The company will review and interpret a service provider’s Employee Retirement Income Security Act (ERISA)
Section 408(b)(2) fee disclosure document and plainly summarize its fees in
dollars, both direct fees and indirect fees paid by mutual fund companies. There will be no cost for this
service.
The company will also summarize its fees for providing the
same services in the same format, allowing for a side-by-side comparison. Employee Fiduciary proposed a similar fee
summary in their response to the Department of Labor’s request for comments related
to 401(k) fee disclosure reform.
“Current fee disclosure regulations only address a small
part of the needs of 401(k) plan fiduciaries,” says Eric Droblyen, president of
Employee Fiduciary, based in Mobile, Alabama. “Because the disclosure
document’s format is open to broad interpretation, many providers have used
this discretion to effectively bury fees in pages of dense language. Plan
fiduciaries are unable to sort out the fees they are paying. Our service is a
direct response to overcoming the inadequacies of the current regulations.”
June 4, 2014 (PLANSPONSOR.com) – The stable value market has changed significantly post financial crisis, says Josh Kruk, head of stable value portfolio management at Dwight Asset Management, and the evolution is ongoing.
This means plan sponsors, who are bound by a fiduciary
duty to regularly monitor and adjust their plan’s investment menu, must
identify and respond to new emerging risks and opportunities in stable value
offerings and fixed-income portfolios more generally. The matter is complicated
by the expectation that interest rates may rise in the short or medium term,
Kruk says, presenting a new and increasingly complex picture for sponsors and
workplace retirement investors.
Kruk and a number of other stable value experts addressed
the topic of fixed-income and stable value investments during a panel
discussion on the second day of the 2014 PLANSPONSOR National Conference, in
Chicago. Panelists reminded attending sponsors that, although conservative in nature, stable
value funds have a general investment objective of providing a greater return over time than money market
funds. One of the key strengths of a stable value fund is low volatility, Kruk says.
“This reliability of this asset class was really proved
during 2008 and 2009,” Kruk says. “On the whole, the asset class performed exactly
as intended during the crisis, and there’s not a whole lot more we could throw
at it than what we saw in 2008 and 2009.”
But
that doesn’t mean stable value products don’t carry risk, Kruk warns. The
stable value asset class may look simple on the surface, he admits, but the tranquil
exterior hides an absolute whirlwind of bond holdings, insurance arrangements
and wrap contracts that can challenge the understanding of even the most financially
savvy sponsors. It would be impossible to fully explain the inner workings of
stable value during one 45-minute presentation, Kruk says, so instead he teaches
sponsors about the key risks that should be monitored.
The first and probably most familiar risk for stable value is interest rate risk, he
says. Effective management of interest rate and extension risk within stable
value portfolios is particularly critical in the current environment, Kruk
says.
Interest rates in the U.S. have been hovering around all-time
lows for years, due largely to sustained downward pressure applied by the Federal Reserve or Fed.
Kruk and other panelists say they expect the Fed to carefully and slowly raise
rates as the economy continues to strengthen, perhaps to 3% for short-term rates by 2015. If rates rise slowly, stable value should be able to respond effectively, Kruk says, but a rate spike is always within
the realm of possibility should inflation surge.
“The impact of a significant increase in rates on the
market-value-to-book-value (MV/BV) ratios of stable value portfolios could be
substantial,” he says. “During the credit crisis, the industry witnessed MV/BV
ratios dip to the low 90% range in some cases.”
As Kruk explains, when the market value of a stable value
fund falls below its book value, the fund has essentially failed to deliver on
its objective of not giving up any value. “While
this prior episode was largely the result of credit-related stress, one could
envision a scenario where interest rate stress could lead to a similar outcome
in the future,” Kruk says.
Another risk to stable value from rising rates could result
from exposure to the agency mortgage-backed securities sector. It’s a complex
risk, Kruk says, but over-extension on mortgage-backed securities duration
could cause portfolios to hit the explicit caps on duration that many wrap
contracts for stable value products now impose, resulting in forced asset sales
that effectively lock in rate-driven losses.
The second risk is also somewhat familiar for sponsors, Kruk
says, and relates to credit and liquidity concerns. Following the financial
crisis, some stable value providers have narrowed the definition of acceptable
credit risk in investment guidelines. Changes have typically included the elimination
of high-yield exposure, Kruk explains, as well as tighter caps on the allocation
to lower-rated securities, especially those below BBB. Providers have also
sought to limit exposure to any single bond fund or insurance provider, Kruk
says. Still, credit risk is present at both the sector and issuer levels, and,
in some cases, through exposure to derivatives counterparts.
Periods of market stress can impair stable value liquidity, Kruk explains, causing transaction costs to increase due to wider bid/ask spreads. When crafting the investment portfolio for a stable value client, managers should take into account considerations of the portfolio’s liquidity profile and the impact that transaction costs may have on the investor experience across various market environments.
Some
plan-specific factors that garner the most focus, Kruk says, include
participant demographics, recent cash flow experience and the degree to which
plan participants move assets among plan options in response to external
influences, especially equity market performance. Due to the mechanics of
stable value withdrawals, persistent negative participant cash flow can exacerbate
any MV/BV deficit, Kruk warns.
The sponsor’s business and industry profile also may be
important in determining how best to construct the stable value portfolio, Kruk
says. Wrap contracts are structured to pay book value for plan participant
activities, but wrap providers will not bear unlimited risk for participant
withdrawals, Kruk explains.
“In fact, certain sponsor activities could result in the
payment of market value rather than book value, which under certain market circumstances can
mean significant losses for participants,” Kruk says. “Sponsors absolutely must
be aware of what these triggers are and be careful to avoid them. While there
is currently an average MV/BV premium in the industry, this may not be the case
in the future.”
Further, since wrap contracts expose sponsor clients to an
element of counterparty risk, effective ongoing assessment and management of
that risk is critical, Kruk says. Sponsors should certainly benefit from
employing a knowledgeable adviser or consultant who can assist with negotiation
and monitoring stable value contracts.
Finally,
the utilization of third party sub-advisers as part of an overall stable value
solution drives another important facet of risk management, Kruk says. When
properly selected and utilized, sub-advisers can add style diversification and
potential “group think” risk mitigation for the portfolio, he explains. However,
it is critical for sponsors to ensure their stable value manager is confirming
these sub-advisers have a sound investment process, good technology/physical infrastructure,
and sound internal controls.