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Key Considerations for Committees Seeking DC Plan Help

By Mark Olsen, Managing Director at PlanPILOT

We’ve observed a growing demand for defined contribution (DC) plan management. This article offers insight into our experience and provides considerations designed to equip committees to evaluate which DC services might be right for their unique plan needs. 

Defined Contribution Plan Oversight Is a Herculean Task

Plan sponsors have the tremendous responsibility of being stewards of DC plan assets on behalf of their participants. The baseline premise of DC plan oversight—making decisions for the sole benefit of plan participants—is a significant undertaking in and of itself. Adding to the level of responsibility in no small measure is the increased fiduciary scrutiny of legislators and regulators, as well as the ongoing evolution of the retirement landscape. It is no wonder that nearly 59% of plan sponsors use an ERISA 3(21) advisor, a fiduciary consultant or advisor who makes investment recommendations in plan oversight. (1) Further, more than two-thirds of plan sponsors are looking to change advisors. (2)

Our work with plan sponsors has confirmed that DC Plan Consultant services are right for many committees and plans. In addition, sponsors already leveraging the assistance of a consultant or advisor may need help determining if their current partnership is bringing them value based on their unique needs and circumstances. We offer a series of themes below to help committees reflect on their own plan facts and circumstances. 

While this outline is certainly not exhaustive, it does offer a starting point for committees. We believe taking the time to consider these factors can be informative in assessing a DC Plan Consultant partner and selecting one that will enhance your plan’s oversight activities.

Efficiency and Timeliness of Plan Oversight Activities

It is productive for committees to take an opportunity to reflect on the timeline and effectiveness of their plan oversight activities. 

  • How are you tracking relative to setting and achieving strategic plan, goals, and objectives over the last 12-24 months?
    • Transitions of key providers (e.g., recordkeeper)
    • Study of retirement readiness metrics of your workforce and making any changes necessary
    • Establishing the role you wish to have in the retirement journey of your workforce, which may impact the Qualified Default Investment Alternative (QDIA), or other offerings
  • Is there a process to ensure consistency and timely execution of all plan oversight activities?
    • Adherence to the Investment Policy Statement (IPS)
    • Investment structure review
    • Provider assessment, monitoring, and management (e.g., recordkeeper, custodian)
    • Investment manager monitoring or replacement (e.g., performance, investment guideline, etc.)
    • Fee monitoring and negotiations 
    • Changing investment vehicles (e.g., fund to trust or separate account)

Increased Economic Activity and Market Shifts

The economic environment is overloaded with a series of fundamental shifts, each requiring an increasing need for time and attention. 

  • Has your committee considered the following economic themes and how they may impact your plan’s investment structure and/or retirement outcomes of participants?
    • Heightened market volatility
    • Higher inflation
    • Interest rate changes
    • Lower expected returns
  • How is your committee taking into consideration the heightened economic activity and market shifts relating to your plan needs?
  • Are recent economic events causing concern and/or the desire for increased need for expert engagement and help?

Complexity of Evolving Retirement Landscape

The retirement landscape is evolving rapidly given the extensive role DC plans play in retirement outcomes of today’s workforce. The range of topics in need of study is extensive, but necessary to ensure participant needs are most effectively met.

  • Is your committee able to assess offerings based on plan and participant needs?
    • Qualified Default Investment Alternatives (QDIA) evolution (e.g., target-date solutions, managed accounts, hybrid solutions, etc.)
    • Study of glide path suitability underlying the QDIA
    • Evolving implementation techniques (e.g., active investment management, passive investment management, or a blend approach)
    • Increasing interest and demand for retirement income services and solutions
    • Growing interest in Environmental Social Governance (ESG) investments
    • Ensuring cybersecurity practices are intact
    • Increasing demand for financial wellness programs
    • Exploring changing risk/reward profiles and the impact on outcomes (e.g., alternative investments)

Committee Structure

The COVID-19 pandemic has increased the complexity of our world, resulting in significant changes to our workforce. Committee structures are not insulated from these trends; thus it is important to take this into consideration any impact to your plan’s oversight.

  • Has your committee experienced reduced resources, committee turnover, etc.?
  • Has committee turnover resulted in revisiting, questioning, and/or the need to affirm prior decisions?
  • Is the institutional memory intact, and/or does your committee have access to prior decision-makers and the rationale and thought process of prior decisions?

