Managing Assets Within the Plan

This PLANADVISER In-Depth story considers the new ways financial advisers are seeking to manage participant 401(k) accounts before they’ve rolled out.

Fraj Lazreg was giving clients financial advice before 401(k)s existed. Now, he’s spreading the gospel to peers about the pressing need to manage the often large sums of money clients hold in their defined contribution plans.

“Things changed drastically over the decades, which comes with complications,” says Lazreg, who is regional director and portfolio manager with Money Concepts. “When 401(k) plans proliferated and became the vehicle for retirement … we saw the writing on the wall as to what needed to be done.” 

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Part of that activity was helping clients maximize their 401(k) investments alongside other assets. But Lazreg and other registered investment advisers note that advice about 401(k) plans has often been given in an ad hoc, back of the envelope fashion—sometimes requiring the client to execute the transactions.

“It was not done in a systematic way where the client can get the maximum benefit out of their plan,” Lazreg says.

Meanwhile, DC assets keep rising, and some data points to participants staying in plan longer. Managed accounts are one way for participants to get in-plan management and advice. But for those paying for financial advisers, DC plan services are—perhaps paradoxically—lacking, says Dave Goldman, Pontera’s chief business officer.

“When you get into the 401(k) space what you realize is that there are solutions for everybody in the plan except for the top 30%, or the people that have financial advisers, because you have target date funds and you have managed accounts,” he says. “But when you get to people who already have financial advisers, they are the ones struggling to get the holistic advice—so it’s upside down from that perspective.”

Today, firms, such Pontera and Future Capital, are offering the connection to 401(k) plan management. There’s also the more time-tested option of advisers working through a self-directed brokerage account, but only about 20% of plans offer that option, according to the 2024 PLANSPONSOR DC Benchmarking Report.  

After looking at options, Lazreg went with Future Capital, he says, in part because the firm was offering to manage the assets within the plan, not to take them over.

“It benefits the client, but also, in the long run, it benefits the adviser because at some point in time, that client will stay with you if the service is good,” he says. “You’re looking at the 401(k) not as an investment vehicle by itself but a total compensation plan for the client that includes everything else … at some point in time that becomes assets under our management for rollover purposes.”

Fiduciary Implications

Lazreg notes that he is aware of and supports the new fiduciary rules by which managing a rollover can only happen under the Employee Retirement Income Security Act. In the meantime, Future Capital provides the fiduciary overlay for in-plan management.

Jay Jumper, the CEO of Future Capital, touts its RIA services. Many advisers, he says, aren’t equipped to manage clients’ 401(k) assets not only due to time and technology restraints, but risk from running afoul of fiduciary obligations.

“We’re a fiduciary,” Jumper says. “We’re coming on and engaging with the customer, taking on the fiduciary liability and managing the portfolio …. most broker/dealers are not wanting their advisers to have full discretion over customer assets, especially when they can’t surveil them because they are at Fidelity, Empower, Voya or wherever they may be.”

Jumper points to the vast and what he sees as growing market of DC savings that currently aren’t being served by advisers.

“Of households with between $100 million to $2 million of liquid net worth, 56% of their assets are in retirement accounts,” he says. “That means 56% of their assets are unreachable by the adviser.”

Historically, Jumper says, the only way advisers had to reach these assets was through managed accounts or the recordkeepers. The shift in the market, he notes, is that now many of those recordkeepers are going after the same pool of clients—and in many ways, they’ve got the better positioning.

“It’s kind of the Trojan horse,” he says. “A lot of people are going out and building out wealth assets, and they are creating whole divisions …. They are going out to advisers and saying, ‘I’ve already got your book of business. I’ve already got your customers.’”

Partner Up

Future Capital isn’t only working through wealth managers. The firm also works with retirement plan advisers as an offering direct to participants via the plan.

