Recordkeeping Landscape Has Shifted Significantly

Recordkeeping systems are not as varied as they used to be, but it's still important for plan advisers to help their sponsor clients pick the right provider.

Twenty-five years ago, a retirement plan recordkeeping system was considered cutting edge if it could offer daily valuation of accounts rather than just “balance forward” processing—the term used to describe valuation updates that were processed monthly or less often.

“Historically it was about the differences in what platforms could handle—daily versus balance forward, defined benefit versus defined contribution—but now most systems can handle pretty much everything,” says Debbie Pritchard, vice president who leads Schwab Retirement Technologies (SRT), a recordkeeping system provider. Based in Phoenix, Arizona, Pritchard explains that choices today are more about volume, customization and control. “These, as well as cost, are the differentiators now.”

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

Rick Bindler, director of sales and marketing at Datair in Chicago, which provides recordkeeping and other systems software to third-party administrators (TPAs) that serve the micro- and small-plan market, says recordkeeping is now becoming a bit of a commodity. “All systems, whether proprietary or outside-developed are able to do testing, administration, statements, web accounts, etc. There used to be oohs and aahs when [a recordkeeper or recordkeeping system provider] came out with something new; now others catch up pretty quickly,” he notes.

Still, both recordkeepers with proprietary systems and recordkeeping system providers are going to some length now to differentiate themselves, such as expanding into mobile technology, according to Bindler.

Bill Byerly, executive vice president and general manager for Omni, a recordkeeping system provided by SunGard, who is based in Birmingham, Alabama, says recordkeeping systems used be challenged by trying to keep up with the next coolest thing or keep up with changing regulations. Now there’s no one doing anything more elaborate than anyone else. He says getting clean data from plans has become the biggest challenge for recordkeepers.

NEXT: Proprietary vs. technology-provider systems

Pritchard notes that Schwab has both a proprietary recordkeeping system and is the provider of the SRT system to other recordkeeping service providers. She contends that, in developing a proprietary system, recordkeepers can develop a platform that is more economical. For example, data security for Schwab’s proprietary system falls under the Schwab standards for data security as a whole; there are already processes in place to handle data security.

She adds that proprietary systems tend to be more customized than systems developed for the general marketplace. Proprietary systems may be built for a specific market size or scale; systems built for the general marketplace must cover all needs of the marketplace so TPAs can build different experiences for different clients.

However, Bindler believes one of the biggest advantages of non-proprietary systems is the ability to customize for a more varied client base. “We get input from a wide variety of viewpoints, and are able to make software that meets different needs,” he says. “We get requests on a daily basis from clients that want some kind of feature enhancement, so we are constantly updating our system.”

Proprietary systems are more like silos, each meeting the needs of certain clients of similar types and sizes, so the software is not as diversified, Bindler contends. In addition, he says a recordkeeping system provider can spread costs of updates across a wider client base than can recordkeepers with a proprietary system, and the client base consists of TPAs, not plan sponsors.

Aaron Venouziou, president and co-owner of Datair, notes that when one client wants a feature, Datair updates its system as a whole so any client can also use the feature. “We have all variations of design and features to offer plan sponsors,” he says.

According to Bindler, this can also be seen as an advantage of proprietary systems—if a client wants something, the recordkeeper can stop everything it is doing for that client to make the change, but his firm cannot do that.

Byerly notes that recordkeeping system technology providers, such as SunGard, are able to focus only on technology. He says he doesn’t know why recordkeeping firms want to be in the technology business when they have other areas of focus. In addition, he says, because SunGard is an international firm, it can look at what trends are happening in the world market and establish partnerships for international trading.

NEXT: What plan sponsors and advisers should know

Pritchard says retirement plan sponsors and advisers shouldn’t have to worry about recordkeeping system compatibilities, as the recordkeeper or software provider will take care of that. But sponsors and advisers may want to ask how often a recordkeeping system gets upgraded. The big question about technology is what entity is hosting the data and can it handle the size and scale of the sponsor’s plan?

“I think overall the goal would be that plan sponsors and advisers have confidence that the recordkeeping system is regulatory compliant, secure from data breaches, and that participants are getting a great online experience,” Pritchard says.

Plan sponsors and advisers should ask about data security and integrity, according to Pritchard. Bindler adds that one thing plan sponsors and advisers need to ask about is system backup in case of a fire or other disaster.

Pritchard says it is also important that the recordkeeping system is staying ahead of regulatory changes. For example, Schwab is currently working on updating its systems to handle money market reform

According to Byerly, SunGard is a member of both SPARK and the American Society of Pension Professionals & Actuaries (ASPPA). It has biweekly webinars with someone at ASPPA to keep involved with new trends and regulations. SunGard also has business analysts that keep up with what is happening at the Department of Labor (DOL), Internal Revenue Service (IRS) and in Congress.

He says plan sponsors should ask how the recordkeeping system takes in data for compliance testing and trading, and what data it can output. Is a website available for plan sponsors and advisers, as well as participants, do the websites offer education tools, and is data made available and easily readable? “Then they should look at cost,” he adds.

