Experts: Good Demographic Data Key to Driving Plan Design

Going beyond foundational participant data is valuable in addressing employee needs and attitudes, according to a panel of retirement industry experts.

When making decisions about plan design, investment menu lineups and financial wellness benefits, leveraging demographic information and properly collecting that data is a key piece of the puzzle, according to panelists who spoke at PLANSPONSOR’s Roadmap livestream event on Tuesday.

At the session “Check Your Demographic Mirrors,” Pam Hess, the executive director of the DCIIA Retirement Research Center, said while most plan sponsors have access to foundational participant data, it is valuable to peel back more layers to fully understand employee demographics and attitudes.

Want the latest retirement plan adviser news and insights? Sign up for PLANADVISER newsletters.

“I think of all the data elements like a house,” Hess said. “The first floor is like some of the basics: age, gender, income, tenure … data that most employers have access to. The second floor can add in some nuances around marital status or race. Not everyone has a second floor, but it’s certainly aspirational. The third floor is like the cobwebby attic, and it’s [understanding] financial wellness. It’s so important, but maybe it’s not well-understood or explored.”

Hess said focus groups can provide more nuanced demographic details, and conducting surveys is an effective way of gathering information. But she said to be wary of outright asking people to submit their demographic information in a survey, as many fear how this information will be used and might be hesitant about sharing too much information with their employer.

Conducting a financial wellness study that embeds straightforward questions about demographic information is a strategy that Hess recommended. She added that it is important for the plan sponsor to be transparent with participants and communicate why they are asking for this information.

An optimal time to gather information is usually at the time of hire or during annual open enrollment, Hess said. If an employer is conducting a survey, she said it is also important that there are no firewalls blocking people from taking it. Incentivization, such as offering people the chance to win a gift card for completing the survey, can be an effective way to drive participation as well.

“Keep it easy, simple and transparent,” Hess said. “I think the main takeaway is: Don’t wait for it to be perfect. … Go into it expecting that you’re not going to have 100% participation. Progress is the goal.”

Bridget Bearden, a research and development strategist at the Employee Benefit Research Institute, said keeping track of who attends employee resource group meetings could also help an employer understand the psychographics—psychological variables like attitudes, values and fears—of workers. A company may have ERGs for the LGBTQ+ community or for military veterans, for example. Tracking attendance at these meetings can help a plan sponsor better understand what their employees value and how that drives their behavior.

Demographic Personas

The panelists also spoke about the concept of demographic personas and how using personas—profiles that align with the characteristics of different categories of participants—can help inform plan sponsors about plan design and even investment lineups.

Personas dig into the personality of a group of participants, focusing on what makes them who they are and what drives them to seek out certain benefit offerings.

“Everyone that’s aged 20 to 30 and a woman earning $75,000 [per year] are not homogenous,” Hess explained.

Plan sponsors can use personas to target different educational materials, benefits offerings and investment menu options to relevant groups within the participant population.

An example of personas can be seen in Capital Group’s recent expansion of its employee engagement program, ICanRetire, an expansion specifically targeted toward Hispanic participants. The various program participant personas represent different age groups, participation rates and other factors like financial knowledge and investing confidence. The personas are invisible to participants using the program, but they inform the way ICanRetire creates tailored content.

Bearden said developing clusters of benefits offerings to meet the needs of different demographic personas in this way is more cost-efficient than personalization because it can target larger swaths of a population.

“You can have seven personas that you do messaging for, and it doesn’t have to be [specific to] age and race,” Bearden said. “It’s really a marketing exercise, at its core.”

Anonymized Data

When providing data, many participants do not want any personally identifiable information to be shared with their employer. A plan sponsor can more easily collect “anonymized data,” information that is stripped of all things personally identifiable, such as addresses, Social Security numbers and phone numbers.

Hess said DCIIA found in a survey that many employees fear their employer will use information against them. For instance, they fear that if their employer finds out that they have a bad credit score, this could impact how their employer views them. Hess reminded attendees at the webinar that employers do not need to know everything about each individual but can survey pockets of the population instead.

Bearden said it is important to separate traditional demographics from personal identities. EBRI research found that caregivers, in particular, are reluctant to tell employers about their role as a caregiver for fear that their manager or employer will treat them differently.

“It is important that we are sensitive to the nuances of demographics and understand where demographics end and where identities begin,” Bearden said.

