IMHO: Mixed Messages

We had wrapped up a very successful half-day adviser event ahead of our annual Awards for Excellence dinner last week.   

As we closed up the session, a co-worker of mine commented to me as an aside, “Nobody ever told me I needed to be saving 12% before.” 

Now, this co-worker has nothing to do with our magazines, or the content that fills our Web sites and newsletters.  He just happens to work at a company that, among other things, publishes information about retirement plans.  He’s a participant in our benefit plans, of course—and so he has probably been exposed to all the same types of education and savings materials as anyone (perhaps more).  He’s a smart guy (he’s pursuing his MBA at night), tech-savvy, and he pays attention.  And yet, it wasn’t till he was effectively sitting there as a fly on the wall in a room full of the nation’s best retirement plan advisers that he overheard someone put forth a specific savings-target figure. 

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Now, like any good plan sponsor, I can explain that.  I don’t know his individual financial circumstances (I’d have to “work” even to find out how much he’s saving at present), have no idea when he plans to retire, and can’t possibly guess at the viability of Social Security or other resources at that date.  He may marry “well,” he may have a rich uncle—heck, he might even win the Lottery.  I can tell you that his employer offers a solid 401(k) plan, with a robust investment menu (reviewed on a regular basis with our financial adviser), a generous match, access to both managed accounts and target-date funds, and the opportunity for him to sit down with a financial adviser (paid for by his employer, I might add) or get a consult via the phone, as well as through an assortment of Web-based tools.  Looking over the plan’s structure, administration, and fees, it’s hard not to feel that (in the words of the Lone Ranger), “Our work here is done.”

Except, of course, it obviously isn’t.

Now, I don’t know that 12% is the right answer in his individual case.  For all I know, that’s still not going to be “enough”—or, based on the combined results of the aforementioned individual circumstances yet to be discerned, it might be way too much.  Obviously, there are many logistical impediments to us divining with precision what the “right” amount is for every individual situation (including our own). 

That said, IMHO, any number of plan design features convey a different message to participants.  A significant number of plans still don’t provide for an automatic (or even immediate) enrollment.  Those who do generally default employees into these programs at a mere 3% of pay, which, in most plans, isn’t even enough to qualify for the full match.  Many plans match those deferrals only up to 6% (or less), auto-accelerate at just 1% increments, and—if we’re rigidly adhering to the outline provided in the Pension Protection Act—probably cap those automatically accelerated deferrals at 10% of pay.    

We all know that the motivations for those plan designs are nearly as varied as the plans that employ them: They represent the plan sponsor’s sense of a competitive benefit structure, they match the expectations of their current workforce, or perhaps they are simply what the employer can afford at any particular time.  Yet, we all see evidence every day that participants read into these structures a kind of “code” that these are the “right” answers to provide them with a financially secure retirement, rather than representing decisions made for reasons that, while generally sound, are completely unrelated to ensuring individual retirement security.  

We’ve long held off giving people a specific target for savings, for a host of real and legitimate reasons.  I wonder if the time hasn’t come to put a target out there for participants—one that might not be precisely the “right” number for every individual situation, but one that will give them something to aim for, rather than continue to duck the issue and hope for the best.   

It’s a message that I think participants are ready for—and there’s no time like the present.

Regulators Propose ABS Credit Risk Retention Rule

Federal agencies are seeking public comment on a proposed rule that would require sponsors of asset-backed securities (ABS) to retain at least 5% of the credit risk of the assets underlying the securities.

The Securities and Exchange Commission (SEC) said the proposal would not permit sponsors to transfer or hedge that 5% credit risk. In crafting the proposed rule, six agencies sought to ensure that the amount of credit risk retained is meaningful, while reducing the potential for the rule to negatively affect the availability and cost of credit to consumers and businesses.

The rule is proposed by the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the SEC, the Federal Housing Finance Agency, and the Department of Housing and Urban Development. It would provide sponsors with various options for meeting the risk-retention requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Among other things, the options include:

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  • Retention of risk by holding at least 5% of each class of ABS issued in a securitization transaction (also known as vertical retention).
  • Retention of a first-loss residual interest in an amount equal to at least 5% of the par value of all ABS interests issued in a securitization transaction (horizontal retention).
  • An equally-divided combination of vertical and horizontal retention.
  • Retention of a representative sample of the assets designated for securitization in an amount equal to at least 5% of the unpaid principal balance of all the designated assets.
  • For commercial mortgage-backed securities, retention of at least a 5% first-loss residual interest by a third party that specifically negotiates for the interest, if certain requirements are met.

As required by the Act, the proposal includes descriptions of loans that would not be subject to these requirements, including asset-backed securities that are collateralized exclusively by residential mortgages that qualify as “qualified residential mortgages” (QRMs).

The proposal would establish a definition for QRMs — incorporating such criteria as borrower credit history, payment terms, and loan-to-value ratio — designed to ensure they are of very high credit quality. The proposed rule also includes investor disclosure requirements regarding material information concerning the sponsor’s retained interests in a securitization transaction. The disclosures would provide investors and the agencies with an efficient mechanism to monitor compliance with the risk-retention requirements of the proposed rules.

The proposed rule also has a zero percent risk-retention requirement for ABS collateralized exclusively by commercial loans, commercial mortgages, or automobile loans that meet certain underwriting standards. As with QRMs, these underwriting standards are designed to be robust and to ensure that the loans backing the ABS are of very low credit risk.

The proposed rule would also recognize that the 100% guarantee of principal and interest provided by Fannie Mae (the Federal National Mortgage Association) and Freddie Mac (the Federal Home Mortgage Loan Corporation) meets their risk-retention requirements as sponsors of mortgage-backed securities for as long as they are in conservatorship or receivership with capital support from the U.S. government.

The agencies are requesting public comments on the proposed rule by June 10, 2011, which can be made here. The rule is at http://www.sec.gov/rules/proposed/2011/34-64148.pdf.

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