How and When to Encourage Use of Managed Accounts

While some defined contribution (DC) plan participants may choose to invest in a managed account, there may be others who don’t choose to do so that would benefit from investing in one.

Many defined contribution (DC) retirement plans default participants into a target-date fund (TDF), but also offer managed accounts—financial planning solutions based on a participant’s personal financial situation utilizing an investment management approach.

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While some participants may choose to invest in a managed account, there may be others who don’t choose to do so that would benefit from investing in one.

Many in the industry are proposing managed accounts as a qualified default investment alternative (QDIA), says Jodi Epstein, partner with Ivins, Phillips & Barker, Chartered in Washington D.C., “But having a managed account as the QDIA means participants are not actively choosing it and providing more information about themselves, which would tailor the underlying investment selections to their specific circumstances. I have a difficult time seeing how fiduciaries can justify the cost of a managed account compared to, for instance, a target-date fund.”

The concept of a hybrid QDIA—one that initially defaults participants into a TDF then moves them to a managed account at a certain point, for example, an age nearing retirement—is gaining attention in the retirement plan industry. But, deciding when and how to move participants automatically from one product to another leaves Epstein with fiduciary concerns.

Epstein says, “If I had a committee interested in a hybrid QDIA, I would have them document how flipping a non-engaged 50-year old from a TDF at 15 basis points to a managed account at 45 basis points is prudent. The participant can opt out, but because this is the default option, they are by definition not engaged so they probably won’t opt out, and the managed account is twice as expensive and may or may not give them an advantage.”

Managed accounts are the default for 4% of DC plans, according to a 2018 Callan report, and the availability of managed accounts has steadily increased over the last decade, up from 6% of plans in 2005 to 55% of plans in 2017.

The data available about participants has increased exponentially from 2007 compared to today. According to a white paper from Morningstar Investment Management LLC, “The Impact of Managed Accounts on Participant Savings and Investment Decisions,” in 2007, most recordkeepers knew a participants age and plan balance—some recordkeepers also knew four other data points which included salary, savings rate, employer match and employer tiered match.

By 2017, most recordkeepers knew seven additional data points including salary, savings rate, brokerage account investments, location, loans, employer match and employer tiered match—some recordkeepers also know a participants retirement age, pension, gender and outside assets.  

Managed accounts as an opt-in investment

“Managed account adoption as an opt-in varies greatly from low single digits to 40%”, says David Blanchett, head of Retirement Research at Morningstar Investment Management, LLC. “The difference is based on plan sponsor support and how the managed account is integrated into promotion materials and on recordkeeper platforms.”

According to Mike Volo, senior partner, Cammack Retirement Group in Wellesley, Massachusetts, “The price of managed accounts has been driven down. They are typically 30 to 40 basis points on average which compared to, for example, a retail managed account at 1% of assets, on a relative basis is quite appealing.”

Managed accounts have been around for 40 years but they were slow to pick up momentum until the QDIA rules changed and they became a potential default. Volo says, “I’m still seeing the vast majority of plans using managed accounts as an opt-in solution. Adoption is usually in the single digits because participants are often not aware that the managed accounts are available.”

Encouraging managed account use

The big question is how and when to educate and encourage DC plan participants to engage with a managed account. “It all comes down to targeted communications,” Volo says. “The adviser working with the plan sponsor and the recordkeeper can outline a communication strategy to target the participants for which a managed account may be a good solution. Whether it’s based upon age, account balance or likely a combination of both, participants can receive targeted communications making them aware of the offering, explaining what it is, and that may increase adoption.”

Lorianne Pannozzo, senior VP, workplace planning and advice in Fidelity’s Boston office agrees that targeted communications have the most impact. “It’s a matter of who you send the value proposition to and let them actively opt-in to it.”

There is a very clear value proposition for a managed account—it’s personalized and suits those with more complex financial needs, Pannozzo says. “At Fidelity we have support tools to help a person decide whether or not they can invest their assets themselves or if they are a target-date fund or managed account type of investor. But in most instances, you are sending targeted communications and allowing the participant to decide for themselves what is right for them.”

From a plan sponsor fiduciary perspective, Epstein says it is much less risky telling participants a managed account is available rather than defaulting them into one. She would suggest to clients that they use verbiage such as “you may want to consider” or “you may want to learn more about this option and here’s how to do that.”

“If it’s available as an option, you certainly want people to know it’s there. And it’s fine to explain who it may be appropriate for—at what age or level of assets in the plan and out of the plan,” Epstein says.

Nathan Voris, managing director, strategy, at Schwab retirement services in Richfield, Ohio says, “It’s easy to talk about the pre-retiree and managed accounts because it’s more tangible. But if you look at the math there’s a lot of value for younger folks as well.”

He says there are advantages for the average Millennial to enroll in a managed account—the personalization, the savings effects that comes along with a managed solution plus participants tend to be stickier through periods of volatility.

Volo says, “It’s all about creating awareness—highlighting the benefits and features of a managed account. I do think for participants who have more complex needs, larger balances and outside assets, the features and benefits of managed accounts will encourage them to seriously consider one as an option.”

Will Changes to Hardship Withdrawal Rules Lead to More Plan Leakage?

Some industry sources believe the availability of more funds for hardship withdrawals and the elimination of the requirement to first take plan loans before hardship withdrawals will lead more people to use their retirement savings before retirement.

While some experts think new rules Congress legislated that the Internal Revenue Service (IRS) proposed regarding hardship withdrawals from 401(k) or 403(b) plans will not lead to additional retirement plan leakage, others say they could potentially have that effect.

