The paper analyzes the source and magnitude of the problem,
along with the legal and financial ramifications for sponsors if not addressed
effectively.
Speaking at a conference earlier this year, Susan M.
Halliday, senior benefits law specialist with the U.S. Department of Labor
(DOL), mentioned an advisory opinion letter in which an attorney argued that,
once a distribution is made from the plan, the money is no longer considered
part of the plan assets. The DOL disagreed, implying it considered benefits
plan assets until a check is cashed or a wire transfer is successfully made
(see “Unanswered Questions About Uncashed Checks”).
“After providing notices to participants that, if they do
not make an election for distribution, their accounts will be automatically
rolled into an individual retirement account (IRA), how long should plan
sponsors or recordkeepers wait for a response,” Janice M. Wegesin,
president of JMW Consulting Inc., queried during the same presentation.
Wegesin said this is not a small problem, since estimates
show that the highest average uncashed benefit check amount is around $42,000.
So, with a lack of guidance, it is a good idea for plan sponsors or
recordkeepers to establish written procedures for handling uncashed checks.
“Data from across the country shows that the problem of
uncashed checks represents a serious and growing dilemma for retirement plan
sponsors,” says Terry Dunne, Millennium Trust senior vice president and
managing director of the Rollover Solutions Group. “With administration costs
continuing, escheatment not being an option in many cases, and the threat of
possible fines and lawsuits increasing the longer plan sponsors fail to follow
through on their responsibilities, it becomes clear that automatic rollover
IRAs provide an easy solution to the problem,” he contends.
Millennium Trust was one of the first to offer an extensive
suite of automatic rollover services Millennium Trust’s automatic rollover
service is designed to help plans meet the DOL’s safe harbor requirements for
the automatic rollover of plan assets to IRAs.
To
receive a copy of the research paper, contact Diane Pressley at 630-368-5614 or
dpressley@mtrustcompany.com.
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A quick review of the marketplace shows why 401(k) plans can
be an attractive business space. Sixty percent of U.S. households reported participation
in an employer-sponsored retirement plan in May 2012, according to the
Investment Company Institute[i].
The ICI also found that American workers were holding $3.5 trillion in 401(k)
plans at the end of 2012[ii].
401(k) Plans – An
Opportunity or Administrative Burden?
With figures like that, it’s easy to see why advisers have
always viewed the 401(k) space as a market with ample opportunity. The 401(k)
market offers advisers the chance to add more clients, increase AUM and, above
all, work directly with plan participants toward their dream retirement
scenario.
However, many advisers are hesitant of the space due to the
hurdles of running a successful 401(k) practice. It’s laborious for advisers,
who often find themselves filling all the roles from plan maintenance to
relationship management; the administrative duties are never-ending; and for
all that work, advisers may find themselves in the role of fiduciary to the
plan, something few want. These seemingly unavoidable obstacles have caused
some advisers, particularly those focusing on small plans, to limit their work in
an otherwise attractive market.
Small Plan Advisers
at a Disadvantage
Small plan advisers are at a disadvantage when it comes to
building a successful 401(k) practice. Regardless of plan size, advisers must
complete the same list of tasks, including investment selection, benchmarking,
enrollment meetings, and so forth. Due to the cost involved with these
functions, both in time and resources, many advisers focus on retirement plans
with substantially larger assets, and utilize specialists or outside consultants
to make the process more manageable.
Small plan advisers who don’t want to change their overall
business model, or who don’t have access to the same resources often struggle
to perform the necessary functions for their retirement plan clients.
Additionally, the services they provide may place them in a fiduciary role,
though they may not want to act as such. All of which can prevent small plan
advisers from spending time working with participants in the plan, an area
considered essential by their plan sponsor clients.
According to a recent survey of defined contribution plan
sponsors by Cogent Research, more than one-in-four small plan sponsors who work
with advisers were not satisfied with how accessible advisers are to
participants, and three-out-of-ten were not satisfied with how advisers are
educating participants about the plan and its investment options[iii].
[i] “The
Role of IRAs in U.S. Households’ Saving for Retirement, 2012,” Investment Company
Institute (2012)
[ii] “The
U.S. Retirement Market, Fourth Quarter 2012,” Investment Company Institute
(2013)
[iii]
“The Hidden Value of DC Advisors,” Cogent Research (2013)
An opportunity exists for small plan advisers who can
dedicate more time to direct participant interaction and service. To do so,
however, would require a shift in how small plan advisers have traditionally
handled their 401(k) business. Advisers are increasingly looking to turnkey
administrative solutions that offer relief from time-consuming activities and
remove them from the fiduciary role in order to create more time for
participant interaction and services.
Nuts and Bolts of
Turnkey 401(k) Solutions
These increasingly popular solutions often combine some
aspects of third-party investment management, benchmarking reports and plan administrative
support, all of which are necessary for small plan advisers to succeed. While many
turnkey solutions look alike, most are not. Advisers should review available turnkey
solutions for their clients and for their practice to make sure those under
consideration provide the investments and services that meet their collective
needs.
Three essential components that should be reviewed in any
program are:
§
Third-Party
Investment Management – The selection and monitoring of an investment
line-up usually places the adviser in a fiduciary role for the plan. Additionally, it’s a time consuming process
especially when factoring in the need to establish review criteria and document
a regular review process. A key consideration for advisers and their clients is
the level of fiduciary coverage available with a turnkey solution provider. Not
all offerings are created equal and may include varying levels of fiduciary coverage,
but some options exist where the third-party manager assumes a significant
portion, if not all, of the investment fiduciary responsibility and accepts
liability for investment option decisions.
§
Benchmarking
and Analytics – Managing the investment lineup for a client’s plan isn’t
the only task that can be incredibly time consuming—benchmarking is another necessity
that can divert time away from providing participant services. In a turnkey
program, advisers may be offered benchmarking services to ensure clients are being
offered high-quality funds and services at a reasonable cost. Benchmarking provides
a value-added service and helps to reassure clients that advisers have their participants’
best interests in mind.
§
Administrative
Support – An adviser’s goal is to help plan participants prepare for a
dream retirement, not to spend hours upon hours of time managing compliance and
regulatory requirements. While it’s impossible for advisers to completely avoid
paperwork, turnkey solutions can make the overall process more efficient. Most
programs offer a single point of contact for advisers to expedite questions, an
easy or pre-filled enrollment process, or a variety of other back office
activities. Streamlining the support process reduces the burden advisers face
and turns a 401(k) plan from a questionable value proposition into an
opportunity to increase participant interaction and grow their practice.
Putting Participants Back
in Focus
Leveraging turnkey solutions enables advisers to return
their attention to the single most important aspect of all 401(k) plans—the
participants. The more free time advisers can generate on the back-end, especially
by lessening the administrative burden, the more time can be devoted to working
with individual participants, gaining new retirement plan clients, contacting
referrals and cross-sell opportunities.
Turnkey solutions may provide win-win scenarios for advisers
looking to build a thriving 401(k) practice—more free time for participant
interaction and a better business model all in a single, easy-to-use offering.
Kevin Watt, AIF® and Vice President of Defined Contribution
Markets, Security Benefit
For more information about this topic please contact
Security Benefit at 800-747-5164, Option 6.
FOR FINANCIAL
PROFESSIONAL USE ONLY
Services are offered through Security Distributors, Inc., a subsidiary of Security Benefit
Corporation (Security Benefit).