The Department of Labor’s (DOL) Employee Benefits
Security Administration (EBSA) prepared general guidance to assist plan
fiduciaries in selecting and monitoring target-date funds (TDFs).
The document says the guidance can
also be used for other investment options in participant-directed individual
account plans. The guidance includes a review of TDF basics.
Establish a process for comparing and selecting
TDFs;
Establish a process for the periodic review of selected
TDFs;
Understand the fund’s investments—the allocation in different
asset classes (stocks, bonds, cash), individual investments and how these
will change over time;
Review the fund’s fees and investment expenses;
Inquire about whether a custom or nonproprietary
target-date fund would be a better fit for the plan; and
LAS VEGAS—While there is considerable room for improvement,
401(k) defined contribution plans have largely been a success. That was the
consensus of speakers at the session, “Are 401(k) Plans a Failed Experiment,”
at the National Association of Plan Advisors/Association of Pension Providers
and Actuaries (NAPA/ASPPA) 401(k) Summit here Sunday.
However, with even the conservative Fox Business calling for the “retirement”
of 401(k)s, the plans have come under attack, said Brian H. Graff, Chief
Executive Officer of ASPPA.
Not all of the criticism is warranted, as 401(k) plans have
helped many people prepare for retirement, said Kevin Crain, head of
institutional and benefit services at Bank of America Merrill Lynch. Automatic
enrollment, in particular, has been a boon for the plans, with 56% of employers
using it, and 89% of employees automatically enrolled and staying enrolled,
Crain said. “401(k) plans have not been a failure,” Crain said. Rather, it is
important to focus on their “evolution in the past 10 years to a Democratic
paternalism.”
That said, plans do need “more advanced use of automatic
enrollment,” Crain said. “It is not enough to default enrollment at 1%. Also,
enroll all eligible employees—not just new hires. Add automatic increases and
other advancements, such as advice. People who use advice save $2,200 to $2,500
more a year, and if they start at a young age, they have a 30% more saved by
retirement.”
Additionally, nearly all—97%— employees who are defaulted
at contribution rates of 6% stick with the plan, Crain said. In fact, at Bank
of America Merrill Lynch, there has been a 20% increase in the past year in
sponsor clients that have combined automatic enrollment and automatic
escalation, Crain said. And if plan sponsors express concern about the higher
cost of participation, it is up to plan advisers to educate them that “higher
auto default rates don’t have to result in higher match costs,” Crain said.
(Cont’d…)
Perhaps the strongest characteristic of 401(k) plans is
their ease of use, said Judy A. Miller, executive director and director of
retirement policy at ASPPA. “They offer automatic payroll-deducted savings,
employer matches, tax deductions, professional asset management and
portability.”
“It’s the only way we have gotten middle class Americans to
save,” added Brian H. Graff, chief executive of ASPAA.
In addition, even though policymakers don’t appreciate this
fact, Crain said, 401(k) plans offer low costs and economies of scale, which
are getting even lower because of the fee disclosure requirements of the past
year. “Small and midsize plans invoke institutional buying power,” he said.
To strengthen 401(k) plans, however, Crain said that more
imagination is needed. Plans that do not automatically enroll employees in
their 401(k) plan should present the opportunity to their staff every year
alongside the annual health care decision, Crain said. The government needs to
preserve the tax benefits of qualified retirement savings accounts, he
continued. Plan designs need to be simplified, and the Department of Labor (DOL)
should limit sponsors’ fiduciary liability, “to encourage employers to continue
to sponsor retirement savings plans,” he said.
There are additional problems with 401(k) plans, noted
Karen Friedman, executive vice president and policy director at the Pension
Rights Center. 401(k) plans were never designed as outright pensions, but as
supplemental savings plans, Friedman said. Thus, to adequately prepare people
for retirement, individuals would have to contribute very large amounts to the
plans. And without automatic enrollment, automatic escalation and the use of
well-diversified qualified default investment alternatives (QDIA), all the risk
and decisions still fall on participants, she added.
(Cont’d…)
“401(k)s are a
gamble because they work for some people and not for others,” Friedman said.
“Only 5% max out their contributions. Lifecycle funds are good—but they vary
considerably and carry higher fees.”
That does not address the fact that millions of Americans do
not even have the option of investing in a workplace retirement plan—and 20% of
those that do take out loans or hardship withdrawals, or cash out of their
plans rather than roll over the money when switching jobs, Friedman said. “The
median 401(k) balance is $44,000 and $100,000 for people at retirement,” she
said. “The reality is that a lot of people aren’t saving for retirement.”
“Then, even if you do everything right, you still have to
make it last,” Friedman said. Retirement income solutions are not even on the
table for 401(k) plans, she said. Sponsors and advisers could start with
partial annuities, she suggested.
To strengthen 401(k) plans, the DOL and Congress should
expand options for annuitization in the plan, Friedman said, and restrict
pre-retirement access.
“The main problem is coverage and access,” Miller added.
“Small companies and part-time employees don’t have access to a retirement plan,
and with a changing workforce,” this is a critical issue, she said.
Additionally, “deferral levels need to rise,” she said. “Automatic enrollment
should be mandatory.” Simply put, Miller said, “people need to save more. And
lifetime income is lacking.
One encouraging development on the legislative front is the
idea of automatic individual retirement accounts (IRAs) for small employers
with five or more employees, Graff said. Seven states—California, Connecticut,
Illinois, Maryland, New York, Oregon and Washington—are considering some
version of this, Graff said. “Expanding the availability of workplace savings
through auto IRAs would set the stage for more employers to move up,” Miller
said. And this would not “cannibalize 401(k)s,” Crain added.