The
Pension Benefit Guaranty Corporation (PBGC) has issued Technical Update 17-1,
which provides guidance about compliance with the active participant reduction
event requirements of section 4043(c)(3) of the Employee Retirement Income
Security Act (ERISA) and the PBGC’s regulation on Reportable Events and Certain Other Notification Requirements (29 CFR part 4043.23(a)).
The
PBGC is providing an alternative method for determining whether reporting an
attrition event to the PBGC is required under § 4043.23(a)(2) to avoid possible duplicative reporting.
This
reportable event occurs when, as a result of a single cause (such as a
reorganization or layoff), or through employee attrition, the number of active
participants in a plan is reduced below 80% of the number at the beginning of
the year or below 75% of the number at the beginning of the prior year.
Since
publication, the agency has received questions from practitioners about whether
the regulatory text requires a plan that files a single-cause event notice to
file an “attrition event” notice at a later date due to the same active
participant reduction. This was not the PBGC’s intent.
The
agency plans to issue a new proposal to clarify this and avoid duplicative
reporting, but because it has not yet issued a rule, there is a need for
interim guidance to avoid duplicative reporting while complying with the
existing (unamended) regulation.
To
determine whether reporting is required for an attrition event for a plan year,
a potential filer may disregard any cessations of active participant status
reported to the PBGC for single-cause events during the plan year or preceding
plan year.
Specifically:
When
determining whether the number of active plan participants at the end of the
plan year is less than 80% of the number of active participants at the
beginning of the plan year, plans may include in the year-end active
participant count participants who ceased to be active participants during the
plan year due to a reported single-cause event.
When determining
whether the number of active plan participants at the end of the plan year is
less than 75% of the number of active participants at the beginning of the
preceding plan year, plans may include in the year-end active participant count
participants who ceased to be active participants during the current or prior
plan year because of a reported single-cause event.
More investment providers are now using ETFs within glide-path-based portfolios, but the business development leader at Stadion says his firm has long embraced the approach, as exemplified by the new TargetFit product launch.
Sitting down with PLANADVISER to discuss his firm’s recent
target-date fund (TDF) product launch and wider industry trends, Todd Lacey, chief
business development officer at Stadion, said the key theme of the TargetFit TDF line is flexibility.
“These new strategies are coming at a time when the vast
majority of target-date products available offer only one glide path,” Lacey
observed. “The reality is retirement plan sponsors and their participants are
looking for investment solutions that are more tailored to their individual
needs.”
Plugging for his firm, Lacey said he is “excited to see what
traction TargetFit will gain in the retirement market in the months and years
to come.” In short, the solution offers three levels of risk within the same TDF family, leveraging exchange-traded funds (ETFs) wrapped within collective investment trusts (CITs) to keep costs as low as possible.
Lacey acknowledged the fact, raised by some researchers and industry analysts,
that an increasing number of managers have chosen to offer additional “flavors”
of target-date fund products in response to various stimuli, resulting
in a saturated marketplace in which it can be difficult for new products to
gain significant assets. Indeed, recently firms with long-standing active
target-date series have launched indexed or blended funds, using elements of
both active and passive investing, while other target-date series have been launched to serve other purposes. Against this backdrop, Lacey voiced confidence that the best products will always gain
the most assets, even in a crowded marketplace, and so he downplayed the risk
of this new launch failing to catch on or cannibalizing assets from the firm’s
existing products.
What makes the TargetFit line a new and unique product, he
said, is that the glide paths utilize a series of carefully tailored components in different blends
designed to offer varying levels of risk exposure. The three underlying components
are labeled Strategic Equity, Strategic Fixed Income and Flex. The Strategic
Equity component “remains fully invested in equity positions at all times,
while retaining the ability to strategically adjust the allocation among
various equity positions.” The Strategic Fixed Income component “remains fully
invested in fixed-income positions at all times, while retaining the ability to
strategically adjust the allocation among various fixed-income positions.” The
Flex component is “actively managed between equity positions, fixed-income
positions, and cash/cash-equivalents depending on the risk level of the market
as determined by Stadion’s proprietary Short Term and Long Term models, which
are each applied to 50% of the Flex.”
The complementary structures of the underlying investments allow the firm to offer three distinct glide paths in the TargetFit line—one
conservative, one moderate and one aggressive. Naturally, this approach is meant to allow
participants to have highly tailored portfolios that more closely match their
individualized risk tolerance and time until retirement. In a bid to keep fees as
low as possible, the firm used ETFs as the primary underlying
investment vehicle, Lacey confirmed, and the TDFs can operate in “multiple open-architecture
platforms” because they are wrapped in collective trusts.
NEXT: Offering both managed
accounts and TDFs
One interesting aspect of Lacey’s job is that he is tasked
with overseeing both Stadion’s TargetFit TDF offering as well as the nearly 2-year-old StoryLine
managed account product set. As Lacey spelled out, it was not all that long
ago that investors who were automatically enrolled into retirement plans were almost
exclusively placed in stable value funds, or perhaps money market
funds—investment approaches deemed to be safe and prudent for any of the small
number of people actually defaulted into retirement plans pre-Pension Protection
Act.
Today, nearly a decade after passage of the major reforms in the PPA,
the steady stream of highly customizable products and services targeted at
automatically enrolled defined contribution (DC) plan participants tells a different
story. A wide variety of investment providers—from the most passively minded
indexing specialists to more daring tactical managers—compete for the coveted
qualified default investment alternative (QDIA) slot on retirement plan menus.
The firms offer a huge variety of philosophies about what approach is best for
“auto-participants.” Sometimes today, the conversation is framed as “managed accounts or TDFs, but not both.”
Lacey said Stadion has reached the conclusion that “it is
not a matter of managed accounts vs. TDFs.” In fact, at his firm the two
approaches are highly complementary and help the firm serve a much broader
range of participants than could be reached previously with just the StoryLine
managed accounts. The reason for this, as Lacey candidly explained, is that the
major recordkeepers today are absolutely swamped with backlogged client
requests and the daunting task of updating their offerings and meeting the challenges
of fee compression and regulatory uncertainty.
“We have established some great relationships with some of
the big recordkeeping providers, but frankly in this environment it is increasingly
difficult, even when they really like our product, to prioritize even the small
amount of development work that will go into adopting our managed account
product,” Lacey said. “In response, we have shifted our strategy and have
been finding success going to smaller, regional and independent
recordkeepers. They can be more nimble, and they have helped us expand the
footprint of the StoryLine managed accounts.”
Lacey described the TargetFit launch as a complementary
strategy in that the TDF products will be widely available on essentially any
open-architecture recordkeeping platform. “This allows us to bring the
philosophy of tailored service and personalization of the StoryLine managed
accounts to a much broader audience investing in TDFs.”