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Institute
December 2014
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4. Revisit automatic feature defaults to ensure they are as robust as possible while continuing
to educate workers on the need to save at high levels in their plan. Arguably one of the PPAs
biggest benefits was to increase the attractiveness of auto features (automatic enrollment, automatic
contribution escalation) by protecting plans that offer them. Today, 62% of plans offer automatic enrollment; more than half of these plans also offer automatic contribution escalation. However, robust
implementation of auto features remains the exception to the rule. Most commonly, plans auto enroll
workers into their DC plans with annual contribution increases of 1% of pay and a 6% cap. Under this
scenario, EBRI projects just under a 70% probability of eligible workers reaching retirement success.
This probability increases to 82% if workers are auto enrolled in a more robust way: with annual auto
contribution increases of 2% up to a 10% cap.2
5. Review and document the appropriateness and efficacy of the TDF. The PPA put TDFs on the DC
map by giving them 404(c) protection under the QDIA regulation. Today, 75% of plans offer a TDF as
the default investment fund for participant-directed monies. According to the Callan DC Index, TDFs
tend to be the single largest option in DC plans, averaging 29% of plan assets when offered. However,
TDFs track record is not flawless: 2008 was a notoriously poor year. The median 2010 TDF lost 22%,
prompting a series of hearings by the Securities and Exchange Commission and DOL. Further, TDF
performance is widely dispersed: an average of all TDF vintages across providers shows that those
in the top decile earned 10.3% annually compared to the bottom deciles 7.8% (over five years ending September 30, 2014). The median TDF failed to outperform the Callan Target Date Index over the
same time period.
6. Resolve to annually benchmark plan fees. Under the PPA, DC plan participants who have the
right to direct their investments receive quarterly statements. The DOL subsequently required that all
participants must receive statements showing the dollar amount of plan-related fees and expenses
charged to their accounts at least quarterly, as well as annual disclosures. Increased transparency has
driven DC sponsors to have a greater focus on plan fees. In 2014, 86% of sponsors calculated fees
for their DC plan. Still, less than two-thirds of these sponsors also benchmarked fees.
7. Reevaluate the plans approach to company stock and carefully document howas a
fiduciaryyou intend to treat company stock in the 401(k) plan. In an effort to reduce company
stock holdings in DC plans, the PPA required the plans that offer it to provide increased disclosure
about diversification, as well as a greater ability for participants to diversify out of company stock.
Today, just over one-third of DC plans offer company stock. According to the Callan DC Index, when
Authored by Lori Lucas, CFA,
Callans Defined Contribution
Practice Leader.
company stock is offered, it accounts for 14% of assets, on averagedown from 22% in 2006. Still,
stock-drop lawsuits continue to proliferate and the Supreme Court recently disallowed presumption of
prudence as a stock-drop lawsuit defense, potentially raising the fiduciary bar.
With the big anniversary around the corner in 2016, it is a good time for sponsors to bolster their DC plans
Email institute@callan.com
implementation of the PPAs provisions. At a minimum, plan sponsors should know where they stand in
with questions.
relation to the PPAs opportunities and challenges before it turns 10 years old.
2 Retirement success is defined as workers replacing at least 80% of their income in retirement through 401(k) balances and Social
Security on an inflation-adjusted basis. To achieve the better outcome, workers must not opt out of auto contribution escalation and
must maintain their deferral levels when switching jobs.