IRS rules regarding hardship withdrawals cover two areas, says Amy Ouellette, director of retirement services at Betterment for Business in New York. The first is reasons a retirement plan participant may apply for a hardship withdrawal, and the second is the onus to describe why this is an immediate and serious financial need. Disaster-related casualty losses has been added to the list of reasons a participant may apply for a hardship withdrawal, Ouellette says, which now include:

● Medical expenses that are not reimbursed;
● Purchasing a primary residence;
● Avoiding eviction or foreclosure;
● Repairing damages to one’s primary residence;
● School tuition fees and room and board for a family member or beneficiary;
● Funeral expenses; and
● Disaster-related casualty losses

The proposed IRS rules add “primary beneficiary under the plan” as an individual for whom qualifying medical, educational, and funeral expenses may be incurred.

Previously, participants could only withdraw contributions to their 401(k)—not earnings or matches, she says. Now, however, participants may withdraw from those additional sources if the plan sponsor chooses, she says. There are certain differences in the rules about what sources of money may be withdrawn from 403(b) plans.

Furthermore, there isn’t a limit on how much a person can withdraw, according to Ouellette. For instance, if he is facing foreclosure or eviction, he could withdraw $200,000 or more. However, she adds, “The participant would have to back that up.”

Previously, participants had to exhaust plan loans available to them before taking out a hardship withdrawal. But, the IRS proposed rule would change that to permit sponsors to sidestep the loans to allow participants to go straight to the hardship withdrawal. Several experts say that because participants are required to repay the loans back to their accounts, loans are much more preferable than hardship withdrawals, which cannot be repaid.

“Unlike a loan, you don’t pay the hardship withdrawal back,” says Tom Foster, national spokesperson for MassMutual’s workplace solutions unit in Enfield, Connecticut. “That money is just gone and there is no way to make that up unless you increase your deferrals to your [defined contribution plan], but most employees taking out a hardship withdrawal are unable to do that.” Additionally, Foster notes, the funds are subject to taxes, and if the participant is younger than 59-1/2, he has to pay a 10% penalty.

Whether an individual is taking out a loan or a hardship withdrawal, those leakages typically set their retirement nest egg back by 14%, he notes.

Dominic DeMatties, a partner with Alston & Bird in Washington, D.C., says he believes Congress wants to make it possible for plan sponsors to permit participants to sidestep the loans before taking out a hardship withdrawal due to the immediate needs that these participants face. “Congress has recognized that for people under financial duress, it may not be practical for them to wait for the whole process of taking out a loan and then seek a hardship withdrawal,” DeMatties says. “So, instead of requiring someone go through two hurdles to get to an end game, they are making it possible for a person to just go through one hurdle, which takes less time.”

Snezana Zlatar, senior vice president and head of full service product and business management at Prudential Retirement in Woodbridge, New Jersey, agrees: “Congress has focused on individuals undergoing true hardship. In that context, we believe that the elimination of the loan requirement actually does make sense because if an individual is in a tough financial situation, loan repayments could very well be a financial burden to them. Additionally, loans may not be enough to meet their financial hardship.”

Mike Zovistoski, managing director at UHY Advisors in Albany, New York, says most of his plan sponsor clients have the paternal instinct. “They want to protect employees from themselves,” he says, so he does not expect many of his clients to permit their employees to take out a hardship withdrawal without first going the loan route.

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More plan leakage expected

However, Mike Windle, a retirement planning specialist at C. Curtis Financial in Plymouth, Michigan, says that with so many people wanting to access their plan funds before retirement, he is afraid that this new provision could lead to more leakage. “There aren’t a lot of people hip to [this new legislation] yet,” Windle says. “But once people start to realize this is available, they are going to start to use it. [Defined contribution plans] were created to incentivize saving for retirement. To use the funds ahead of time puts us back at square one.”

DeMatties agrees: “Without a doubt, the new rule makes it easier for people to access money in the event they have a hardship. Where the jury is still out is to what extent participants will utilize these procedures and access the money even when they do not qualify for one of the seven reasons the IRS has spelled out.”

Discouraging plan leakage

Zlatar says one way retirement plan sponsors can discourage participants from taking out either a loan or a hardship withdrawal is by helping them set up an after-tax emergency savings feature. Prudential and other providers have already built into such features into their recordkeeping platforms. “Our position is that a short-term emergency savings option within the 401(k) plan is the best alternative to a loan or hardship withdrawal, which is why we make this available,” Zlatar says.

Educating participants about the need to establish a budget and an emergency fund should also be part of that equation, Foster says. A participant might rethink taking out a loan or hardship withdrawal if the sponsor requires them to sign a document outlining the downsides, he says.

Sponsors should also offer alternatives to plan leakage, such as health savings accounts (HSAs), long-term or critical illness insurance and information about low-cost loans, Foster adds.

A positive note

One positive component of the new rules is that people with hardship withdrawals will no longer be precluded from contributing to their 401(k) or 403(b) for six months, notes Chad Parks, chief executive officer of Ubiquity Retirement + Savings in San Francisco. Because of inertia, that requirement has often led to participants never resuming deferrals to their plan, Parks says. “That could help substantially, because you are no longer asking people to stop contributing to their [plan]. With participants continuing to contribute, I would hope that these people will still come out ahead.”

One other aspect related to the new rules is that a sponsor no longer is required to keep evidence of the hardship expense and also may rely on the participant’s representation that he or she has no other financial means to alleviate the hardship, DeMatties says. “Instead, the sponsor can keep a summary of what is in the source documents that substantiate the hardship expense,” he says.

However, the IRS might conduct a plan audit and ask for those source documents if certain requirements are not met. For that reason, Zovistoski believes it is a best practice for sponsors to still require copies of the source document.

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