McDermott Will & Emery law firm is releasing a new program to help retirement plan sponsors comply with plan document requirements.
The McDermott Retirement Plan Compliance Program is a new opinion letter and operational review program for individually designed 401(a) and 403(b) retirement plans, which will allow plan sponsors to document their plans’ compliance with tax code requirements in response to the curtailment of the Internal Revenue Service’s (IRS’) determination letter program.
Against the background of strong equity market performance in
the last seven or eight years, passive target-date funds now account for 42% of
the TDF market, compared with 27% in 2009.
The second day of the 2017 PLANADVISER National Conference
in Orlando featured an extensive conversation on the difficult topic of
measuring target-date fund (TDF) performance.
Including the moderator, the panel discussion featured a
team of five retirement plan industry veterans: Brooks Herman, vice president,
data and research, Strategic Insight; Joe Szalay, vice president for defined
contribution (DC) investment strategy, BlackRock; Todd Leszczynski, managing
director, MFS; Derek Young, head of investment client strategy, vice chairman,
Fidelity Institutional Asset Management; and Todd Lacey, chief business
development officer, Stadion Money Management.
As the panel laid out, passive strategies now account for
42% of the entire TDF market, compared with 27% in 2009. This growth in passive
approaches is coming from large and jumbo plans looking to reduce fees, mainly,
but it also extends into the midsize and smaller DC plan market. The panelists
voiced some concern about this fast growth and questioned whether plan sponsors
understand what could happen to passive TDFs during a sharp market downturn.
Alongside the trend of a strong shift toward passive
management, the use of collective
investment trusts (CITs) as a means of target-date investing continues to
grow, with 52% of net TDF assets now invested through this type of vehicle. There
is also some emerging evidence that the use of exchange-traded
funds as the basis for target-date portfolios is increasing, though far
more slowly than that of CITs.
The panelists all agreed that, while TDFs are known for
their simplicity of use, this is something of a mischaracterization. It is true
TDFs are relatively easy to use from the participant perspective, but there is
a significant amount of preliminary and ongoing analysis required of the plan
sponsor and the adviser to ensure the appropriate TDF strategy is put in place.
Some of the panelists seemed to favor the approach of offering multiple glide
paths to a given plan population within the same target-date product family,
while others were more comfortable with the idea of finding a single,
middle-ground glide path for the plan population. In either case, the panelists
agreed that the adviser has a crucial role to play in helping sponsors identify,
consider and ultimately select the best TDF approach for their plan.
Important to note, the panelists mainly agreed that the only
trend that may slow the growth in TDFs would be growth in managed accounts. They
stressed that there is an emerging conversation about pairing
TDFs and managed accounts together on the plan menu to serve people with
simpler needs vs. those with more specific, individual needs. The idea is that
a newly employed 25-year-old with his first DC account probably will be better
served by a TDF, whereas older workers with greater amounts of retirement
savings could be better served by managed accounts.
Other topics that were broached during the panel discussion
included the unfortunate fact that many plan sponsors utilizing passive
target-date funds believe that doing so absolves them of fiduciary responsibility—a
completely inaccurate assumption that advisers should combat. Further, the
panelists considered the relative importance of screening the target-date fund
as a whole compared with screening
the individual investments built into that TDF. Especially when proprietary
options are being used, there may be investments within the TDF series that
would not necessarily pass a plan sponsor’s scrutiny were they considered on
their own as stand-alone options for the core menu.