IMHO: The Deification of DB-ification

Last week, I stumbled across another of those “DC plans are becoming like DB plans″ articles—you know, the “DB-ification″ of 401(k)s?
This is all supposed to be a good thing, of course, because we know that defined benefit plans do a better job of providing adequate income in retirement than defined contribution plans (well, properly funded, and when workers accumulate adequate service credits, anyway). Moreover, the new Pension Protection Act-engendered trends toward auto-enrollment (nobody asks people to fill out a form to be covered by their DB plan) and asset allocation fund defaults (nobody asks participants to make the investments in the DB plan) are also widely touted as DB innovations that we have finally had the good sense to bring to the DC side of the world.
Don’t get me wrong—anything that turns employees into participants (and automatic enrollment surely does that) and helps them make better investment decisions (and, generally speaking, asset allocation solutions fulfill that need) has to be a good thing. But to suggest that these trends are essentially helping our DC programs mature into their more “responsible’ DB counterparts represents, IMHO, a gross misinterpretation of what is going on.
The most obvious difference, of course, is that DB plans not only don’t ask employees to sign up or make investment decisions—they generally don’t ask participants to FUND them, either. In a DB plan, all the participant has to do is—well, they don’t have to do anything (other than continue to meet the eligibility requirements for the plan, and that’s generally been a natural outgrowth of keeping your job). Some might argue that that lack of involvement contributes to what continues to be a widely evidenced lack of appreciation for the benefit.
Another Difference
There is another big difference, of course, and it also has to do with how these plans are funded. Defined benefit plans are funded—at least, they are supposed to be—with an eye toward the benefit that will be paid out. As the name suggests, the benefit is defined—and the decisions that are made about how much to contribute to the plan and how those contributions will be invested are also done with that in mind.
Defined contribution plans, on the other hand—even the “new,’ “automatic,’ DB-ificated ones—have an entirely different focus. They are (still) about how much you can afford to put into them, not how much you need to get out of them. Oh, sure, the PPA’s safe harbor automatic enrollment includes a provision to increase those contributions on an annual basis—but starting at just 3%, and rising only to 6% of pay. That may well be all that many can afford to contribute—but is it any replacement for the kind of funding discipline that a true defined benefit focus represents? More importantly, will it be enough to provide the same kind of retirement security that the DB system promised?
Still, this notion of DB-ification keeps popping up. As though, through the graces of the PPA, we have managed to magically replace that missing leg on the three-legged stool of retirement security—when all we have really done is stick a piece of cardboard under one of the two remaining.
IMHO, we won’t really have a “DB-ification’ of our defined contribution designs until we shift the focus—not just the funding. And maybe not then.

ERISA Expert Discusses Plan for Successful Retirement Plans

According to Fred Reish, there are three main components to a successful retirement plan.
Reish, an attorney with Reish Luftman Reicher & Cohen, discussed the future of participant directed plans last week with attendees at the Retirement and Benefits Management Seminar in Charlotte, North Carolina. He told attendees that a successful 401(k) plan is one that provides adequate and broad-based retirement benefits. Fiduciaries are required by ERISA to engage in a prudent process for the exclusive purpose of providing retirement benefits – and successful benefit levels provide the same standard of living in retirement as during their working career, Reish said.
However, it can be difficult to gauge that measure of success, Reish said. Therefore, he suggested three pillars of a successful retirement plan, all of which can be measured; participation levels, deferral rates, and the quality of participant investing.
The industry needs to do better when it comes to participation rates and deferral rates, according to Reish. The national average of eligible employees who participate in their retirement plan is about two thirds – this was great when 401(k) plans were supplemental savings plans, he said, but lousy for retirement plans. Automatic enrollment will be a significant help for this, he believes, because the program works without upsetting employees.
As for deferral rates, people can defer less if they are going to work longer, but the industry has not done a good job of helping people understand what they need to save in order to retire at various ages. “The industry doesn’t tell you that you need to be deferring 9.7% in order to retire at 65,” Reish commented.
When it comes to quality of participant investing, Reish suggested that a good measure of success is whether half of new dollars going into a plan are in asset allocation funds. ERISA is predicated on a belief that participants are using modern portfolio theory to make their investment selections, Reish said, but in actuality, no one is doing this. Employees therefore, in order to ensure quality investing, should be using one of the asset allocation solutions, he said.
Part of this will be helped by the implementation of the qualified default investment alternatives (QDIAs), he told the audience. Reish said that he does not believe stable value will be added back into the list of allowed options, although he does believe that asset allocation models will come back into the list, especially because they are available for a very low cost for large plans, something that fits with the Department of Labor’s recent interest in plan fees. Although the proposed regulations did not specifically include lifestyle funds (risk-based asset allocation funds), Reish said that they can be included as part of the balanced fund option. However, plan sponsors will not be able to put people into a suite of them, instead they will have to pick one of the four or five options that fits their workforce demographic, and that will most likely will be the middle risk option, he suggested.
In fact, QDIAs coupled with automatic enrollment are going to change the 401(k) market; not only can they be used as traditional and automatic enrollment defaults, but can be used for mapping and in conversions. Additionally, they can also be used as re-enrollment defaults, Reish said, where the participants are all moved into the default fund unless they elect otherwise.

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