Considerations for DC plan sponsors
Summary
Although the “great resignation” or “great rethinking” appears to have nearly run its course, benefit teams have not seen much relief and continue to be asked to do more with less. Elevated turnover is having an impact on committee membership, retirement plan staff and institutional memory.
Employees continue to report that one of their top concerns is being able to retire. As a result, investment committees will have to dig deeper into their investment offerings. They need to evaluate the potential for unintended risks, and find new opportunities through avenues such as private investments.
In addition, prompted in part by the SECURE Act 2.0, sponsors should look more strategically and holistically at what they offer participants, including cost-effective income solutions that help get participants to and through retirement.
Another challenge comes from the development of more sophisticated and more insidious cyber and data risks. These, when added to continued fee litigation, are prompting many plan sponsors to consider risk management through a new governance lens — just as they are weighing the challenges and opportunities presented by Artificial Intelligence (AI).
This paper offers ways for sponsors to align their investments — and their plan design features and operations — to match the evolving needs of participants.
What percent of employers rate their employees’ financial wellbeing as a high concern in 2023 vs 2022?
2023
2022
Considerations for DC plan sponsors
What are you getting from your investment providers?
However, an important and sometimes overlooked step involves looking at how subtle changes to investment strategies are being affected by evolving capital markets.
Similarly, it is important to look for any unintended consequences as industry dynamics and cost pressures drive change. In light of these concerns, the following shows four areas we believe warrant closer examination.
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US large cap growthThe appreciation of growth stocks has continued, creating diversification and operational concerns for some investment managers. Many managers prudently limit their allocations to individual securities at a certain level (or are required by the US Securities and Exchange Commission (SEC) classification of their investment funds to act in this way). As a result of risk controls, active large-cap growth managers may be forced to underweight high-conviction names relative to market-cap-weighted indices, or to reclassify their funds from diversified to non-diversified. It is therefore important to understand whether this is an issue for your large-cap growth option and to consider how best to release the pressure valve if needed.
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An increasing number of DC plans offer managed accounts, as sponsors seek to respond to participants’ desire for advice. Not surprisingly, new proprietary managed account offerings from recordkeepers are therefore on the rise. However, not all models are created equal and there can be notable portfolio impacts for participants. Understanding the portfolio creation process, especially the nature of investment allocations, is therefore critical as these solutions can vary significantly. Additionally, fiduciaries should be wary of being lured by “low-cost” options. They should understand how such solutions differ from those being put forward by other providers and evaluate the impact they will have on overall administrative fees.
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Target-date fund providers continue to look for unique ways to address the interest of participants and plan sponsors in retirement income, personalization and environmental, social and governance (ESG) offerings. Many providers are aiming to offer a target-date flavor to meet different participant needs. This is being done in the hope of gaining or maintaining market share in this increasingly competitive space. We believe target-date funds set up with an eye towards facilitating decumulation in a way that feels customized, and which also includes an income stream, will gain interest in the near future. As this is the default of most DC plans, it is critical for plan sponsors to evaluate how their target-date provider and others are evolving their relevant glidepaths and strategies.
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Capital preservationThe recent swift increase in rates, and the current high interest rate environment, have both benefitted money market funds. At the same time, by design, stable value funds have seen a more gradual increase in crediting rates. This has led some sponsors to question whether the addition of money market, with or without the elimination of stable value, is warranted. The current interest rate environment is also bolstering yields in other DC plan fixed-income options. This factor should also be taken into consideration in conjunction with capital preservation options. We encourage fiduciaries to consider the longer-term interest rate environment, which is expected to benefit stable value. They should also consider the complexities of offering multiple capital preservation options before taking any action.
Is there any juice left to squeeze?
Labor markets have shifted rapidly over the past few years. Now that we are on the other side of the “great resignation,” companies are looking for opportunities to reduce expenses and enhance resource efficiency.
Benefit teams are being asked to do more with less. At the same time, elevated turnover is having an impact on committee membership, retirement plan staff and institutional memory.
