Cash Balance Plans Gain in Popularity

Combining features of DB and DC plans, these hybrids especially appeal to small and midsize businesses.

Cash balance retirement plans are the fastest-growing sector of the retirement plan market, with more than $1 trillion in assets nationwide, say findings from FuturePlan by Ascensus, a third-party administrator.

According to the “2020 National Cash Balance Research Report,” the firm’s most recent data, the number of new cash balance plans increased 17% from 2017 through 2018, versus just a 2% growth in new 401(k) plans. There are two factors driving the growth: 1) The plans provide a way for small to midsize businesses to receive a significant tax cut for employee contributions to the plan, and 2) they allow participants to accelerate retirement savings on a tax-advantaged basis beyond what they could put into a 401(k).

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FuturePlan defines cash balance plans offered by large businesses as those having more than 10,000 participants, but these plans generally are conversions from older, traditional defined benefit plans, the report says.

In a tight labor market, the cash balance plan’s benefits could also be a way to attract talent, as opposed to offering equity in a business, says Jerry Cicalese, senior vice president of strategic partnerships at Sentinel Group. As these plans become more popular, industry experts say, business owners looking to implement a plan or companies seeking to convert their traditional defined benefit plan must work to explain carefully these plans’ complexity and their pros and cons.

How Cash Balance Plans Work

Cash balance plans are defined benefit plans that accrue assets in two ways: a pay credit, which is the employer contribution, and a guaranteed interest credit rate, the mandated participant earnings, says Daniel Kravitz, FuturePlan’s cash balance practice leader. As with traditional defined benefit plans, the employer bears the risk of the investment performance.

The Department of Labor describes cash balance plans as a type of DB plan whose promised benefit resembles that of a defined contribution plan—i.e., having a stated account balance.

They’re often called hybrid plans because they have the look and feel of a DC plan, says Kristy Wrigley-Durer, senior counsel at law firm Crowell & Moring. The accounts are hypothetical, however, as payments are calculated based on a formula like any defined benefit plan.

Also like 401(k)s, the plans are portable, so participants may take their savings with them when they leave the employer and either roll the amount into an individual retirement account or a plan at their new employer. “Withdrawing yourself from a traditional DB plan is nearly impossible,” notes Bob Smith, president at Sage Advisory. “That portability is a major attraction for the cash balance plan.”

The Source of Cash Balance Growth

Big corporations with traditional DB plans have converted them to cash balance plans because the latter remove the interest-rate risk that led to the constantly changing value of liabilities in that traditional DB, the FuturePlan report says. Additionally, the cash balance plan structure allows for more consistent contributions to employees, rather than basing contributions by age. That also keeps business’s costs down as, under traditional plans, employee costs rose as workers neared retirement age.

FuturePlan’s research shows the greatest growth in cash balance plans to be in small to midsize businesses with fewer than 100 employees—especially, over the past seven years, in companies with fewer than 25 employees. Pension Benefit Guaranty Corporation coverage and fees start once more than 26 employees have enrolled in a cash balance plan, says Steve Sansone, a managing director at SageView Advisory Group.

Often, one of these plans is offered along with a 401(k) as another way for participants to save, income tax-deferred, beyond the DC plan’s combined employee/employer contribution limit—for 2023, $66,000. High-income participants in the cash balance plan could receive up to $300,000 in contributions on their behalf annually—up to $3 million over their lifetime, indexed to inflation

The plans are popular with professional service firms, such as those operated by doctors, lawyers, investment advisers or other professionals, where much of their income is taxed as ordinary income, Kravitz says.

Bob Smith, president of Sage Advisory Services, says a key reason for a small to midsize firm to offer a cash balance plan is it enables sheltering considerable taxable income beyond the 401(k) limits. The type of earner who profits from the tax-sheltering benefit is one who makes $300,000 or more. If the partnership or business owner can’t afford to take advantage of the income-tax savings, “then there’s no reason to have one [of the plans],” Smith says.

The lure of a cash balance plan is that high earners can accelerate tax-deferred savings, but to open a plan, the IRS requires that companies pass discrimination and coverage tests. To reap the biggest of the tax savings for their high earners, companies must be able to contribute 5% to 7.5% of employee compensation into a profit-sharing 401(k) that benefits all their employees, Sansone says.

