Sponsors Can Expect Expanding ESG Opportunities

One firm, for example, plans to soon roll out multiple additional products to complement its two existing ESG-labeled strategies—next will come ESG approaches to global equity and global income.

Ron Cohen, Wells Fargo Asset Management’s head of defined contribution investment only (DCIO) sales, took on his current role back in 2015, moving over from J.P. Morgan’s national accounts team for defined contribution investment services.

While that was just four years ago, Cohen says the retirement industry’s conversation around the subject of environmental, social and governance (ESG) investing has evolved remarkably quickly in the time since. Cohen points to the growth in his own firm’s ESG-focused staff, including the hiring of Fredrik Axater as an executive vice president and head of strategic business segments—of which ESG is one of the most promising. Cohen also points to the influence of Nate Miles, who joined the firm in 2017 as head of DCIO, for whom ESG is a significant topic.

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“Until pretty recently, the retirement plan industry was only just starting to think about the ESG topic, whereas today it is a frequently addressed subject at conference events and in trade publications,” Cohen says. “The subject increasingly comes up in formal requests for proposals circulated by plan sponsor clients and prospects, as well.”

According to Timothy Calkins, director of fixed income at Nottingham Advisors, client expectations are indeed evolving rapidly around the question of how environmental, social and governance-focused investment approaches fit into the world of institutional asset management.

“I’ve been working on and alongside the topic of ESG for some time now,” Calkins says. “Back, say, 10 years ago, the consensus was still that you had to give up some performance by ‘doing good’ in the markets. But more recently, especially since some big meta-studies published in 2015, the conclusion around ESG integration has moved to being either neutral or more often positive from the performance perspective.”

In practical terms, Calkins’ firm is already using separately managed accounts (SMAs) as a way to deliver ESG strategies to clients. Some clients choose to really engage with risk management and return-boosting opportunities having to do with the environment, he explains, while others may choose to utilize a gender lens when reviewing the fund managers they use or the companies they invest in. As opposed to mutual funds or collective trusts, the SMAs can be customized to allow clients to uniquely implement their ESG perspective.

“Being able to offer customized ESG solutions is a big part of our future, we feel, as is finding new ways to clearly demonstrate the performance benefits of these strategies,” Calkins says. “Especially when it comes to serving clients under the Employee Retirement Income Security Act, we know the performance conversation is always going to be critical.”  

Cohen agrees that there exists strong, objective evidence there to show that ESG utilization is at a minimum neutral from a performance standpoint. In fact, he says, the majority of the evidence actually shows ESG can be a positive from the performance perspective.

At this stage, Cohen highlights, Wells Fargo Asset Management has not rolled out any funds with an ESG label meant for retirement plans. Instead the firm is taking “an education-first approach” and creating a value-add ESG investment review program that advisers and sponsors have already eagerly embraced.

“Now let me be clear, we’re on the road to have ESG-labeled product, but at this point it’s not about selling products,” Cohen notes. “What I’m really excited about is the scorecard component we have recently rolled out in partnership with Morningstar. We felt from the beginning that, at a minimum, plan sponsors would want their advisers to be able to talk with them about what the existing fund options look like from an ESG perspective.”

Sponsors can work with their advisers to use Wells Fargo’s scoring service to analyze a plan’s exiting menu to ensure the plan is using funds that perform well not only from an absolute return perspective, but also from an ESG perspective and a risk mitigation perspective.

“Sponsors can and should promote this among their participants. We have seen the data that shows employees have more favorable views of the employer organization when ESG is offered,” Cohen says. “It’s important to point out that this ESG framework is something that can be applied across the market, it’s not just about ESG-labeled funds. We can see the individual scores of funds on an ESG basis and run very informative comparisons of risk, performance and ESG scores.”

At this stage Cohen cannot offer more specific detail about Wells Fargo’s plans for ESG-labeled products in the retirement plan space, nor could he speculate whether ESG will be more conspicuously included in the firm’s asset-allocation solutions or target-date funds (TDFs).