72% of respondents say that inflation and volatility have increased their levels of stress
25% of institutional asset owners plan to use OCIO for the first time or to expand their OCIO relationships in the next 24 months.1
Are you thinking like a participant?
Participants may not think of their financial resources in the same way that benefit programs are structured, which may lead to lower adoption of these programs. At the same time, employers are continuing to provide new financial wellness benefits for their employees often through separate point solutions.
As the links between long-term retirement benefits and shorter term financial needs strengthen, point solutions will need to become more encompassing if they are to truly add value. Furthermore, framing your benefit offerings to align with participant needs will be key as DC plan features and other benefits continue to evolve to address broader financial needs.
To ensure that efforts to address employees’ needs do not get ignored, it is important to have a thoughtful, holistic approach to communications and engagement . This is important as messaging included in off-the-shelf materials may not be effective or aligned with your organization’s broader strategy . Having an annual planning session and reviewing materials regularly may help improve the overall effectiveness of your participant outreach .
The opportunity to expand DC plan design sparked by SECURE 2.0 could also prompt you to take a strategic look at what you offer to participants . Ask the following types of questions:
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How will the changes required under SECURE 2 .0 affect your current retirement benefits?
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How will the necessary and optional changes align with your other benefit offerings?
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Are any changes that you are considering duplicative with an existing offering?
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Are participants better served by a different offering outside of the DC plan?
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What is the cost/benefit of individual financial wellness benefits if they are delivered through the broader DC plan?
How will you navigate their retirement income needs?
The design of DC plans and communications, along with the mainstream media, have encouraged DC plan participants to leave assets in their prior employer’s plan after termination or retirement.
Most DC plans and committees are well versed in structuring prudent plans for the accumulation phase of the retirement savings journey. However, many have yet to develop an approach for supporting participants as they transition to and through retirement.
Some of the largest target-date fund providers are already live, or are in the process of launching guaranteed income variations of their target-date suites. Managed account providers are offering customized guidance and advice for the drawdown period. Employees of all ages want guidance and help.
We therefore anticipate that evaluating retirement income solutions will become a requirement for plan fiduciaries within the next five years.
Who wants access to retirement income options?
Does your DC plan need a chief risk officer?
The risks DC plans face continue to grow and change. This means that the processes for managing those risks must also evolve. At times, it may feel like you need an expert on DC plan risks solely to keep pace with developments and avoid any missteps.
Cyber and data risk management have taken center stage recently and we anticipate that both the number and level of threats will increase as bad actors learn how to use AI.
It is also important to highlight that ERISA plans are carved out of most corporate cyber insurance policies. We believe that this is an emerging focus for insurance and will be a new type of offering alongside fiduciary liability insurance.
Similarly, lawsuits are becoming more nuanced. We saw the first jury trial for an ERISA case in 2023. There has also been a recent suit relating to ESG use through brokerage windows. Fees continue to be one of the main sources of litigation. However, cases are now going farther than they did previously. They are now considering managed accounts and other plan features. They are even moving into nuances of plan administration. Virtually all areas of DC plans are potential targets for litigation. This underscores the importance of ensuring that plan administration and governance procedures are well established and well documented.
The arrival of AI — how can you keep pace?
As a result of the rapid growth and integration of AI into daily life, we believe changes will follow in how retirement benefits are consumed, and how DC plans are administered.
Data storage, analysis and access will also evolve
Recordkeepers that have not already migrated to the Cloud (or even started the process) are already behind the curve. Those who do not integrate the capabilities of AI into the analysis and provision of comparative plan information will struggle to engage plan sponsors. They will also lag in the development of participant tools and solutions.
The growth of AI should mean that data accuracy will improve and that transitions from different administrative platforms will become smoother and easier to execute. On the flip side, better out-of-plan consumer experiences and customization — without the confines of ERISA — may lead to reductions in the retention of former participants’ assets. However, this will provide opportunities for multiand pooled-employer plans to fill those gaps and also help set the standard of participant experience with their greater combined resources.
Sponsors should keep a close eye on how plan service providers are preparing for and integrating AI into their offerings. This should lead to open and productive dialogues about the issue.