Finance

By Mark Olsen, Managing Director at PlanPILOT

In an increasingly complex financial landscape, managing endowments and foundations has never been more challenging. Markets are constantly evolving, compliance and due diligence requirements are intensifying, and regulatory landscapes are shifting. Amid this complexity, a comprehensive and focused approach to investing is not just desirable—it’s essential. 

At PlanPILOT, we aim to minimize fiduciary risk for institutional governance teams, and be diligent stewards of the investments they manage. This commitment aligns well with the role of an Outsourced Chief Investment Officer (OCIO), a rapidly growing investment model that is projected to manage a total of $3 trillion in assets by 2025. 

In this article, we’ll explain what an OCIO is, how it can benefit endowments and foundations, and the various types of OCIO services you can use. 

What Is an OCIO?

An Outsourced Chief Investment Officer (OCIO) is a specialized service in which an institution delegates a significant portion, if not all, of its investment management activities to an external expert. This model of investment management offers a holistic approach, overseeing all aspects of an organization’s investment portfolio. The OCIO is responsible for setting strategic asset allocation, making tactical investment decisions, handling manager selection and due diligence, and ensuring adherence to regulatory standards. 

Importantly, an OCIO is also accountable for investment performance. They operate under a fiduciary duty, which means they are legally obliged to act in the best interest of their client. This approach allows institutions to leverage the OCIO’s skill set, resources, and infrastructure, enabling them to focus on their core mission while having confidence that their investments are being professionally managed.

How an OCIO Can Benefit Endowments and Foundations

The decision to engage an OCIO is not taken lightly, and it’s driven by a multitude of key benefits this model offers. One of the primary advantages is the considerable back-end support provided by the OCIO. By overseeing the daily operations and administration of investment activities, the OCIO allows institutions to free up their time and resources, focusing instead on broader strategic goals. 

Moreover, an OCIO brings a wealth of investment experience to the table. With their deep knowledge of the financial markets, they offer strategic asset allocation advice, guide on manager selection, and provide risk management tactics—activities that demand considerable time, experience, and resources. This level of skill is particularly valuable for smaller organizations, which may lack the resources to maintain a fully staffed, in-house investment team. 

Compliance adherence is another area where an OCIO can make a significant difference. Given the increasingly complex regulatory environment surrounding managing investments, an OCIO can help keep your plan in compliance with all relevant laws and regulations, minimizing potential legal and financial risks.

Differentiation Among OCIO Providers

As the OCIO market continues to grow and evolve, differentiation among providers becomes increasingly pronounced. Some OCIOs offer a comprehensive, full-service solution, managing every aspect of your investment strategy, allowing institutions to work on other aspects of their organization. Others provide à la carte services tailored to your specific needs. Before requesting proposals from OCIOs, it would be wise to make a list of all areas you’d like help with so you know the key traits you are looking for in a provider. 

Additionally, some OCIO firms may have more niche investment strategies. Some of them offer ESG (environmental, social, and governance) investments, while others incorporate private equity into their investment strategy. Each of these strategies are polarizing topics in the investment world, so it’s important for you to know whether or not it’s right for your firm. 

After understanding the service offerings as well as any unique investment strategy, other key considerations should be their investment philosophy, performance record, risk management approach, and the depth and quality of their investment team. You also want to verify you understand their fee structures, and that the OCIO is a cultural fit with your organization. In a diverse and growing landscape, understanding these variations is crucial to find the most compatible OCIO partner.

Is an OCIO Right for Your Plan?

Are you grappling with the complexities of governing an endowment or foundation and implementing best governance practices? Now is the time to consider whether an OCIO might be right for you. An OCIO can provide a level of skill and support that enhances your strategy, confirms compliance, and ultimately helps your plan participants to experience better outcomes. With a tailored approach to your unique needs, an OCIO can be an invaluable partner for your endowment or foundation. 

At PlanPILOT, our goal is to help you find the best of class investment manager that meets the goals of your organization and all shareholders and decision-makers. If you’d like to start your search to find the best OCIO for you, 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), 403(b), and 457 plan sponsors. 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.

By Mark Olsen, Managing Director at PlanPILOT

Just when retirement plan sponsors were getting used to the SECURE Act that went into effect in 2020, new legislation was passed in 2022 designating new rules in the SECURE Act 2.0. Some of those changes went into effect immediately and other changes are set to start as far out as January 2024. This means it’s crucial for employers and plan sponsors to familiarize themselves with these upcoming modifications and prepare for their implementation. By staying informed and proactive, plan sponsors can assist in a smooth transition to the new rules, maximizing benefits for employees and maintaining compliance with regulatory requirements. Here’s how to plan ahead for all the upcoming changes. 

