Monitoring DC Plan Fund Menus Important for Participant Outcomes

It is important for plan fiduciaries to know what to consider for placing a fund on watch or replacing it.

A Morningstar report, “Change Is a Great Thing,” finds that monitoring defined contribution (DC) plan fund menus can improve performance, although more research on why this effect occurs is warranted.

The report cites previous research which found that institutional investment managers hired to replace terminated underperforming managers perform much better before they are hired, but this outperformance disappears after they are selected.

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Morningstar researchers used a large data set of plan holdings from three different recordkeepers between January 2010 and November 2018, to investigate the monitoring value provided by plan sponsors. For each plan, a list of available funds is available at some interval, typically quarterly. They employ a matching criterion to determine when a fund is replaced within the same investment factor style based on its Morningstar Category over time. The analysis results in a sample of 3,478 replacements across 678 DC plans. They find that on average replacement funds had better historical performance and lower expense ratios, along with more-favorable comprehensive metrics such as the Morningstar

Rating for funds (the “star rating”) and the Morningstar Quantitative Rating for funds, than the funds they replaced. The largest performance difference in the replacement and replaced funds is the five-year historical returns, suggesting this historical reference period is the one that carries the most weight among plan sponsors.

They also found that the future performance of the replacement fund is better than the fund being replaced at both the future one-year and three-year time periods, and that these differences are statistically significant. The outperformance persists even after controlling for expense ratios, momentum, style exposures, and other metrics commonly used by plan sponsors to evaluate funds such as the star rating and quantitative rating.

“Our findings suggest that monitoring plan menus can have a positive impact on performance,” the researchers conclude.

Jim Licato, vice president of product management at Morningstar in Chicago, and co-author of the report, tells PLANSPONSOR, “We have found, and believe it is very important, for someone to be keeping an eye on retirement plan investments—whether an investment committee or investment adviser—and make necessary changes. We found not doing so is a disservice to participants.”

He says that the prior studies did not include as robust a data set as the Morningstar analysis and that may be the reason it found different results than prior research. However, he adds, “We still have not dug through the detail about why exactly replacement funds are overperforming. It will require further research as it remains elusive as to why.

“What we can say,” Licato continues, “is that prior to replacement, plan sponsors were looking at a number of areas—past performance, expense ratios, Morningstar ratings, etc.—and all improved with the replacement fund.”

Considerations for fund replacement

Other than declining returns, Mike Goss, EVP and co-founder, Fiduciary Investment Advisors in Windsor, Connecticut, says one big factor in considering a fund for replacement for his firm is a fund manager change—whether a lead portfolio manager or a key member of that team. When this happens a fund may be put on watch because generally the manager is ultimately responsible for the funds track record and which securities to own. A fund manager change could change the fund’s track record or style, he explains.

Other factors in considering a fund for placement on a watch list or for considering a fund change is the change in ownership of the investment firm. “It’s a potential change that could lead to poor results,” Goss says. Those tasked with monitoring a DC plan’s investment menu also want to watch out for a fund style change or drift—for example, from value to growth—and for a strange in strategy or fund turnover—for example, some funds own stocks for a long time and some trade frequently. “Both can be good strategies, but if a fund changes strategy it should cause a plan fiduciary to ask why,” he says. “Plan sponsors select funds based on a certain process, style or philosophy. Any change would be a red flag.”

According to Licato, fund expenses should also be monitored to make sure they are in line with what similar funds are charging.

He says when a fund is put on a watch list, it can remain on the watch list for one quarter or a few quarters. Those monitoring the DC plan fund menu will look to see whether what triggered putting the fund on the watch list has been improved or gotten worse. If it’s gotten worse, the fund should be replaced. “There is no set number of funds that need to be replaced or put on watch. It’s more about fund monitoring and staying on top of things,” he adds.

According to Goss, his firm’s rule is that a fund cannot be on watch more than year. “There’s no law or necessary best practice, but we think a year is enough time to make a quality assessment to either maintain the fund in the DC plan investment menu or change it,” he says.

Goss warns that DC plan fiduciaries should never try to time the market. “That’s no reason to add or delete a fund. Hopefully, if they’re doing very good due diligence when they select a fund to include on the investment menu, they should not have a significant turnover of funds. We very rarely turn funds over,” he says. Goss adds that one of the things fiduciaries can outsource through a 3(38) investment manager is the ability to have the manager select, monitor and replace funds.

Licato points out that fund turnover can be disruptive for recordkeepers and participants—the paperwork and moving of assets is never a good thing from an administrative standpoint. However, he says, if a plan fiduciary is contemplating not removing a fund because it will be disruptive, it is not looking at the best interest of participants. “If it will benefit participants, do it.”