Summary

The complexity of DC plan oversight and the increasing demand of time and attention from committees cannot be underestimated. The expansion of services, solutions, and offerings can be overwhelming to committee members with full-time commitments and competing priorities. What’s more, the critical nature of DC plans providing successful retirement outcomes is more important than ever. Some committees are hitting on all cylinders and not in need of additional help. However, there are many committees who may benefit from adding or even changing their existing DC Plan Consultant to help them better accomplish their plan goals and objectives. Taking time to assess your plan’s unique needs and circumstances and whether additional help is needed is time well spent.

Want to Learn More?

Do you need help evaluating which DC services would be the best fit for your plan? At PlanPILOT, we strive to deliver comprehensive advisory services that help you meet and exceed your fiduciary responsibilities by providing you with the proper risk management solutions and independent advice you need. If this sounds like the type of partnership you’re looking for, call us at (312) 973-4913 or email mark.olsen@PlanPILOT.com to set up an introductory meeting. We look forward to hearing from you!

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k) and 403(b) plan sponsors. Drawing on more than two decades of experience, Mark provides institutional retirement plan consulting to 401(k), 403(b), and defined benefit plans. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, Stable Value Investment Association, and CUPA-HR.

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(1) Deloitte 2019 Defined Contribution Benchmarking Survey Report

https://www2.deloitte.com/content/dam/Deloitte/us/Documents/human-capital/us-the-retirement-landscape-has-changed-are-plan-sponsors-ready.pdf

(2) Fidelity 2021 Plan Sponsor Attitudes Survey 

https://institutional.fidelity.com/app/item/RD_13569_26306.html

Is a Safe Harbor 401(k) the Right Choice?

By Mark Olsen, Managing Director at PlanPILOT

Contrary to popular belief, an employer-sponsored retirement plan is more than just a benefit for employees; there are actually many ways the plan sponsor can benefit as well. From attracting and retaining key employees to tax-deductible contributions and expenses, a retirement plan is a benefit that can work well for everyone involved. 

Despite the benefits, it can be difficult to sort through all the information out there and truly know which plan is best for you and your business. It doesn’t have to be this way! We at PlanPILOT can help you sort through the many retirement options available to plan sponsors. In this guide, we’ll explore the pros and cons of the safe harbor 401(k) and how to decide if it’s the right option for you.

What Is a Safe Harbor 401(k)?

A safe harbor 401(k) is named after the “safe harbor” provision in the tax code which states certain alternative conduct will be considered compliant for a particular rule or requirement. In this case, a safe harbor 401(k) plan will be exempt from annual nondiscrimination testing as long as the employer makes fully vested contributions to every eligible employee’s account. (1)

Plan sponsors can choose which type of safe harbor plan they would like to adopt, which provides flexibility in finding a plan that fits your needs. 

  • Basic safe harbor match: (2) The employer must match 100% of employee contributions on the first 3% of compensation, then 50% of contributions on the next 2% of compensation. The matching contributions are only limited to employees who are actively deferring funds into the plan. This means you could contribute to fewer employees but you will probably contribute more per person. 
  • Non-elective safe harbor: (3) With this plan, employers will contribute 3% of all eligible employees’ salaries, regardless of whether the employees contribute themselves. In this case, you would contribute to a greater number of employees but less per person.
  • Qualified automatic contribution arrangement (QACA): (4) This plan is also known as a safe harbor plan with an automatic enrollment feature. It is used to automatically enroll employees into the plan at a savings rate of 3%. The employer can then choose to make matching contributions or non-elective contributions at a reduced rate. The QACA match plan requires employers to match 100% of contributions on the first 1% of employee compensation, then 50% of contributions on the next 5% of compensation. The QACA non-elective plan, on the other hand, requires employers to contribute 3% of compensation to all eligible participants. Both plans require that employer contributions fully vest after two years, which is more favorable to plan sponsors and can be used to promote employee retention.