Understand Recordkeeping Readiness

As the new provisions come into effect, it’s essential to assess your organization’s current recordkeeping provider. Start by requesting insight from your recordkeeper on their capability plans to handle the new provisions, including:

1. Allowing employees to designate employer contributions as Roth contributions, which will impact employee taxes and require considerations for vesting. (optional provision)
2. Permitting qualified student loan payments to receive employer matching contributions, which will have budget implications for plan sponsors. (optional provision)
3. Establishing an emergency savings plan for non-highly compensated employees linked to the defined contribution plan, potentially with a 3% auto-enrollment feature, subject to specific account balance and investment limitations. (optional provision)
4. Ensuring catch-up contributions for employees with compensation over $145,000 (indexed for future years) are contributed on a Roth basis, and allowing all participants to make catch-up contributions on a Roth basis. (mandatory provision)
5. Increasing the catch-up contribution limit for individuals aged 60-63 to the greater of $10,000 or 150% of the regular catch-up contribution amount ($11,250 for 2023), indexed for cost-of-living increases. (optional provision)

The next step is to determine which of these optional provisions are aligned with your outlook on the employee benefit plan. An additional consideration is “packaging” a number of these changes versus rolling them out on an individual basis.

And that’s just some of the changes to come! Needless to say, there will have to be a lot of modifications to your recordkeeping process. Which of these changes will be easier to make, and which might present a challenge? Establish an open line of communication with your recordkeeper to make a smooth transition and minimize potential disruptions to your internal staff that are supporting these changes.

Lastly, you can keep tabs on all the changes in our SECURE 2.0 Plan Sponsor Checklist.

Plan for Multi-Stage Employee Communication

In making this transition to the new SECURE 2.0 provisions, it’s a good idea to plan your employee communication carefully. Since a number of changes are coming up, a multi-stage communication strategy can help create awareness and understanding among employees. 

Begin by announcing the upcoming changes and providing a brief overview of how they affect your employees. This initial communication should be clear, concise, and informative, giving employees a basic understanding of what to expect. 

Next, dive deeper into the specific provisions that are most discussed and asked about, especially on topics that impact employees’ retirement planning. Offer detailed explanations and resources to help employees understand the changes and how they can benefit from them. This stage is critical to keeping employees well informed and feeling confident in their retirement planning decisions. 

Finally, host Q&A sessions and provide additional resources to address any lingering questions or concerns. These sessions can be conducted as webinars or in-person meetings, allowing employees to ask questions and clarify any confusion. Provide written materials and online resources for employees to reference as needed. The good news is your plan recordkeeper will likely be in a position to assist you with some or all of these additional communication resources.

Review Impacts to the Employer’s Budget

Implementing the SECURE 2.0 Act provisions will likely have financial implications for your organization. Begin by assessing the costs associated with implementing the new provisions, such as technology upgrades or additional administrative tasks. At the same time, estimate potential savings from voluntary provisions like the tax credit for small businesses that adopt automatic enrollment. 

Adjust your organization’s budget to accommodate these changes. Allocate resources for necessary updates and adjustments, and balance the budget to maintain financial stability. Be prepared to reallocate funds as needed to help implement a smooth implementation of the SECURE 2.0 Act provisions. 

Is Your Plan Ready for SECURE 2.0?

The list of rules and regulations businesses need to follow in both the SECURE Act as well as the SECURE Act 2.0 can be daunting and overwhelming. If you’d like help preparing for these changes and more, we’d welcome the opportunity to assist you. At PlanPILOT, we have been navigating legal and regulatory changes as qualified plan consultants for over 20 years. If you’re ready to take the next step with your employer-sponsored retirement plan, we would love to hear from you. Call us at (312) 973-4913 or email mark.olsen@PlanPILOT.com to get started today.

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), 403(b), and 457 plan sponsors. 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.

By Mark Olsen, Managing Director at PlanPILOT

Choosing the right advisor is essential for employers who want to offer their employees a high-quality retirement plan. The right advisor can help plan sponsors navigate the complex world of retirement planning, keep them up to date with the changing landscape of legal and regulatory requirements, and verify that the plan meets the needs of the company and its employees. However, not all advisor partnerships are created equal, and plan sponsors need to assess the suitability of potential advisors before making a decision. Read on to learn more about what to look for in a qualified plan consultant and how you can make the best decision for your company.