He adds that the main lesson from Morningstar’s analysis is, “Don’t’ set the investment menu on cruise control and not look at it for years. During that time there could be many red flags.”

DOL Receives Recommendations for Lifetime Income in DC Plans

The ERISA Advisory Council sent a report to Secretary of Labor R. Alexander Acosta focusing on recommendations for promoting lifetime income (LTI) within defined contribution (DC) plans through changes to the annuity selection safe harbor and modifying the qualified default investment alternative (QDIA) rule.

The Advisory Council on Employee Welfare and Pension Benefit Plans, referred to as the ERISA Advisory Council, has sent a report to Secretary of Labor R. Alexander Acosta focusing on recommendations for promoting lifetime income (LTI) within defined contribution (DC) plans through changes to the annuity selection safe harbor and modifying the qualified default investment alternative (QDIA) rule to focus on asset accumulation and decumulation issues in the context of LTI needs and solutions.

Based upon testimony received during two days of hearings supplemented by written material submitted from interested stakeholders, the Council said it observed:

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  • No single product or plan design is likely to address decumulation needs for all DC plan participants. This issue arises from differences in general financial circumstances, account sizes, assets held outside of plans, health profiles, age, gender and marital status. To meet these variable needs, plans may need different solutions.
  • Plan sponsors may be deterred from incorporating LTI features within QDIA options because QDIA regulations remain ambiguous in several areas, including liquidity requirements and the ability to limit participation to particular demographic groups, e.g., participants of a specific age or length of service.
  • Plan sponsors remain challenged in incorporating LTI options due to fiduciary concerns around selecting and monitoring an annuity issuer. Plan sponsors generally seek an objective and uniformly applied safe harbor. No witnesses before the Council suggested standards for such a safe harbor. Several witnesses broadly supported potential and pending legislative proposals that would materially modify the fiduciary framework; however, this legislation is beyond the Council’s scope and remit.
  • Inconsistencies and disparities across LTI products and administrative platforms hinder LTI utilization.
  • As discussed in prior Councils’ reports, participants would benefit from clear and unbiased education and information related to DC plan asset decumulation strategies. Plan sponsors may be more inclined to provide this information if they were certain that providing such information would not constitute investment advice.
  • The complexity of the LTI topic masks the fact that plan design offerings, such as a Social Security bridge option or installment payout, could be accommodated today on most recordkeeping platforms at limited cost.

As for pending legislative proposals regarding an annuity selection safe harbor, speakers at a recent Brookings Institution event suggested that those proposals miss the mark and agreed that a financial strength criterion asking how sound is an annuity carrier should be a critical part in any annuity selection safe harbor for defined contribution (DC) plan sponsors. However, the ERISA Advisory Council recommended that the Department of Labor should publish guidance confirming that a named plan fiduciary may appoint a 3(38) investment manager to select and monitor annuity and other LTI providers for DC plan decumulation, as well as accumulation. ”Specifically, applying the fiduciary responsibility scheme of ERISA section 3(38) in which the plan fiduciary only has responsibility for the prudent selection and monitoring of an independent expert would address many plan sponsor concerns about fiduciary liability,” the Council says in its report.

The Council notes that the QDIA regulations tangentially address LTI and the DOL’s guidance has generally been informal. In 2016, in an information letter to Christopher Spence, senior director, Federal Government Relations at TIAA, the DOL said a DC plan could prudently choose a default investment for the plan that contains lifetime income elements.

The Council concluded that amending QDIA regulations to specifically address LTI could incent plan sponsors to adopt innovative QDIAs, including QDIAs with LTI options. It says such changes should address the permissibility of including fixed annuities, living benefits and other LTI approaches in a QDIA; address the importance of tailoring QDIA options to affected participants, similar to rules applicable to QDIA balanced funds. (It specifically recommended that the DOL clarify that sponsors may default participants into different options based on participant demographics because plan populations may not be sufficiently similar for a single default to be universally appropriate); maintain the current transferability and liquidity requirements, but clarify whether living benefits satisfy these requirements; and address the extent to which charges may be imposed if they have the effect of limiting liquidity and/or transferability.

The Council further concluded that plans offering different kinds of distribution options could have a positive material impact on participants’ retirement income. Including these distribution options are settlor decisions and these options are readily available on most recordkeeping platforms at modest cost. The Council said it believes more plan sponsors would adopt multiple distribution options if the DOL clarifies that offering multiple distribution options is a business decision made in a settlor capacity and this decision is exempt from fiduciary liability. It recommends that the DOL encourage plan sponsors to adopt plan design features that facilitate LTI, including, but not limited to: allowing participants to take ad hoc distributions, enabling installment payments, providing Social Security bridge options and allowing for payment of required minimum distributions.

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