In
a comment letter to the Internal Revenue Service (IRS) about its proposal to
eliminate its determination letter program for individually designed plans, the ERISA Industry Committee (ERIC) asked the
IRS to reconsider.
ERIC
argues that most large employers do not use predetermined or “off the shelf”
retirement plans, instead choosing to individually design plans that best
benefit their workforces. “The IRS’s proposal to eliminate determination
letters for these types of plans would disproportionately and unfairly affect
large employers and their retirement plans. The inability to prove that a
retirement plan is in compliance with current tax laws and plan provisions
would create chaos,” ERIC said.
Annette
Guarisco Fildes, president and CEO of ERIC, wrote, “Large employers routinely
make changes to their retirement plans to conform to new laws or regulations,
to reflect a merger, acquisition or spin-off, or to implement new and
innovative changes that are in the participants’ best interest. Limiting the
ability of large employers to receive the IRS’s ‘seal of approval’ regarding
tax qualification status is potentially devastating, because it would create
uncertainty for the plans and plan participants, as well as undermine the
ability of companies to execute mergers, acquisitions and spin-offs.”
ERIC
recommends that the IRS allow certain large plans to continue to apply for a
favorable determination letter, similar to the approach currently in effect,
but limiting the burden on the IRS resources by substantially reducing the pool
of qualified applicants. “By limiting the determination letter approval program
to extremely large employers, those with 15,000 or more participants, the IRS
will not only ensure the smooth administration of large employer plans, but
will also guarantee that it uses its limited resources efficiently,” said
Guarisco Fildes.
Recordkeeper/Adviser Partners Key for Plan Success
Two senior retirement industry executives—one from an
advisory firm and one from a recordkeeper—discuss how the two types of service
providers can work together for better plan sponsor outcomes.
Our sister brand, PLANADVISER, held its national conference
this week in Orlando. As part of one panel, two experts discussed how advice
and recordkeeping service providers can work together for better plan sponsor
outcomes.
According to Joe Ready, executive vice president of Wells
Fargo Institutional Retirement and Trust, dedicated retirement plan advisers’ most
effective service delivery partner should be their recordkeeper. If it isn’t,
it’s time for them to find another recordkeeper.
“Mutual agreement upfront and mutual service from the
recordkeeper and the adviser are foundational to good plan sponsor outcomes,”
Ready said. “When the recordkeeper supports the adviser, and the adviser knows
the recordkeeper inside and out, it absolutely leads to better ideas and better
best practices.”
Working together throughout the process of running a
retirement plan will certainly bring better outcomes and increased satisfaction
from the plan sponsor, agreed Randy Long, managing principal at SageView
Advisory Group. He observed that, earlier in his career, winning a new advisory
client almost always meant converting them to a new recordkeeper.
“Today the process essentially works in reverse,” he
explained. “Starting in the last 10 or 15 years, the industry has really
evolved, and we’re commonly winning new clients through our recordkeeper. It’s
a client on the recordkeeping platform looking for a new adviser, which only
makes things easier from the participant perspective.”
The benefits that arise from close coordination between
adviser and recordkeeper are myriad, the pair explained. From greater plan
management efficiency to more advanced reporting and faster data updates, a
skilled recordkeeper/adviser team can really turn up the heat on plan view-ability
and performance.
For those advisers who feel it’s important to maintain a
coolheaded distance from the recordkeeper in order to promote an image of
independence and transparency among clients, Long says that’s great, but this
doesn’t mean the adviser has to coordinate less with the recordkeeper or be a
less-effective partner.
“You can maintain your independence while presenting
services in a highly coordinated and effective way,” Long said. “That’s
something we have strived pretty successfully to do, I think. Just remember,
the end goal is always to put the client first and keep the client happy, both
for adviser and recordkeeper.”
NEXT: (Careful)
collaboration is key
While more-effective partnering between recordkeeper and
adviser can improve efficiency for all plan stakeholders, Long and Ready agree
that problems can arise, especially when duties are not carefully and clearly
divided among service providers.
“For success with adviser and recordkeeper, keeping the
duties and responsibilities clear will always be a key effort,” Ready said.
“Successful collaboration means maximizing use of data by all parties and proactively
creating the best relationships we can among the sponsor, the adviser and the
recordkeeper.”
Ready said one area in particular where advisers and
recordkeepers should work more aggressively together “is around the
cost-versus-value question,” referring to the ongoing market trends squeezing
advisory and recordkeeping pricing closer to unsustainable levels from a
practice management perspective.
“I don’t think recordkeepers or advisers have done a good
job on navigating and taking charge of this cost-versus-value question,” Ready
explained. “Neither side has done a particularly good job enumerating the value
of our service deliverables. Instead we have focused on rolling out shiny new
tools and services to try and justify our pricing. It’s unsustainable when you
think long term and our challenge, industry wide, is to do a better job
demonstrating our costs and how this relates to the value that is delivered.”
Long agreed: “If you think about what a given participant
actually gets for his $100 or so in recordkeeping costs each year, it’s a huge
value. Think about everything else you spend $100 on in a year and it’s
probably worth a lot less than access to investments, asset custody and all the
other services a recordkeeper actually provides.”
Both speakers concluded that recordkeepers, with their
troves of data and ability to pull reports on demand, are particularly
well-positioned to help advisers map out the value they are delivering to a
plan. As Long explained, they can help the adviser identify and broadcast gains
in key plan performance metrics experienced by the typical client, for example.
“We just haven’t connected the costs to the outcomes,” Long
said. “We all know a $5 per year recordkeeping service is not going to deliver
strong value, but how can we make clients better understand this? It’s a
problem for advisers and recordkeepers to tackle together.”