Client Services

A clear and effective client services model is essential for building a successful partnership between the plan sponsor and advisor. Plan sponsors should ask potential advisors about their approach to client service, including their communication and reporting practices, and how they handle your questions and concerns. 

The advisor should have a well-defined client services model that aligns with your expectations and needs. This includes flexibility with virtual versus in-person meetings, proactive decision support when significant regulatory changes occur (e.g., SECURE 2.0), as well as the availability of online resources, such as educational materials and calculators. A commitment to client services is the foundation for a strong advisor partnership.

Conflict-Free Business Model

Another important factor to consider when assessing the suitability of advisor partnerships for retirement plan sponsors is the advisor’s business model. Plan sponsors should look for advisors who have a conflict-free business model, which means they don’t receive any compensation from third-party providers for recommending their investment products or services. This is important because it ensures that the advisor’s recommendations are based solely on the best interests of the plan sponsor and its participants, rather than any financial incentives. 

You’ll also want to assess whether the advisor is acting as a fiduciary and if so are they willing to put that in writing in the client agreement. A fiduciary is an advisor who is legally obligated to act in the best interests of the plan sponsor and its participants. Fiduciary advisors must avoid conflicts of interest, disclose all fees and compensation, and provide impartial advice. Be sure to ask potential advisors if they are fiduciaries and how they plan to fulfill their fiduciary responsibilities.

References and Reputation

Anyone can say they are a fiduciary with a robust client services model, but the proof is truly in the pudding when it comes to whether they can back up those statements with a strong reputation and positive client references. When assessing the suitability of advisor partnerships for retirement plan sponsors, it is crucial to consider the advisor’s years of experience, client feedback, responsiveness to client questions, communication skills, and the number of clients serviced.

Plan sponsors should also ask potential advisors for references and speak to current or former clients about their experiences working with the advisor. This can provide important firsthand knowledge about the advisor’s strengths, weaknesses, and overall suitability for the plan sponsor’s needs. Through speaking with references, you can gain a more complete picture of the advisor’s capabilities to be confident you’re making an informed decision.

How PlanPilot Can Help

At PlanPILOT, our well-developed client services model, commitment to conflict-free business, and stellar reputation have set us apart from other qualified plan consultants for over 20 years. We are dedicated to creating and maintaining the best plans for you and your employees. If you’re ready to take the next step with your employer-sponsored retirement plan, we would love to hear from you. Call us at (312) 973-4913 or email mark.olsen@PlanPILOT.com to get started today.

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), 403(b), and 457 plan sponsors. 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.

By Mark Olsen, Managing Director at PlanPILOT

Planning for the year ahead is critical to ensure we are prepared to meet our clients’ needs and deliver valuable insights in a timely manner. In this article, we outline the themes and activities we expect to be key priorities in our work with clients throughout 2023, as well as inform our thought leadership in the year ahead. 

Beyond “If and When”, Onto “What to Do”

We first want to share that we are picking up on a shift in the way plan sponsors are operating in oversight of defined contribution (DC) plans. In fact, through our work, we’ve observed plan sponsors want to know what to do, the best way to tackle problems and seek solutions, and to understand the practical implications of their activities in plan oversight. We anticipate this shift to underpin all of our work with clients in the year ahead.

Top Priority Themes

• Changing Landscape and Assessing Suitability of Advisor Partnerships.  The retirement provider landscape — in whole — is layered with complexity and the potential for conflicts of interest. Increasing merger and acquisition activity among providers to support the growing need to identify sustainable revenue streams and the push for product placement, and it adds up to a complex arena for plan sponsors to navigate when selecting a partner in retirement plan oversight. Plan sponsors face the need to assess matters of independence and to ensure their advisor is philosophically aligned to their organization’s values, objectives, and needs. The changing landscape and concern over conflicts of interest brings into focus the importance for committees to conduct thorough due diligence and assess the suitability of their provider partnerships. It is our belief that it is vital to ensure that the priorities of both the client and the advisor are in alignment.  This topic will be a central tenet in our work with clients for the year ahead.

 

• Collective Investment Trusts in 403(b) Plans – Institutional employer-sponsored DC retirement plans, including 401(k) plans and governmental 401(a) and 457(b) plans, have enjoyed the benefits of collective investment trusts (CITs) for the better part of fifteen years. Over the last several years, legislators have worked to pave the way to allow CIT use in 403(b) plans, which is currently not permitted. In late December 2022, SECURE 2.0 passed (1), opening up the potential use of CITs in 403(b) plans. There was a loophole in the final regulations which requires a revision to federal securities law in order for CITs, as well as pooled Stable Value funds to be permitted in 403(b) plans. There are pros and cons to CITs, but in aggregate, the greatest benefit is cost efficiency. We expect the topic to be front and center in 2023 as we prepare our clients for using these vehicles in 403(b) plans. 