“We work with retirement plan advisers who are out selling plans to work with them to engage all the participants to get them on a customized plan to meet their retirement goal,” Jumper says. “For every dollar in a plan there is typically $3 to $5 of outside assets. What we help do is go engage with participants to identify those outside assets.”

Pontera, one of the most visible players in the space, provides financial advisers with the technology by which to monitor and allocate 401(k) investments. With its model, RIAs can be trained to use the service and then leverage it as an additional offering to clients.

The market interest has been clear from the results: Pontera has penned 32 partnerships since 2022, including firms with large footprints in the retirement plan and wealth world, such as CAPTRUST, Commonwealth Financial Network and SageView Financial Advisers. These are just the deals the firm has announced publicly, says Pontera’s Goldman.

“There’s about 85 million workers and $7.2 trillion of 401(k) assets,” he says. “It’s clear to our partners and to a lot of participants that these assets, although they are a significant portion of retirement savers’ nest eggs, are not getting enough attention—and the advisory firms and the participants are both seeing the same thing.”

Goldman says advisers have been providing 401(k) management for many years, but in his opinion, it’s a “cumbersome process” with layers of complexity and cost. Pontera, he says, is “not a new service, but just a more secure framework.”

Pontera charges an asset-based fee to the advisory firms using its services. Firms, like SageView, which signed on with Pontera in 2022, have been putting it to use in the field.

Adviser Use

“Previously, allocation advice was based on a static set of data that the client provided via statements or screenshots,” says Nick Lamb, senior financial adviser at SageView. “Now, we can view and manage our clients’ held away accounts in real time. In addition, the client gets the benefit of having investible assets professionally managed.”

Lamb says the ability to offer 401(k) and 403(b) is not just good for current clients, but prospecting.

“We are finding that some clients prefer a firm that can handle all their investments, including held away accounts,” he says.

Commonwealth is currently training some of its advisers on using the Pontera platform and will start rolling out services this summer, says Karen McColl, senior vice president, wealth management.

“We were having a lot of conversations with advisers that felt like they weren’t getting the full financial picture from their clients,” she says. “For a lot of folks their great source of wealth is in their current retirement plan; we wanted to make sure there would be this systematic way to see what was in those accounts and help incorporate them into the full financial plan.”

McColl notes that, when talking to Pontera, they were drawn to data showing that an individual who gets professional management of their DC investments outperforms those without management by an average of 4% after fees.

“The missing part for us is allowing the adviser to set the asset allocation and do disciplined rebalancing, see inside the plan lineup, decide what the plan lineup will be, establish exposures, establish rebalancing schedules,” she says. “The adviser can be a lot more strategic around those different pockets of assets but still have the overarching approach to view everything together.”

More on this topic:

Participant Data and the Race for Ownership
Financial Wellness Moves From “Nice to Have” to Table Stakes
Recordkeepers and Participants: An Evolving Relationship
By the Numbers: Participant Retirement Saving Strategies & Outcomes

Roth in Reality

Further guidance is needed for recent federal retirement legislation as industry faces implementation.

Plan advisers and sponsors facing implementation of new rules outlined in the SECURE 2.0 Act of 2022 are up for a challenge— and experts say they’ll need further guidance from the IRS to make the Roth provisions a reality.

The federal retirement legislation made post-tax contributions to retirement plans more prevalent with two changes: As of 2024, employers can make matching contributions directly to Roth 401(k)s, and starting in 2026, high-income earners must make catch-up contributions Roth-based.

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These Roth provisions are a top focus for plan advisers,  from Cogent Syndicated and Escalent. But experts say the IRS hasn’t yet provided enough information for the industry to fully put these provisions into practice.

“There is a lot [unknown] in terms of determination, taxation and operationally how it’s going to go,” said Alison Cohen, an ERISA attorney and partner with Ferenczy Benefits Law Center.