Pros

There are many benefits to a safe harbor 401(k) plan, including:

  • Exempt from annual nondiscrimination testing: A safe harbor plan is considered compliant with the major annual tests (ADP, ACP, and top-heavy) as long as the mandatory contribution levels are met. This alleviates a significant administrative burden and expense on the plan sponsor’s side.
  • Increased contributions: Since safe harbor plans are not tested for nondiscrimination, employers and highly compensated employees can both contribute more to their accounts without fear that the plan will be considered non-compliant.
  • Tax-deductible contributions: Like other 401(k) plans, employer contributions are tax-deductible up to 25% of covered compensation paid, limited to $305,000 of compensation per employee. (5)
  • Attract & retain employees: The required employer contributions are an attractive benefit to employees who are looking for long-term stability and growth within the company. This can help attract and retain top prospects.

Cons

While the benefits of a safe harbor 401(k) are enticing, it’s important to keep the cons in mind as well:

  • Costly contributions: Choosing a safe harbor plan means you will be required to make employer contributions every pay period or at the end of each plan year. These can quickly add up, especially if you have a lot of eligible employees. If you don’t keep up with the contributions, your plan could lose its tax-qualified status, resulting in hefty fines and penalties.
  • Immediate vesting: Unless you choose the QACA plan, safe harbor plans require immediate vesting of employer contributions. That means employees will automatically be entitled to 100% of the funds should they quit or get fired. This can make it easier for employees to leave, reducing overall retention rates.
  • Annual administrative requirements: Safe harbor plans must deliver notice to plan participants every year, at least 30 days before the plan year ends. This notice must detail each employee’s rights and obligations under the plan. (6) Ensuring that notices are sent in a timely fashion can add an administrative burden to the plan sponsor.

Making the Right Choice

Choosing the right retirement plan offering, whether it’s a traditional 401(k) or a safe harbor plan, comes down to several factors, including employee count and demographic, participation levels, company cash flow, previous compliance issues (if any), and desired plan design. 

At PlanPILOT, we help retirement plan sponsors sort through these factors to determine the right choice for their employees and their companies. If you are considering a safe harbor 401(k) and would like more information on the pros and cons, call us at (312) 973-4913 or email mark.olsen@PlanPILOT.com.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k) and 403(b) plan sponsors. Drawing on more than two decades of experience, Mark provides institutional retirement plan consulting to 401(k), 403(b), and defined benefit plans. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, Stable Value Investment Association, and CUPA-HR.

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(1) https://www.irs.gov/retirement-plans/plan-sponsor/401k-plan-overview

(2) https://www.paychex.com/articles/employee-benefits/is-a-safe-harbor-401k-right-for-you

(3) https://www.paychex.com/articles/employee-benefits/is-a-safe-harbor-401k-right-for-you

(4) https://www.investopedia.com/terms/q/qualified-automatic-contribution-arrangements-qacas.asp

(5) https://www.irs.gov/retirement-plans/plan-sponsor/401k-plan-overview

(6) https://www.irs.gov/retirement-plans/notice-requirement-for-a-safe-harbor-401k-or-401m-plan

ESG Investing for Retirement Plan Sponsors

By Mark Olsen, Managing Director at PlanPILOT

As the world continues to recover from the effects of the COVID-19 pandemic, there has been an increasing movement in American society to look beyond just ourselves and consider the impact we’re making on the people and the world around us. This has gone beyond just individuals and has permeated corporate expectations as well. 

How Can You Help Your Plan Participants Weather Stock Market Volatility?

By Mark Olsen, Managing Director at PlanPILOT

After a three-year rally, the financial markets have been down for seven straight days, marking their worst slide since the pandemic decline in March of 2020. (1) Monday’s market dip put the S&P 500 down over 10%, which is officially called a “correction” on Wall Street. (2)

In addition to the stock market decline, inflation has been causing concerns. Because inflation is reaching 40-year highs, it is expected that the Federal Reserve will begin raising interest rates in the spring, which could potentially slow the economy. (3)

Investors are understandably nervous about their investments and their purchasing power, and it’s likely your employees are worried about their retirement goals. Here’s how to support them and help them keep a level head and avoid financial mistakes. 

What Is an Outsourced Chief Investment Officer & Why Should I Work with One?

By Mark Olsen, Managing Director at PlanPILOT

A growing number of organizations are turning to outsourced chief investment officers (OCIO). In fact, an independent survey found that 37% of organizations are either currently outsourcing their investments or have plans to do so in the next two years. (1) In 2020 alone, OCIO-managed assets increased 5.8%, reaching $1.96 trillion. (2) If you’re looking for a better way to manage your organization’s assets, consider these reasons why an OCIO relationship might be right for you.