Cash Balance Plans Gain Clarity with New Regs

The adoption of cash balance plans has slowed to a trickle since the passage of the Pension Protection Act of 2006, according to Sibson Consulting, a division of Segal.

The lack of regulations is thought to be the leading cause. However, employers received much of the clarity they were waiting for about the design and structure of cash balance plans when the Internal Revenue Service (IRS) issued proposed and final regulations (see “IRS Corrects Hybrid DB Plan Rule“), and Sibson says the hybrid appeal is worth another look in light of this legal clarity (see “Bright Future Seen for Cash Balance Programs“).  

In a Spotlight report, Sibson says the potentially compelling reasons for employers to consider a cash balance plan are: 

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  • Financial Efficiency:  A traditional defined contribution (DC) plan is the approach to follow for employers that want to “set it, and forget it” because the cost of the plan is fixed: x percent of pay. However, in a simple cash balance plan the apparent cost of the plan is x percent of payroll, but the expected economic cost of the plan can be much less. The source of this savings is the differential between the rate that a plan will credit on employee accounts (which is often the 10-year or 30-year Treasury rate) and the discount rate. Under funding and accounting rules, the discount rate is based on corporate investment grade bonds. Given recent market conditions, this differential can result in a 1 to 2 percent spread, potentially saving as much as 2% of payroll each year (or more, if emerging investment performance exceeds the rate earned on corporate bonds). 
  • Mitigating a Significant Financial Risk Compared to a Traditional DB Plan:  A traditional defined benefit (DB) plan is exposed to both an investment risk (through its assets) and an interest-rate risk (through its liabilities). When the two risks go the wrong way — assets going down while liabilities increase — plan sponsors have experienced a “perfect storm.” And, while a cash balance plan is a DB plan, under a typical feature where the annual interest credit is set at a market rate (e.g., 30-year Treasuries), the interest-rate risk on the liabilities is significantly muted without needing to introduce complex interest rate hedging techniques that one would need in a traditional DB plan. The reason for this is simply that whereas lower discount rates drive up a typical DB plan’s present value of future benefits (i.e., the plan’s liability), lower discount rates  usually reduce a typical cash balance plan’s interest crediting rate, thereby offsetting the increase in the liability due to lower discount rates.
  • Universal Coverage:If employers shift the primary retirement vehicle from a traditional DB plan to a traditional §401(k) plan, one group of employees is left out in the cold: those employees who are unable to save money in the §401(k) plan and, therefore, receive no employer match. Although typically not a substantial portion of the population, it is nevertheless a group about which the human resources department is often concerned. A cash balance plan fills this gap because, like a traditional DB plan, it covers all employees. 
  • Balance of Risk: Many employers believe that their assumption of 100% of the financial risks of the retirement program is too far to one extreme. However, a growing number of employers think that having employees assume 100% of the risks goes too far in the other direction. A cash balance plan operating in tandem with a DC plan provides a reasonable middle ground. 
  • Benefit Design Flexibility:Because a cash balance plan is a DB plan, it can be used to meet employers’ personnel goals in ways that are not available to DC plans. For example, they can be (although not often are) the basis for providing early retirement windows and spousal benefits.
     
  • Passing Non-Discrimination Testing:  Many DB plan sponsors closed their DB program to new hires in the past few years. If this has not already created non-discrimination problems, it is likely to do so in the future as the DB population ages and becomes higher paid. Redirecting a portion of current DC accruals into a cash balance feature in the DB plan (effectively allowing new participants into the DB plan) may make it easier to pass the non-discrimination test for the closed DB plans.
Advantages of Cash Balance for Employees  

In its Spotlight report, Sibson Consulting said from the employees’ point of view, there are two main advantages of a cash balance plan: 

  • Preservation of Investment Principal:Cash balance plans typically provide a feature that DC plans do not provide under the commonly elected investment options: account values that can only increase from year to year. Essentially, cash balance plans act like stable-value funds providing a dependable floor of protection. Further, although the interest credit in a cash balance plan might seem conservative compared to traditional DC investments, participants could compensate for this conservatism by allocating a larger portion of their DC accumulation to equities. 
  • Longevity Protection:Surveys have shown that one of the two major fears of employees who are about to retire is outliving their money. (The other is a medical catastrophe that wipes out savings.) Because a cash balance plan is a DB plan, it must offer the option of receiving a lifetime payout rather than a lump sum. To some extent, this also serves as a floor of protection against outliving one’s money.

ICI Report Shows Fund Fees Declined in 2010

Average fees and expenses incurred by investors in long-term mutual funds declined in 2010, according to a recent study.

The report by the Investment Company Institute (ICI) said stock fund investors in 2010 paid an average of 95 basis points (0.95%) in fees and expenses, down 3 basis points from 2009. Fees and expenses of bond funds declined one basis point, to 72 basis points.

ICI said expense ratios of stock funds declined in 2010, while expense ratios of bond funds were unchanged. The average expense ratio of stock funds fell two basis points to 84 basis points, after having risen the previous year. Bond fund expense ratios remained unchanged at 64 basis points, according to the data.

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The decline in fees and expenses of long-term funds was aided by a decline in load fee payments by investors; in 2010, the maximum sales load on stock funds offered to investors averaged 5.3%. But the average sales load investors actually paid was 1%, owing to load fee discounts on large purchases and fee waivers, such as those on purchases through 401(k) plans, ICI said.

Money Market Funds 

Meanwhile, the average fees and expenses of money market funds declined sharply in 2010. The average expense ratio on money market funds fell seven basis points, from 33 basis points in 2009 to 26 basis points in 2010. Expense ratios on money market funds fell sharply in 2010 because the great majority of funds waived expenses to ensure that net returns to investors remained positive in the current low interest rate environment.

ICI said average expense ratios of funds of funds declined for the fifth consecutive year. In 2010, the total expense ratio of funds of funds, which includes both the expenses that a fund pays directly out of its assets as well as the expense ratios of the underlying funds in which it invests, fell one basis point to 90 basis points.

Since 2005, the average expense ratio for investing in funds of funds has fallen 11 basis points, in part reflecting a shift by investors toward funds with lower expense ratios, according to the ICI data.

More information is at http://www.ici.org/pdf/per17-02.pdf .

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