Skip to main content

You are here


5 New Year’s Resolutions for 401(k) Plan Fiduciaries

Fiduciary Rules and Practices

This is the time of year when resolutions for the cessation of bad behaviors and the beginning of better ones are in vogue. Here are three for plan fiduciaries for 2023.

Develop a plan budget.

Most financially-focused New Year’s Resolutions focus on spending (less) or saving (more)—and the really thoughtful ones do both—all tied around the development of a budget that aligns what we have to spend with what we actually spend. 

Most (many?) plans have a budget when it comes to the expenditures that require corporate funding.  Less clear is how many establish some kind of budget when it comes to what participants have to spend.  Now, granted, what they pay will vary based on any number of …variables—but an essential part of ensuring that the fees paid by the plan (for the services provided to the plan) is knowing how much—and for what. 

At some level that means not only keeping an eye on things like expense ratios, the options with revenue-sharing, and the availability of alternative share classes (or options like CITs)—but it also means having an awareness not only of the plan features, but the usage rates of those plan features.

Because when it comes to retirement plans, there often IS a direct link between spending less and saving more.

Put your fund menu on a diet.

Though it is a point often made with studies (well, one frequently cited study, actually) dealing with jellies and ice cream, a long-standing behavioral finance tenet is that more choice doesn’t lead to better decisions. So, what’s with those (still) burgeoning 401(k) investment menus? The 65th annual Plan Sponsor Council of America’s Survey of Profit-Sharing and 401(k) Plans found that more than a quarter of plan sponsors offer 26 OR MORE options, while another 18% offered 21-25, and 27% offered 16-20.

Odds are that there are funds on the current menu that either aren’t being used or aren’t being used widely—options that contribute little other than clutter to your investment review and to the decisions of your participants.

Take a look—your retirement plan menu shouldn’t be a kitchen sink “solution.”

Check-up—on your target-date fund(s).

Flows to target-date funds (TDF) have continued to be strong—and little wonder, what with their positioning as the qualified default investment alternative (QDIA) of choice for most 401(k)s. That said, the vast majority of those assets are still under the purview of an incredibly small number of firms—with glidepaths that are not as dissimilar as their marketing materials might suggest. 

A TDF is, of course, a plan investment, and like any plan investment, if it fails to pass muster, a plan fiduciary would certainly want to remedy that situation, including removing the fund if necessary (don’t take my word for it—that’s coming straight from the Labor Department).  

That said, TDFs are frequently, if not always, pitched (and likely bought) as a package. While each fund in the family is reviewed separately, and certainly should be, breaking up the set certainly carries with it a series of complicated consequences, not the least of which are participant communication issues and glide path compatibility. Not that those can’t be overcome—and not that those complications would be deemed sufficient to retain an inappropriate investment on the plan menu—but it doesn’t take much imagination to think about the heartburn that might cause.

The reasons cited behind TDF selection run a predictable gamut; price/fees, performance (past, of course, despite those disclaimers), platform (as in, it happens either to be their recordkeepers, or compatible with their program)—and doubtless some are actually doing so based on an objective evaluation of the TDF’s suitability for their plan and employee demographics. 

Whatever your rationale, it’s likely that things have changed—with the TDF’s designs, the markets, your plan, your workforce, or all of the above. 

Pump up the default rate in your auto-enrollment plan.

While a growing number of employers are auto-enrolling workers in their 401(k) plan, one is inclined to assume that, a decade and a half after the passage of the Pension Protection Act, if a plan hasn’t done so by now, they likely have some very specific reasons.

But for those who have already embraced automatic enrollment, those are plans who have (apparently) overcome the range of objections; concerns about paternalism, administrative issues, cost—some may even have heard that fixing problems with automatic enrollment can be—well, problematic (though things have gotten a little easier on that front).

There has been movement here over the years—indeed the most recent PSCA survey found that two-thirds (65%) of plans with automatic enrollment set the default deferral rate high enough so that participants receive the full possible company matching contribution, up from 57.1% as recently as 2020. In fact, the most common default rate for automatic enrollment plans is now more than 6%. 

Set goals for your plan designs.

The mantra about retirement benefits has always been that they exist to help attract and retain good workers. More recently, a reimagined emphasis on financial wellness has offered some nuance to that—to provide better levels of engagement while they are working, to forestall the “distractions” (and potential malfeasance) that financial stress can engender, and ultimately to help workers retire “on time.” These goals are not inherently incompatible, but at any given point in time they require differences in communication, education, emphasis, and potentially program design.  

There is, by the way, a sense of a shift in such things. While the primary goal of participant education has historically been to increase participation rates, the Plan Sponsor Council of America’s 65th Annual Survey of Profit-Sharing and 401(k) plans notes that in 2020 that shifted to increasing financial literacy of employees in 2020—a shift that held in the most recent survey with 77.4% of organizations now stating that as their primary educational goal. The secondary goal was increasing appreciation for the plan (likely as a retention method) followed by providing retirement planning to employees. The percent of organizations offering financial wellness programs increased to 27%, including more than half of large employers.

If you haven’t revisited those objectives in a while—or, heaven forbid, have never done so—there’s no time like the present for a reset. After all, as Yogi Berra once commented, “If you don’t know where you’re going, you might wind up someplace else.” 


All comments
Clark Armor
8 months 3 weeks ago
Great article, but add "Find out what each of your plan providers" is getting paid, not just by you, the plan sponsor, and the participants, but also from the fund companies and other parties. Include the advisory fee (or commissions), the TPA (including revenue sharing) and the Recordkeeper (and attorney if using outside ERISA counsel).