“The owners are getting large deductions, but the rank and file are getting 7.5% of pay. It’s a very generous contribution,” he says.

Because these are Employee Retirement Income Security Act plans, they are sheltered from creditors in case of bankruptcy or lawsuit, Cicalese says.

Points to Consider With These Plans

Cash balance plans require actuarial work and cross-testing, making them about two to three times more costly than a 401(k) plan design, Sansone says. Contributions must be made annually, so the plans work only for firms that are consistently profitable—able to make the payments to all the employees; this is different than in a 401(k) plan where companies can easily freeze employer contributions.

Sansone says there are certain circumstances under which plans may be frozen. He did that for some plans in 2020, after COVID-19 hit, since plan participants hadn’t reached 1,000 hours of service for the year, which is one way to legally freeze contributions.

The plans are also legally binding. Kravitz says they must define the pay credit, which can be a percentage of pay or a fixed dollar amount, and specify the guaranteed interest crediting rate. Kravitz uses a 4% fixed crediting rate. For example, a medical group with a shareholder doctor may have a contribution credit of $250,000, and the employees receive a pay credit of 8%, plus a guaranteed return of 4%.

It’s hard to exactly hit the interest credit rate annually, so sometimes plans can be slightly over- or underfunded. If a plan is underfunded in a given year, there are a few options the company may use to bring the plan to full funding, including contributing more in a one-time payment to cover the shortfall, Sansone says.

Making up any shortfall is necessary because, if the plan runs into significant deficits, this affects portability, Smith says.

More recently, some plans have started using a variable crediting rate instead of the fixed crediting rate. Using a variable rate allows the plan to use the investment performance of its assets for a particular year vs. a fixed amount as the credit rate, Sansone says. This helps address the occasional underfunding. However, any shortfalls that do occur must be trued up when a plan participant leaves.

Since the costs to start and terminate a plan are high, business owners should plan to operate these plans for at least three to five years to make them economical, Sansone says. There is no formal IRS rule stating how long a cash balance plan must exist; the agency’s point of view is that the plans should have some permanency.

Cicalese says that’s why cash balance plans are for well-established businesses with a history and a pattern of earnings to support contributions. He says his firm designs these with the idea that they’ll be open for five years, while the maximum benefit to the participant comes by year 10. The plans have some flexibility; they can be frozen or amended if the benefits are too rich, and the plans may be terminated, but the IRS requires good reasons, he says.

“You need to go into this with the mindset that I’m going to make at least three years of required contributions,” he says.

End Of The Road For Defined Benefit Plans? Not Quite

While the vast majority of DB plans are frozen, plan sponsors are keeping all options on the table for participants.

When talking about defined benefit plans, it’s mostly in the context of how plan assets are being managed with the understanding that the vast majority of these plans are closed to new participants, and plan sponsors are probably considering a risk transfer or lump-sum payouts at some point in the future. But are defined benefit plans truly a thing of the past?

Not entirely, says Emily Hylton, an Atlanta-based senior vice president and investment consultant at Callan. Some employers are still offering defined benefit plans as a means of attracting and retaining talent. Others have shifted to cash balance plans, a type of defined benefit plan that defines the promised benefit in terms of a stated account balance.

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Offering defined benefit plans can be a boon for companies that want to attract talent and are willing to take on long-term obligations. In a survey of both Millennials and Baby Boomers, the National Institute on Retirement Security found that the majority of respondents from both groups believe having a pension is important and said they would stay at a job that offered such a benefit. That finding is notable, given that Millennials entered the workforce at a time when pensions were not typically offered. The data suggest that plan participants understand the need for and desire lifetime income but are not totally sure how to achieve that on their own.

“I think what we’re seeing is a recognition that the current system doesn’t work that well,” explains John Lowell, an Atlanta-based partner in retirement consultant October Three. “Even within older age groups that might still have a defined benefit, those participants are working longer and/or may not be able to retire for a whole host of reasons. The first age group that was defined-contribution-only is also now nearing retirement, and many of them are faced with the same issue: Account balances aren’t enough, and when they look at annuities, for example, the lifetime income offered is much less than they anticipated it would be.”