Challenges in Implementation

Because there hasn’t been a lot of demand for the option to have employers make Roth contributions to retirement savings plans—and because the Roth catch-up provision requirement was pushed back from 2024 to 2026—there hasn’t been much implementation yet, said Steven Grieb, senior compliance counsel for Gallagher.

But before the delay to 2026, there was a lot of finger-pointing, and that’s still the major hurdle Grieb expects the industry to face regarding these provisions.

“Recordkeepers were saying ‘no, this isn’t our job, this is your payroll provider’s job,’ and payroll providers were saying ‘we can’t implement this, you have to talk to your recordkeeper,’” Grieb said. “No one was really stepping up to the plate.”

Because he can’t imagine the IRS will specify who is responsible, Grieb said his primary concern is that once guidance comes from the IRS, there’s going to be more finger-pointing and the industry will still be “running in circles” in 2025.

If responsibility does fall to the payroll companies, that could put smaller payroll companies and their customers at a disadvantage, said Sean Menickella, managing director at Beacon Financial Services. Local payroll providers may not have the infrastructure of firms like ADP, Paychex and Paylocity, and that could force plan sponsors to feel like they need to audit the work of payroll companies or not give the option to have employers make matching contributions directly to Roth 401(k)s at all.

“If it causes more work, more liability and a greater headache for the employers, are they really going to implement it even if it’s a benefit to the employees?” Menickella said.

Susan Shoemaker, principal at CAPTRUST, foresees headaches related to the administration of designating employer contributions as Roth. There are already so many moving parts when it comes to how plan sponsors and payroll work together, and with adding this option for employers to make Roth contributions, “There are a lot of errors that could happen that we’re not aware of yet.”

Another challenge Shoemaker points to is educating plan participants. For example, higher earners may have never had Roth accounts before and now they’ll have to make Roth catch-up contributions. They may not be aware of Roth rules like that an account needs to be open for five years to not trigger a taxable event when withdrawing earnings, Shoemaker said.

Plans will also need to communicate the significance of having employers make Roth contributions, including that the move could put the participant in another tax bracket since they’re making pre-tax money after-tax and they’ll have to pay taxes outside of the plan, Shoemaker adds.

IRS Guidance Needed

The IRS’ guidance on the Roth provisions has been sparse, leaving questions for plan sponsors, advisers and recordkeepers. For instance, if payroll companies need to hit certain triggers in order to implement the Roth catch-up contributions, how will they know when to do so? It’s unclear, Cohen said.

The same goes for how exactly someone will be classified as “higher earning” and, therefore, need to make catch-up contributions after-tax. SECURE 2.0 says that any participant who earns more than $145,000 in FICA wages will need to make catch-up contributions as Roth contributions, but it’s not clear if that includes self-employed and government workers who don’t get FICA wages, Cohen said.

There are also mechanical questions for recordkeepers and third-party administrators who conduct actual deferral percentage (ADP) nondiscrimination tests to ensure higher-paid employees aren’t getting unfair advantages in the plan. If a highly compensated employees’ contributions fail testing and need to be re-classified as catch-up contributions, additional paperwork will need to be issued since that contribution will now need to be Roth. If the testing is happening late, participants may need to file amended tax returns, Cohen pointed out.

There’s also concern about the possibility of a universal availability problem when it comes to Roth catch-up contributions, Cohen said. If a plan doesn’t provide for Roth, but now catch-up contributions for highly compensated employees must be Roth, there’s the possibility that plans won’t allow these individuals to make catch-up contributions. There’s also the possibility that plans will allow highly compensated employees to make catch-ups Roth, but no one else.

Can plans determine that all catch-up contributions have to be Roth, even if you made less than $145,000 last year? Grieb said it’s another unknown. 

When it comes to employers being able to make Roth contributions, Cohen said that the mechanics of trying to make those contributions go into the employees’ accounts as Roth also need to be ironed out with guidance from the government.

The IRS has indicated that more guidance is on the way, but experts are hoping it comes in time to avoid a last-minute scramble.

 

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