Core Menus Need to Evolve

David Blanchett of PGIM argues that qualified retirement plan menus have ‘notable gaps’ in alternative asset classes that would improve outcomes, and retention, for retirees.

The role of the core investment menu in defined contribution plans has changed considerably over the last decade, as qualified default investment alternatives, particularly target-date funds, now capture more plan sponsor attention and participant assets than ever.

This evolution requires plan sponsors and consultants to revisit key assumptions about optimal core menu design, especially as plan sponsors increasingly seek to retain participant assets during retirement, since older participants are more likely to use the core menu and invest conservatively.

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David Blanchett

To better understand what types of asset classes are available in 401(k) plans today, I recently analyzed the core menus of 8,271 401(k) plans using 2020 plan year data and found through my research that equity funds dominated core menus, with roughly three times as many equity funds on core menus versus bond funds, on average. Additionally, while certain strategies like target-date funds are widely available, there are notable gaps in certain areas, such as alternative asset classes. While the plans are from 2020, it provided the most robust recent data for my purposes, and serves as a good baseline for today’s savers.

The lack of availability of certain asset classes has important implications for participants, since it makes it more difficult to build efficient portfolios. While each core menu is different, I found that the average participant using the core menu correctly could generate approximately four more years of income if he or she had a complete menu of funds available.

Efficient portfolios can look very different based on where an investor is in his or her life cycle. The gaps in core menus today are likely to disproportionately affect older investors (e.g., retirees), who tend to be more focused on the risks of inflation and have more conservative allocations. The most notable gaps in asset class availability today are likely inflation-linked bonds, commodities and real estate, although other asset classes, such as long-term bonds and high yield bonds, deserve wider consideration as well.

While there may be some hesitation to expand core menus, given past research on the topic (e.g., research finding a negative relationship between core menu size and plan participation), it is important to recognize that DC participant behaviors have evolved and adapted in response to wider adoption of plan design features like automatic enrollment and QDIAs. Core menu users tend to be more sophisticated than the average participant (e.g., are older, have higher incomes, higher balances, etc.), and therefore concerns regarding misuse of the core menu need to be placed in the correct context, especially given the gaps in the fixed-income asset classes.

Better core menus do not necessarily mean that core menus need to get larger, but rather more thoughtfully designed. For example, using a single (multi-asset) fund to represent U.S. large-cap equities and adding a real estate and an inflation-protected bond fund is going to enable participants more diversification than having each of the nine common “style box” asset classes covered. Another area of focus for plan sponsors should be the availability of funds that can be used to combat inflation, like adding a single “real asset” strategy or the respective components.

Creating core menus that allow participants to build more diversified portfolios should result in better investment and retirement outcomes. Improving core menus is also a relatively low lift compared with other more complex solutions being discussed today; it makes good sense for plan sponsors to ensure their core menu is in the best shape it can be.

David Blanchett is managing director, portfolio manager and head of retirement research for PGIM DC Solutions.

2 Advisers Fined for ‘AI Washing’ Marketing Violations

Delphia and Global Predictions were fined a combined $400,000 for marketing rule violations related to their use of artificial intelligence.

The Securities and Exchange Commission fined two advisers on Monday for using misleading marketing materials related to their use of artificial intelligence.

SEC Chairman Gary Gensler has emphasized in recent statements the importance of taking enforcement action against “AI washing,” the practice of falsely claiming to use AI for specific investment functions.

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Delphia Inc., an adviser based in Toronto, was fined $225,000 for misleading statements made from August 2019 through August 2023. According to the SEC, Delphia made misleading statements in its SEC filings, press releases and on its website that the firm used AI and machine learning in its investment recommendations.

The SEC found that Delphia did not have the technological capabilities to provide the services it claimed to provide. Though the firm started data collection in 2019, it never applied the data to an artificial intelligence technology. The SEC’s Division of Exams identified this issue in 2021, according to the SEC, but Delphia did not adequately update its disclosures until 2023.

Global Predictions Inc., a San Francisco-based adviser, was fined $175,000 for making false statements about its use of AI, multiple marketing rule violations unrelated to AI and an unlawful liability hedge clause in its advisory contracts.

According to the SEC, Global Predictions falsely claimed it was the “first regulated AI financial adviser” and that it used a chatbot that generated AI-driven asset allocation recommendations.

Additionally, Global Predictions was unable to substantiate specific performance claims, such as claiming that the firm had outperformed IMF forecasts by 34% without disclosing the IMF forecast in question. The advisory firm also used hypothetical performance on its YouTube page, where it reaches a general audience, when the SEC’s marketing rules require hypothetical performance to be delivered to a specific and relevant audience only.

The SEC’s announcement of the fines was framed as pertaining to AI-specific violations, though the violations would be unlawful under the marketing rule if another technology were being mispresented. Jay Gould, a special counsel with Baker Botts, says the SEC is “reminding registrants that false promotional efforts claiming use of AI needs to be correct.”

Gould adds that, “I think it is framed this way so that the SEC puts everyone on notice that they are up to date on AI and all things tech. This really is something that the SEC should be signaling to the industry.”

 

 

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