Reflecting on what comes next with ESG investment opportunities, Calkins says ESG can only become more mainstream and more accepted by investors, even under ERISA.

“The consensus is that this is a material conversation and that ESG can positively impact returns,” he says. “With younger people and Millennials growing to be a larger part of the investing population, this topic is not going to diminish. That’s why we are moving enthusiastically into this space.”

Cohen and Calkins agree that product development will heat up in this area in the coming years. At Nottingham, for example, the firm plans to roll out additional ESG products to complement its two existing ESG-labeled strategies. Next will come ESG approaches to global equity and global income.

“We have seen a lot of activity in terms of launching mutual funds and ETFs that are ESG focused, but these funds are actually mostly limited in their scope, perhaps focusing just on the S&P 500 or small-cap funds,” Calkins explains. “This is a hurdle from the plan sponsor perspective because you don’t want to have to include 50 or 100 funds to cover the market in both an ESG and non-ESG way. So we expect ESG to evolve to really be applied in asset-allocation solutions. In our case, we have developed risk-based ESG asset-allocation strategies that hit just about every participants’ needs.”

(b)lines Ask the Experts – Employer Contribution Calculation When Moving from Union to Non-Union 403(b)

Experts from Groom Law Group and Cammack Retirement Group answer questions concerning 403(b) plans and regulations.

“I work with an employer that sponsors two 403(b) plans; a nonunion plan and a plan for collectively bargained employees. An employee met the eligibility for the employer contribution to the union plan years ago. However, she moved from union status to non-union status in 2018. The non-union plan provides for an employer contribution, and service in the union plan is credited toward eligibility for the nonunion plan so she was immediately eligible for the employer contribution in the nonunion plan. The definition of compensation in the non-union plan is all compensation earned during the year, even when the employee is not eligible. Do I include the compensation when the participant was eligible for the union plan or exclude the compensation earned during the time he was with the union plan?”

 

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Stacey Bradford, Kimberly Boberg, David Levine and David Powell, with Groom Law Group, and Michael A. Webb, vice president, Retirement Plan Services, Cammack Retirement Group, answer:

 

This is an excellent question as it demonstrates that plan language that is written for one purpose can have unintended consequences! The Experts have seen this situation too many times to count, which is why it is so important to draft plan language carefully and work closely with counsel well-versed in such issues to make certain that situations don’t arise such as the one you describe.

 

In this particular situation, the Experts suspect that the intent of the plan language was to ease administration (it is much easier to track full-year compensation than partial-year compensation for each employee). However, the unintended consequence surfaces when someone switches from union to nonunion status and the plan language does not address that particular scenario. Since there is no regulation that states that compensation for a given year cannot be eligible compensation for more than one plan sponsored by the same employer, the plan document language governs.

 

Thus, assuming that retirement plan counsel concurs that the language states that compensation earned while a union member is not specifically excluded from the nonunion plan (and it is always important to confirm such matters with counsel), the employee in question would receive an employer contribution to the nonunion plan for all compensation earned in 2018, and, depending upon the language in the union plan, would be entitled to an employer contribution to the union plan for 2018 as well, based on the portion of the same 2018 compensation that was earned while eligible for the union plan. Presumably, this “double contribution” on some of the same compensation was not the intended consequence for the plan sponsor; and the plan sponsor may wish to work with counsel going forward so that compensation earned while a union member is excluded from the nonunion plan, and vice versa.

 

One caveat to this analysis; since these are two 403(b) plans, it should be noted that a single 415 limit applies to both, so in no event can the total amount of employer contributions and elective deferrals (excluding age-50 catch-up contributions, but including deferrals pursuant to the 15-year catch-up provision) to both 403(b) plans combined exceed the lesser of $55,000 or 100% of compensation.

 

 

NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.

 

Do YOU have a question for the Experts? If so, we would love to hear from you! Simply forward your question to Rebecca.Moore@strategic-i.com with Subject: Ask the Experts, and the Experts will do their best to answer your question in a future Ask the Experts column.

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