According to Byerly, processing levelized revenue-sharing may still be considered unique, and nonqualified and union plans can get unique in their features, but as more plan sponsors are trying to simplify plans, there’s “not a lot of uniqueness out there.” However, if something special is required, plan sponsors and their advisers need to make sure the recordkeeping system can handle it.

Bindler says, when looking at recordkeeping systems, “there’s no right or wrong, it’s ‘what is the best fit?’”

Clearing Up Money Market Fund Reform Misunderstanding

Retirement plans will not necessarily have to divest from retail money market funds under SEC’s pending reforms, but plan sponsors and advisers may decide it's best.

Some qualified retirement plan sponsors and service providers are misinterpreting the likely impact of the Securities and Exchange Commission’s (SEC) money market fund reforms, opining the rulemaking will necessarily drive defined contribution (DC) plans away from retail money market funds.

The SEC is focusing on educating the retirement planning industry about the likely impacts of money market fund reforms adopted in 2014. In short, the rule amendments require providers to establish a floating net asset value (NAV) for institutional prime money market funds, which will allow the daily share prices of these funds to fluctuate along with changes in the market-based value of fund assets. The rule updates also provide non-government retail money market funds with new tools, known as liquidity fees and redemption gates, to address potential runs on fund assets. 

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

The retirement space is still in the process of digesting the rule changes. The good news is that sponsors and advisers have until October 2016 to decide how they will address the nearly 900-pages of rulemaking. But the timeline is tighter than some may think, given the complexity of money market funds and the potential for a late-mover premium should too many sponsors wait until the last minute to make changes.

One important section of the rulemaking for plan sponsors and service providers to understand starts at page 225, running through about page 271. The passage contains helpful discussion of what it takes to qualify as a retail money market fund, and how floating NAVs will be calculated and applied, along with guidance about the fees and redemption gates that have caused some Employee Retirement Income Security Act (ERISA) fiduciaries to doubt whether they’ll still be able to offer retail money market funds.

This is a common misconception—that retirement plan fiduciaries will be flat out required to start using government-sponsored money market funds, which will not gain the use of liquidity fees and/or redemption gates. In fact this is not the case, and the rules provide important exceptions for investing in retail money market funds that could ease plan sponsors’ fiduciary concerns.

NEXT: Important NAV exceptions

Critical for plan sponsors to understand is the fact that there is an exception for the floating NAV requirement for any money market fund that is a retail fund—and retail funds are defined under the new rulemaking as funds in which only natural persons can invest.

The money market fund rulemaking generally understands DC retirement plans as collections of natural persons, rather than as a distinct class of institutional investors. This, in turn, means most DC plans will be able to continue to invest in retail money market funds.

A big question for plan sponsors will be whether they feel comfortable, considering their fiduciary duty, with the prospect of plan participants potentially facing liquidity fees and gates within retail money market funds. The impact of these gates could potentially be dramatic, should a situation like the 2008 financial crisis occur again. In certain cases of stressed liquidity for a retail money market fund, a liquidity fee would go into place that could damage plan participant returns. In other cases, a redemption gate could be implemented, lasting up to 10 days, preventing all withdrawals from a money market fund.

Redemption fees and gates are not necessarily at odds with the fiduciary duty, especially if plan sponsors do a good job educating their plan participants up front about the money market fund changes. Indeed, the whole point of implementing liquidity gates and fees is to protect investor assets against sharp drops resulting from runs on money market fund assets. It could be distressing for a plan participant to face a liquidity fee or redemption gate, but plan sponsors can protect themselves from liability by educating participants about this possibility, and coaching them to stick with their long-term investing goals even during short-term periods of market stress.

NEXT: Other money market fund considerations

Plan sponsors and advisers should also be prepared to face changes coming from fund providers and recordkeepers.

Even in cases where a DC plan decides it is comfortable sticking with its current money market fund option, the plan’s recordkeeper or investment provider could decide change is necessary. This situation is likely to be faced by at least some plan sponsors, given that more and more fund providers are adding and changing options to get ready for the rule implementation in fall 2016.

Something else to consider is that it will be harder, if not impossible, for defined benefit (DB) plans to qualify as natural person investors. Therefore DB plans are probably likelier to have to switch to government money market funds, or another similar asset class.

Both DB and DC sponsors will have to be vigilant with regards to their recordkeeper’s shifting capabilities under the rulemaking. There are still a lot of operational systems issues that need to be addressed to ensure that the liquidity fees and redemption gates can smoothly go into effect.

On its website, the SEC urges retirement planning professionals to read a recently issued FAQ publication that addresses a number of retirement plan-related issues under the money market fund reforms. In particular FAQ 16 (which explains issues related to retail funds) and 17 (about forfeiture accounts) as well as FAQs 26-31 about the operation of fees and gates may all be of interest.

A link to the FAQs is here.

«