Curves ahead

These dynamics put plan sponsors in a tricky position. Currently, closed defined benefit plans will still be paying out benefits to participants for many decades to come and are unlikely to be reopened. Retirement consultants say plan sponsors are hesitant to take on new long-term obligations because of the associated cost and regulatory hassles . But plan sponsors may end up with a different set of headaches by focusing just on defined contribution plans. Older employees may choose to stay in positions longer, which could limit new hiring opportunities. Younger employees may feel less loyalty to employers if there is no long-term benefit to staying in a role.

There are also issues with sunsetting existing defined benefit plans. Pension risk transfer, liability-driven investing and lump-sum payouts are all tools plan sponsors can use, but each requires certain funded status and often takes a significant amount of time to implement.

“There are trillions of dollars in defined benefit plans right now, and even coming off a big year for pension risk transfer, that solution only represents about 3% of the market,” explains Ari Jacobs, a senior partner in and the global retirement solutions leader at Aon. “I don’t think you can say all defined benefit plans are eventually going to end at a risk transfer. There are too many factors at play, and the plan sponsors we are working with are leaving all options on the table. The other thing to remember is: Each plan is unique, and plan needs will change over time, so we’re seeing plan sponsors try to be as flexible as they can.”

Lifetime income

Arguably, the chief advantage of a defined benefit plan is lifetime income. Whether that income is delivered through the plan itself or eventually through an annuity, the predictability gives participants peace of mind.

However, offering participants lifetime income in defined benefit plans that have lower coverage can be challenging. Risk transfers or lump-sum payouts may solve the equation for plan sponsors, but they can create a new set of issues for plan participants. October Three’s Lowell notes that annuities have a bad reputation with many participants, and lump-sum payouts put participants that were in defined benefit plans in the unique position of having to create a fixed income for themselves, similar to participants in a defined contribution plan.

Hylton notes plan sponsors are faced with a bit of a conundrum.

“I don’t think there’s an appetite to reopen a lot of these plans, but there is a greater recognition that something needs to be done in terms of lifetime income,” she says.

Matt McDaniel, a partner in and the U.S. pension strategies and solutions leader at Mercer, agrees.

“I don’t want to go so far as to say we’re at an inflection point,” he says. “But there are questions about long-term obligations, and we’re also getting data from the first generation of workers that were defined-contribution-only showing that the account balances really aren’t sufficient enough to retire with. As more people retire and that problem grows, I think we could see the tide start to shift back toward something that looks more like defined benefits, but it’s hard to say what that ultimately looks like.”

SECURE 2.0 and the Future

Provisions in the recently passed SECURE 2.0 Act of 2022 seemed to pick up on this dynamic. Lowell notes that cash balance plan-focused provisions fix some of the tax and regulatory hurdles that have kept plan sponsors from offering cash balance plans in the past.

“These provisions haven’t gotten the same attention as others in the [law], but they are important,” he says. “They give plan sponsors the option to do a market-based rate of return such that the assets and liabilities are moving together without the kind of volatility we have seen in the past. That makes it easier for CFOs to model these plans, and when you have cost stability, that makes it more palatable to plan sponsors.”

Other provisions in the law will make it easier for plan sponsors to offer annuities and synthetic annuities to plan participants. Although work may yet need to be done to overcome the hesitancy that plan participants have about adopting annuities, consultants say.

Looking ahead, these provisions offer a base from which plan sponsors can continue to make refinements based on feedback from participants. Mercer’s McDaniel says that rates of product adoption typically determine which solution set becomes the most widely used.

“The retirement space tends to move incrementally,” he says. “If you look back 30 years ago when defined benefit pension plans were common, there wasn’t one single moment when the whole industry shifted to defined contribution. It was an accumulation of changes over time. I think plan sponsors are going to continue to weigh their options and get feedback from participants, and we’ll see more incremental change. So it’s possible we could look up 10 or 15 years from now and things are very different, but it won’t be one moment where everything shifts back to defined benefit. It’s more likely that we end up with something that looks like more of a mix of defined benefit and defined contribution features.”

 

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