 

• Environmental, Social and Governance (ESG) Finalized – All eyes have been on ESG over the last several years. Actual implementation and use of ESG options in DC plans have remained fairly lackluster to date. However, the overall interest in ESG is not dying down. In fact, the complexity of the topic is increasing – with much debate about the value proposition of ESG and the question of how, and even if, plan sponsors should incorporate ESG in DC plans. The Department of Labor’s Final Rule on ESG – Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (2) clarifies that the changes to the regulation enable fiduciaries to factor in the impact of a broader range of ESG factors on investments. The DOL clarified that the amended regulation continues to require fiduciaries focus on relevant risk-return factors. It also makes clear that fiduciaries cannot take on excessive risk or sacrifice returns in the ESG pursuit. We anticipate the debate and evaluation process to continue as plan fiduciaries consider ESG investing. 

 

• Custom Qualified Default Investment Alternatives (QDIA) – Last year, we wrote about the broad range of QDIA offerings and the evolution in the choice of solutions. In 2023, we anticipate the demand for customization of the default alternative in defined contribution plans to gain momentum. The appeal of a custom solution is that it allows for tailoring of the glide path and underlying investments to your plan objectives and investment beliefs. Often, custom solutions are more appealing to larger plans as scale and buying power make the endeavor more cost effective. As DC plans continue to grow and evolve, we expect this trend to be a focus area in 2023 in our work with clients, particularly given the ability to tailor the design of the default to the unique needs of individual plans. The assessment process for selection, implementation, and monitoring is vital to get right, and it is now more important than ever given the role of the default offering in achieving successful retirement outcomes. 

 

 

• Retirement Income Solutions – In our paper series last year, we covered the broad array of solutions and provided suggestions for plan sponsors in the retirement income pursuit. We expect 2023 to bring more deliberate retirement income solution assessments and pursuits. Specifically, plan sponsors are moving toward assessments that review retirement income offerings based on the unique characteristics of the offering and alignment to plan needs. In other words, retirement income pursuits are aimed at integrating a solution or a range of solutions for purpose.

 

 

• Raising Risk Literacy in Plan Oversight – We covered how risk comes in many forms in our paper series last year. The last year has accentuated this point – bringing into focus the reality of experiencing these various risks inside of retirement plans. Inflation has remained high, interest rates have been on a steady increasing trajectory, volatility and downside risk have crept into the market environment, and participants understandably are reacting, with 401(k) withdrawals on the rise and hardship withdrawals at an all-time high in 2022. (3) The reality of the range and impact of the various risks faced in retirement plan oversight, and ultimately affecting participants, will be central to plan sponsor work in 2023.

 

• Importance of Staying Vigilant with Litigation on the Rise – The number of class action 401(k) and 403(b) lawsuits in 2022 was significant, due in part to the U.S. Supreme Court decision vacating a Seventh Circuit decision (4) in early 2022. The decision makes it easier for plaintiff lawsuits to survive motions to dismiss. As a result, we can expect this steady trend of lawsuits connected to plan monitoring and excessive fees to remain in focus… requiring plan sponsors to stay vigilant in their plan work.

Stay Tuned!

These themes… and more will shape our work and inform our client partnerships in 2023. You can expect us to produce thought leadership to illuminate the importance of each of these priorities, as well as provide actionable insights for you and your committee to leverage in your day-to-day plan oversight. Rest assured that we are prepared to help our clients tackle these topics effectively. We also welcome and value your input. If there are topics you would like us to add to our thought leadership list, please get in touch with us. 

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), 403(b), and 457 plan sponsors. 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) Securing a Strong Retirement Act of 2022, H.R. 2954 https://www.congress.gov/bill/117th-congress/house-bill/2954/text

(2) https://www.federalregister.gov/documents/2022/12/01/2022-25783/prudence-and-loyalty-in-selecting-plan-investments-and-exercising-shareholder-rights

(3) Source: Vanguard https://corporate.vanguard.com/content/corporatesite/us/en/corp/articles/vanguard-investor-pulse.html

(4) https://www.supremecourt.gov/opinions/21pdf/19-1401_m6io.pdf