Fed Report Suggests More Investing and Financial Education Needed

Three-fifths of non-retirees with self-directed retirement savings accounts have little or no comfort managing their investments, and only one-fifth of adults answered five financial literacy questions correctly, according to the Federal Reserve.

Less than two-fifths of non-retired adults think their retirement savings is on track, whereas over two-fifths think it is not on track and about one-fifth are not sure, according to The Federal Reserve Board’s latest report on the Economic Well-Being of U.S. Households.

One-quarter of the non-retired indicate that they have no retirement savings or pension whatsoever.

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Older adults are more likely to have retirement savings and to view their savings being on track than younger adults. However, even among non-retirees in their 50s and 60s, one in eight lacks any retirement savings and less than half think their retirement savings is on track. Additionally, retirement savings vary substantially by race and ethnicity. White non-retirees are 14% more likely than black non-retirees to have any retirement savings, and they are 18% more likely to view their retirement savings as on track.

According to the report, self-assessments of retirement preparedness vary with the amount of current savings and time remaining until retirement. Among young adults younger than 30, people typically believe that their savings are on track if they have at least $10,000 set aside for retirement. The amount of savings needed for a majority to think they are on track increases as people near retirement, rising to at least $100,000 of retirement savings among those age 40 and older. Approximately nine in 10 people with at least $500,000 of retirement savings think they are on track, regardless of their age.

Withdrawing from accounts and discomfort managing investments

Some people withdraw money from their retirement accounts early for purposes other than retirement, according to the report. Overall, 5% of non-retirees have borrowed money from their retirement accounts in the past year, 4% have permanently withdrawn funds, and 1% have done both. Those who have withdrawn early are less likely to view their retirement savings as on track than those who have not—27% versus 39%, respectively.

Among those with self-directed retirement savings, including 401(k)s, IRAs, and savings outside of formal retirement accounts, comfort in managing investments is mixed. Three-fifths of non-retirees with these accounts have little or no comfort managing their investments. On average, women of all education levels and less-educated men are less comfortable managing their retirement investments than other groups.

The report says expressed comfort in financial decisionmaking may or may not correlate with actual knowledge about how to do so. To assess actual financial literacy, respondents were asked five basic questions about finances. The average number of correct answers is 2.8 with one-fifth of adults getting all five correct. The average number of correct financial literacy questions was higher for those who are generally comfortable with managing their retirement accounts (3.5 questions) than those who have savings but limited comfort (2.9 questions).

When and why people are retiring

Half of retirees in 2017 retired before age 62, and an additional one-fourth retired between the ages of 62 and 64. Average retirement ages differ by race and ethnicity, with black and Hispanic retirees more likely to have retired before age 62 (58% and 55%, respectively) than white retirees (48%).

In choosing when to retire, a desire to do other things than work or to spend time with family were the most common factors. Fifty-eight percent of whites cited a desire to do other things, while 63% of Hispanics cited wanting to spend more time with family. In addition, two-fifths of retirements before age 62—and one-third between ages 62 and 64—involved poor health as a contributing factor. About one-fourth of those who retired before age 65 said the lack of available work contributed to their decision.

Sources of retirement income

For income in retirement, 86% of retirees in 2017 received Social Security benefits, and 56% drew on a defined benefit pension, while 58% used savings from an IRA, 401(k), or other defined contribution plan. The types of retirement savings for current retirees differs substantially from non-retirees, for whom defined contribution (DC) plans are much more common than defined benefit (DB) plans.

The sources of retirement income also differ by race and ethnicity. Black and Hispanic retirees are less likely than whites to have self-directed savings. In aggregate, 71% of black retirees and 66% of Hispanic retirees are drawing from at least some private retirement savings (other than employment during retirement and relying on family), compared to 86% of white retirees.

FINRA Seeking Comments on Churning Rules as SEC Considers Action

A new client alert published by the Wagner Law Group urges advisory firms to review and consider an update to anti-churning policies, now that FINRA and the SEC are both engaging in the matter.

On April 20, 2018, following the Securities and Exchange Commission’s (SEC) introduction of “Regulation Best Interest” and related conflict of interest reform proposals, the Financial Industry Regulatory Authority (FINRA) issued its own Regulatory Notice 18-13, seeking comment on proposed amendments to the “quantitative suitability obligation” under FINRA Rule 2111.

According to a Law Alert publication shared by Wagner Law Group, under Rule 2111, quantitative suitability requires a broker who has control over a customer’s account to have “a reasonable basis for believing that a series of recommended transactions is not excessive or unsuitable for the customer, although the individual transactions may be suitable when viewed in isolation.” As the Wagner attorneys note, the element of control in this requirement “may be evidenced by actual or de facto control.” If the broker does not control the customer’s account, however, the quantitative suitability obligation is not triggered, the attorneys explain.

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With its latest proposal, FINRA suggests it may “remove the element of control from Supplementary Material .05(c) of Rule 2111 in order to better address instances of excessive trading, sometimes referred to as churning.”

“From FINRA’s perspective, the rationale for the amendment is threefold,” the Wagner attorneys suggest. “First, the original basis for requiring the control element is rooted in the perceived need to ensure that culpability for excessive trading was attributed to the individual initiating the transaction. Since the rule requires a showing that the broker is the recommending party, the concern simply is not present under the rule. Second, FINRA is concerned that the control element has been or may be used as a shield for brokers engaged in excessive trading. The third reason is FINRA’s consideration of the SEC’s Regulation Best Interest.”

According to the Wagner attorneys, SEC’s Regulation Best Interest also includes a prohibition on excessive trading, but it excluded the control element. Importantly, the comment period for the amendments to Rule 2111 expires on June 19, 2018, giving readers less than a month to weigh in.  

“Although many firms have existent supervisory policies in place with regard to churning activity, it would be timely to review and consider an update to such policies, especially where the element of control is not clearly defined,” the attorneys warn.

Taking a deep dive into FINRA Regulatory Notice 18-14

Turning to a separate but also relevant matter, the Wagner attorneys weigh in on FINRA Regulatory Notice 18-14, issued shortly after Notice 18-13.

“Notice 18-14 announces the retrospective review of Rule 3110(a)(7) and Supplementary Material .04 (Annual Compliance Meeting), which requires each registered representative and registered principal to participate in an annual interview or meeting at which compliance matters relevant to the individual are discussed,” the attorneys observe.

Under the relevant FINRA rules, a broker/dealer firm is not required to hold an in-person meeting for this purpose.

“However, if the compliance meeting is conducted by using another method (e.g., on-demand webcast, video conference, classroom, telephone or electronic), each registered person must attend the entire meeting, and the firm must ensure that registered persons are able to ask questions and receive answers in a timely fashion,” the attorneys add. “FINRA is seeking comments to six specific questions set forth in Notice 18-14. The questions relate to whether the rule has been effective, registered individuals’ experience with the implementation of the rule, the rule’s economic impacts such as the cost and benefits of the annual meetings, and asks whether FINRA can make the rules, interpretations and administrative processes more efficient and effective. FINRA also invited comments on any other aspects of Rule 3110.”

Readers may also note that FINRA is concurrently reassessing its requirements for RIAs to monitor the outside business activities of their reps; experts argue it is likely that, if the final rule reflects the proposed rule, many plan advisers who serve plans through an independent registered investment adviser (RIA) (as opposed to the broker/dealer’s “corporate” RIA) will seek to renegotiate their compensation arrangements relating to their independent RIA revenue.

The FINRA Regulatory Notice comment portal is here.

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