Industry Advocates Implore DOL for Regulatory Clarity on SECURE 2.0

Emergency savings and disclosures were points of focus.

Retirement industry groups filed comment letters Wednesday with the Department of Labor asking for clarity on certain provisions of the SECURE 2.0 Act of 2022 and for streamlined disclosure requirements. The comments came in response to a DOL request for information in August.

SECURE 2.0 contains several provisions reforming the disclosure process for retirement plans. Among them are changes to lump sum distribution disclosures and to the electronic delivery of statements.

Want the latest retirement plan adviser news and insights? Sign up for PLANADVISER newsletters.

Emergency Savings

The Insured Retirement Institute and the ERISA Industry Committee both asked the DOL to issue regulations to clarify how the emergency savings “sidecar” accounts created by SECURE 2.0 fit into the overall retirement plan. The ESAs are limited to $2,500 (indexed), and participants can withdraw funds without the typical 10% penalty.

The IRI asked the DOL for guidance on how to interpret the word “emergency” for purposes of withdrawals and how ESAs overlap with plans using a qualified default investment alternative. Specifically, can sponsors designate the ESA as a QDIA? Can a plan have separate QDIAs for the ESA and for the retirement plan?

The ERIC asked the DOL to clarify that the $2,500 cap does not apply to growth within the account. Since highly compensated employees do not qualify for an ESA, the ERIC requested that the DOL be flexible with employees who change HCE status over the course of the year. It also asked for regulatory flexibility on matches and vesting schedules as applied to ESAs.

Electronic Delivery

Section 338 of the law requires defined contribution plans to send at least one paper copy of a benefit statement to each participant annually, every three years for defined benefit plans. Participants may, however, elect to receive these documents electronically, and sponsors can also use the 2002 safe harbor exemption. The provision is effective for plan years after December 31, 2025.

Jason Berkowitz, the chief legal and regulatory affairs officer at the IRI, explains that the 2002 safe harbor permits sponsors to send benefit statements and other disclosures electronically only if they ensure that the participants receiving the disclosures have reliable internet access and are, in fact, receiving the disclosures.

The comment letter sent by the IRI described Section 338 as “unfortunate” because of the additional burdens this will place on sponsors. The DOL had previously issued an updated safe harbor ruling in 2020, Berkowitz says, which was more of a “notice and access” approach by which sponsors could default participants into electronic delivery if they were given the ability to opt out and were notified when disclosures were available.

Sponsors using the 2020 safe harbor, but not the 2002 safe harbor, will be subject to the annual paper requirements, Berkowitz says. Since Section 338 is a statutory requirement that the DOL cannot regulate away, the IRI letter advocated that the DOL “go no further than is clearly and absolutely necessary” to comply with SECURE 2.0. The IRI letter noted that electronic delivery is generally more secure than paper delivery and is more easily translated into other languages or to an audio file for vision-impaired participants.

Lump Sums

The ERIC letter also addressed disclosures of lump-sum buyout offers. Section 342 of SECURE 2.0 requires defined benefit plans to disclose several items to participants eligible for a lump sum payment. At 90 days before a lump-sum offer decision period, plan sponsors must disclose the assumptions used to calculate the lump sum, the value of annuities offered by the plan, tax rules involved with accepting a lump sum and a warning that annuities purchased in the market might be more expensive than those in the plan and that taking a lump sum exposes the recipient to longevity risk.

According to the ERIC letter, the DOL should not mandate any new factors to be disclosed, but should allow plans to list potential “positives” of taking a lump sum instead of “negatives.” For example, sponsors should be allowed to inform participants that lump sums can help estate planning and can pay off in the long run if the payment is invested well.

Section 342 does not contain any “negatives” for lump sums, per se, but would require disclosure on alternatives to the payment. Andrew Banducci, the senior vice president for retirement and compensation policy at the ERIC, clarifies that the warnings in the disclosure “have a skeptical trend” and said that a Model Notice circulated by the DOL “does not provide a balanced perspective” on lump sum payments.

SECURE 2.0 requires the DOL and Department of the Treasury to issue joint regulations on the lump-sum provision no earlier than one year after the December 29, 2022, enactment of the law.

The comment period for the RFI closed on Wednesday, and it is not clear when the DOL will propose the regulations required. Sidecar ESAs are eligible to be created starting in 2024, but they are unlikely to be offered until regulatory guidance is issued.

«