigation Concerns

Kerry Bandow, head of defined contribution solutions at Russell Investments, says he loves the idea of dynamic QDIAs and once worked with a client who defaulted participants directly into a managed account, skipping the TDF. In that case, the plan paid the fees, so it was essentially a “free managed account for participants.”

Currently, however, Bandow is working with plans of $10 billion or more in assets, and none are currently interested in the dynamic QDIA option.

“When you look at a managed account and, depending on plan size, [the cost] can be 20 or 25 basis points on plan assets [for a large plan],” he says. “When you can get plans using target-date funds that are 5 basis points … it can be really hard to justify. That’s particularly the case when participants don’t engage.”

That engagement issue, Bandow says, can be a real stumbling block for plan sponsors who are skeptical of getting participants to put the managed account to use. That said, Bandow still finds the option compelling.

“When participants get closer to retirement—when the end zone is in sight or the end of the tunnel is in sight—then they start to engage more,” he says. “That’s the beauty of the hybrid approach: Let’s just get people to save now and use auto-enroll and auto-escalation to save at the right level … and then once it becomes more meaningful and they are paying more attention, flip them to a managed account, which they can engage with, or those that can, of course, opt out.”

When speaking to recordkeepers, Bandow, has heard, in line with Cerulli’s research, that smaller plans are more likely to use the dynamic QDIA option. That’s in part, he says, because they are less concerned with getting hit by the retirement plan litigation that is a major concern for mega-plans with billions in assets.

“Litigation really inhibits advancement in DC,” Bandow says. “If you are over a billion dollars, you have a target on your back, because that is a lot of money to extract a settlement from. Really, the large-end marketplace—as much as I’m supportive of it—nobody wants to go there, because they don’t want to be the first to do it.”

Concept vs. Reality

“We’re not necessarily seeing plan sponsors ask for managed accounts, but personalizing any benefit (retirement or otherwise) is always something employers are interested in,” Craig Stanley, financial adviser and lead partner for retirement plan consulting in Summit Group, an Alera Group company, wrote in an email.

Stanley said his team has discussed hybrid QDIAs with clients and has seen “some movement toward this hybrid approach.”

“For those approaching their distribution years and having a more predictable set of assumptions, we believe a managed account can certainly provide value and personalization, even if they have not yet engaged,” he says. “For example, having your retirement assets in a portfolio of several distinct investments (unlike an all-in-one target-date fund) may provide a retiree with additional flexibility when taking a partial distribution—allowing them to target what investments are sold in order to avoid selling certain investments at inopportune times.”

But Stanley also notes that “there is usually a difference between conceptual value and practical reality that has to be considered.”

“The likelihood of engagement will increase significantly as the participants begin receiving communications from the managed account provider, especially as their time horizon shrinks and the idea of retirement becomes more of a priority,” he notes. “We are also beginning to see some managed account providers go above and beyond just focusing on investment allocations by also delivering guidance on claiming Social Security, how to structure sustainable retirement income distributions and other value-add services that can help justify the additional fee a managed account may bring.”

Olsen, of PlanPILOT, says he has seen greater interest and traction when discussing embedded retirement income products with plan sponsors. He says a combination of people getting over a misperception perception of annuities and a down market for both equities in fixed income and stocks during calendar year 2022 has made plan sponsors interested in the guaranteed income conversation.

“You’re putting [participants] into something that is going to offer protection,” he says. “That makes plan sponsors feel good, like they are helping people to help themselves.”

That can be a more compelling offer, he says, than telling people that participants are going to be transferred into a higher-cost managed account that should, with engagement, produce better outcomes.

Kennedy also notes that dynamic QDIAs, as a product, are “growing up” in a retirement plan market that has been managing through 2019’s original SECURE Act, the COVID-19 pandemic and now the SECURE 2.0 Act of 2022, all in the past three years.

“It doesn’t surprise me that they took a lower-level priority compared to those other things in the world,” Kennedy says. “But maybe going forward, once those things calm down, we’ll see more people concentrating on these new products and adopting them in their plans.”

New SEC Cybersecurity Rule a ‘Business Problem,’ Not Just IT or Legal, According to Experts

The new disclosure requirements for public companies will require time and resources to meet cybersecurity needs.


New cybersecurity rules adopted by the Securities and Exchange Commission last month will require investments in additional training and resources, according to compliance experts who have studied the rule.

Under the new rules, public companies need to disclose significant cybersecurity events within four business days of their discovery and maintain policies and procedures to ensure compliance. The first step for businesses to meet these regulations will be determining if a digital risk is “significant” or not, according to Richard Cooper, the global head of financial services at Fusion Risk Management. To do that, he says, firms must first understand what their business is and what security breaches would be a concern.

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“This isn’t an IT problem; it’s a business problem,” he explains.

Different firms have different priorities, and a regulator such as the SEC does not have insight into the nuances of every business, Cooper notes. The word “significant” is ambiguous, but “it’s ambiguous for your own good,” because the alternative would be the SEC deciding how to run and protect individual businesses.

Cooper gives the example of a bank’s access to cash, loans or key information on their clients and the market being breached or compromised as a “significant event.” But leaks of internal training material, preliminary data or publicly available information probably would not be considered “significant.”

Cooper adds that, for all relevant companies, employee training will be essential. If one department is compromised, then the entire firm only has four days to report it. This means employees will need to be able to recognize an event and know how to report it and to whom. Cooper asks, “Are you confident they will tell you quickly enough?” Companies should therefore focus training efforts on all departments rather than just the IT and legal divisions, he says.

If there is a significant digital event, a firm can request two 30-day extensions, followed by a final 60-day extension, by appealing to the U.S. Attorney General’s office to determine that disclosing the event would compromise national security or public safety, according to the rule.

Helen Christakos, a partner in Allen & Overy LLP, says, “It’s going to be a challenge to get in touch with the AG in that short a window.” She adds that, “there will be something of an art to writing these disclosures” to ensure compliance with the SEC’s rule while not complicating investigations taking place at the state or local level, since those officials do not have the authority to request a postponement of the disclosure.

Speaking of state law enforcement, Christakos recommends that companies “make sure everyone is in the loop and comfortable with what is disclosed,” but that, ultimately, a firm must still comply with the SEC rule.

There is no additional postponement for a significant cybersecurity event after 120 days, according to the rule.

Michael Borgia, a partner in Davis Wright Tremaine LLP, quips that, “after 120 days, it no longer matters what the AG thinks about national security; you have to disclose it.”

 

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