DC Retirement Plan Participant Portfolio Construction Has Improved

At year-end 2015, about half of all Vanguard participants were solely invested in an automatic investment program—compared with just 29% at the end of 2010.

Vanguard’s 2016 How America Saves report shows the number of defined contribution (DC) plan participants with professionally managed allocations—those who have their entire account balance invested in a single target-date or balanced fund or in a managed account advisory service—has grown.

At year-end 2015, about half of all Vanguard participants were solely invested in an automatic investment program—compared with just 29% at the end of 2010. Forty-two percent of all participants were invested in a single target-date fund; another 2% held one other balanced fund; and 4% used a managed account program. Among new plan entrants (participants entering the plan for the first time in 2015), eight in 10 were solely invested in a professionally managed allocation.

For more stories like this, sign up for the PLANADVISERdash daily newsletter.

Jean Young, senior research analyst at the Vanguard Center for Retirement Research, and lead author of How America Saves, based in Malvern, Pennsylvania, tells PLANSPONSOR, while automatic enrollment and plan sponsors choice of a qualified default investment alternative (QDIA) had something to do with this, the study found more participants chose these options than were defaulted into them. “Just offering the options eases decisions for participants,” she says.

As for the use of managed accounts, Young says the study indicates those who choose managed accounts tend to have higher account balances and be higher-income, longer-tenured employees. “At some point, their balance gets high enough that they want advice and professional investment management,” she notes.

Given the growing focus on plan fees, there is increased interest among plan sponsors in offering a wider range of low-cost passive or index funds. An “index core” is a comprehensive set of low-cost index options that span the global capital markets. In 2015, half (54%) of Vanguard plans offered a set of options providing an index core.

Over the past decade, the number of plans offering an index core has grown by nearly 90%. Because large plans have adopted this approach more quickly, about two-thirds of all Vanguard participants were offered an index core as part of the overall plan investment menu. Factoring in passive target-date funds, 69% of participants hold equity index investments.

“I do think the fee transparency regulations had a lot to do with this,” Young says. “As plan sponsors look at their investment lineups, they want to be sure they have low-cost passive option for participants.”

NEXT: What the markets did to account balances

Young points to scatter plots in the How America Saves report that show the five-year annualized total return for participants in professionally managed options versus those participants who select investments on their own. The scatter plots show consistent allocations to bonds and stocks and consistently rising returns for those in professionally managed accounts. However, the allocations and returns for those selecting their own investments included many outliers, with some experiencing negative returns.

The How America Saves study found that with essentially flat markets in 2015, the average one-year participant total return was –0.4%. Five-year participant total returns averaged 7.3% per year. Among continuous participants—those with a balance at year-end 2010 and 2015—the median account balance rose by 105% over five years, reflecting both the effect of ongoing contributions and strong market returns during this period. More than 90% of continuous participants saw their account balance rise during the five-year period ended December 31, 2015.

Young explains that the returns participants see depends in part on the size of the account balance. The Vanguard study found the median account balance was $26,000; only 25% have account balances higher than average. Young says there are a few things going on. “The effect of auto enrollment is more small balances. For better or worse, participants don’t get the idea of total return and compounding, so they look at what their account balance is doing. In 2015 when equity was down, ongoing contributions masked that, so while participants might hear about market volatility, what they are experiencing in their own account doesn’t reflect that. Smaller account balances are like rose-colored glasses, and the good thing is it doesn’t make participants panic.”

Young says those with higher account balances may see more of a loss in their accounts, which is not necessarily a bad thing because they are buying low with their contributions.

“The two big criticism for 401(k)s is that participants don’t save enough, and don’t know how to invest. We found the overall contribution rate is 10%, which we’d like to see higher, but it is good. We’ve made much more headway on the participant portfolio construction issue. These are the two things we need to get right,” Young concludes.

Committee Strongly Suggests IRS Not End Determination Letter Program

However, the committee made another suggestion assuming "there will be no IRS change of heart."

The Employee Plans Subcommittee (EP Subcommittee) of the Advisory Committee on Tax Exempt and Government Entities (ACT) has attempted to identify viable approaches the Internal Revenue Service (IRS) could take to minimize the impact on the employee plans community, while respecting the challenges faced by the IRS budgetary shortfalls and personnel reductions in ACT’s 2016 Report of Recommendations.

The IRS announced in July 2015 its intent to eliminate the staggered five-year determination letter remedial amendment cycles for individually designed retirement plans and limit the scope of the determination letter program to initial plan qualification and qualification upon plan termination.

Want the latest retirement plan adviser news and insights? Sign up for PLANADVISER newsletters.

According to the ACT report, the IRS has received numerous comment letters from the employee plans community in response to the request for comments in the announcement, which were resoundingly negative toward the change. The ERISA Industry Committee (ERIC) asked the IRS to reconsider, arguing that most large employers do not use predetermined or “off the shelf” retirement plans, instead choosing to individually design plans that best benefit their workforces. Other industry sources agree.

The EP Subcommittee makes three recommendations. The first recommendation is not to generally eliminate periodic determination letters under the determination letter program. But, the EP Subcommittee says it recognizes the IRS is not likely to accept this recommendation, “but it is a recommendation with which all members of the EP Subcommittee strongly concur.”

The second recommendation is to proceed as the IRS has so far, but only as a transition measure while it discusses the matter further with the employee plans community. “This would address IRS’s immediate workload problem concerning a backlog of determination letter applications, while providing time for a real interactive dialogue with the [employee plans] community,” the report says.

NEXT: Assuming no IRS change of heart

The third recommendation, which consists of 11 points, assumes there will be no IRS change of heart. The EP Subcommittee says it “recognizes that many of the points require difficult choices as to how best to allocate limited resources and that is why the EP Subcommittee would recommend the transitional approach set forth in the second recommendation.”

The key points of the third recommendation are:

  • The IRS should provide certainty of the availability of determination letters to as much of the employee plans community as is feasible. The EP Subcommittee has provided several possible ways to accomplish this.
  • The IRS should look for ways to make the pre-approved program more flexible.
  • The IRS should reduce the user fees for document sponsors of pre-approved plans.
  • The IRS should modify its Employee Plans Compliance Resolution System (EPCRS) so it can be used without a plan sponsor having a current determination letter and for issues identified on audit.
  • The IRS should expand the plan provisions that can be incorporated by reference to the Internal Revenue Code of 1986, as amended (the Code) or regulations to simplify plan documents.
  • The IRS should allow leniency for "immaterial" flaws in plan document language found on IRS examination.
  • The IRS should immediately confirm that protection under Code Section 7805(b) continues for any plan document language that remains unchanged from issuance of a prior determination letter and further consider the feasibility of accepting an independent private review as "good faith" compliance extending Code Section 7805(b) protection.
  • The IRS should provide sponsors with a safe harbor approach for converting an individually designed plan into a pre-approved plan or establish a program to review and approve such conversions.
  • The IRS should publish model amendments along with the Cumulative Lists and List of Required Modifications (LRMs).
  • The IRS should provide adequate time to adopt all interim amendments.
  • The IRS should ask Congress to increase and dedicate user fees for the determination letter program and dedicate such amounts for use by, and on behalf of, the determination letter program.

The ACT report is here.

«