Will DC Plans See More Robo Advice?

Defined contribution plans are not likely to use robo advisers in the near future, but may begin to if the innovation develops, sources say.

According to Alison Borland, senior vice president of retirement strategy and solutions at Aon Hewitt, the use of robo-advisers is not sparking a lot of interest from the large plans Aon Hewitt services. “Most large plans already include some level of advice, some of which is automated, and not very different from a robo-adviser,” she tells PLANSPONSOR. Whether the plan uses a third-party advice provider or not, most plan sponsors already do provide the advice without an explicit fee to participants, though there is generally a cost to the plan.

“I don’t expect plan sponsors to go out and pull in an app-like online experience until it can be integrated with existing offerings,” Borland maintains. Most plans already have access to an automated solution, she notes, adding that she thinks more competition and more offerings will be positive, since they can put cost pressures on the existing solutions. But meanwhile, she does not expect plan sponsors to go looking for additional help. “They’re not willing to scour the market for third-party solutions.”

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Borland notes that the terms are still confusing. “The difference may not be clearly defined in the marketplace,” she says. “When the industry talks about robo-advice, they generally are referring to the low-cost to no-cost tools that are out there that can manage or allocate investments in a very efficient, cost-effective way.” This is a misnomer, and defined contribution plans already have access to solutions that do that.

“Robo-advisers provide low-cost asset allocation where it was not available before,” she says. “The cost of having someone manage your account as a retail investor is quite high. Access to it in a plan is much more cost-efficient if you’re talking about actual discretion management—perhaps there’s a flat fee or much lower cost.

The size of the plan rather than fees will be a determining factor, Borland says. The level of scrutiny and oversight in the defined contribution plan space are very different from that in the retail world, she observes, but concedes that pressure on providers and more automation tends to lower costs.

It’s possible, but not likely, that plan sponsors will send participants to robo-advisers directly, says Chris Jones, chief investment officer of Financial Engines. “None of the current group of robo-advisers seems to be targeting plan sponsors as their primary way of acquiring customers,” he tells PLANSPONSOR. 


Next: What’s holding back wider-spread adoption of robo-advisers?
 

“Most robo-advisers require you to move your money to their platform in order to receive advice and management. You don’t have that luxury as an employee with a 401(k),” Jones says. Other factors that could impede plan adoption: none of the robo-advisers has the infrastructure to execute trades on the recordkeeping platforms yet, hampering their ability to support large-scale targeting of defined contribution plan participants, he points out.

The use of robo-advisers will mostly fall to individual investors seeking services from these firms rather than plan sponsors directing large numbers of participants to them, Jones predicts. “There are already established independent advice providers in the 401(k) market that provide these services, and most robo-advisors are targeting younger, affluent taxable investors,” he says.

From a more general perspective, Jones believes the influx of new firms offering investment advice facilitated by technology is positive for several reasons, such as increased choice for consumers and pressure on existing providers to improve services.

“However, there are significant differences in the quality and philosophy of the advice being provided by different firms,” Jones says. “It will take time for the market to separate out the high-quality firms from the lower quality ones. Plan sponsors make a fiduciary decision when they select an adviser for their participants.”

Whether implementing robo technology in a plan will affect the cost of providing advice to participants is still uncertain. Jones comments that the robo-advisers are putting pressure on the traditional advice and management business model. “With today’s technology, it is possible to provide high-quality advice at a lower cost,” he says. “However, many participants want to talk to a human adviser as part of their experience. I expect that the robo-advisers will contribute to an already established trend of greater price sensitivity and focus on value for fees in the financial services industry.”

Todd Clarke, chief executive of CLS Investments, sees robo-advisers as an advice solution that will fit some retirement plans, but the option is unlikely to have any effect on the cost of providing advice to participants. “We charge the same whether you eat in our restaurant or go through our drive-through,” he tells PLANSPONSOR, only half joking. The reason is that CLS delivers the same service whether it’s via technology or in a face-to-face session, he explains. “We’re putting in the same amount of work behind the scenes in managing our portfolios. Our advice is our advice. It’s just a different way to package it.”

“There are many complexities that exist in the 401(k) world that do not exist with standard brokerage accounts,” Jones says. “It will take some time for the robo-adviser firms to adapt their services to meet the needs of sponsors and participants.”

You Failed Nondiscrimination Testing, Now What?

Plan design can help retirement plans pass nondiscrimination testing.

 

According to a survey from Judy Diamond Associates, nearly 60,000 401(k) plans failed Internal Revenue Service (IRS) nondiscrimination testing, with more than one in 10 issuing corrective distributions to highly compensated employees (HCEs) in 2012.

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“The plan design is by far the best way to get to a point where more employers are passing their nondiscrimination testing,” says Geno Cufone, senior vice president, retirement administration, at Ascensus in Dresher, Pennsylvania. “But you have to consider whether or not they have the wherewithal to afford doing some type of employer match.”

He says there are three factors that determine whether or not the plan will be prepared for the next round of testing: plan design, employee behavior and continuous monitoring.

“From a plan design perspective, automatic enrollment will definitely provide the best opportunity for getting your non-highly compensated employees [NHCEs] into the plan, to offset the contributions of the highly compensated employees,” Cufone notes. If rank-and-file workers are not making sufficient deferrals, the plan sponsor should try to change employee behavior. One—admittedly unpopular—possibility is to have HCEs cut down their deferrals. “Ask them to contribute a little bit less if they know that [otherwise] they’re going to be getting a refund.”

The best thing for the plan and for participants, Cufone says, is to “influence the non-highly compensated employees to contribute more if you see that you’re falling within the range where, potentially, you’re going to fail.” He recommends sending out targeted communications to urge participants to increase their deferrals. “We know it’s in their best interest to contribute more to the plan, and you get the added benefit of having a greater opportunity to pass your nondiscrimination testing.”

 


 

What is most advisable for plan sponsors, Cufone says, is to regularly monitor the plan and look at participants’ deferrals in order to avoid reaching that point. Otherwise, the plan may want to adopt a safe harbor employer contribution, to avoid testing altogether.

“If you can afford to do that, choosing a safe harbor basic employer match will eliminate the need for testing at all. Offering a safe harbor match contribution—100% of the first 3% of compensation employees defer and 50% of the next 2% they defer—eliminates the need for both ADP [testing of employee deferrals] and ACP testing [of employee after-tax and employer contributions], and then you get the added bonus of not having to do top-heavy testing as well,” he says. “Another option is to offer a 3% nonelective contribution to all employees in the plan, regardless of whether or not they’re contributing. By doing that, you no longer have to do any of the required testing.”

With regard to actual deferral percentage (ADP) and actual contribution percentage (ACP) testing, Cufone says, “In our experience, [a plan’s failure] really depends on how long the plan has been in existence and whether or not the plan administrator at the employer has had any experience running a 401(k) plan in the past. Especially with start-up plans, plans that have just begun, there does seem to be a surprise element, more often than not.”

To avoid being caught off-guard, he recommends that plan sponsors provide complete census information to their recordkeepers on an ongoing basis and have their recordkeepers test their plans mid-year to see where participants fall. “The more information that they provide … to the recordkeeper, the better prepared we can make them, to ensure that they don’t fail,” Cufone says.

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