New Fee Disclosures for US DC Plan Participants: Context Is Key
The US Department of Labor’s new 404(a)(5) fee-disclosure rules for defined contribution (DC) plans will provide participants with a lot more information on plan and investment fees—in plain language. That’s a good thing. But there’s a real risk that the new rule may unintentionally drive participants to make poor investment choices.
The rules apply to participant-directed plans for plan years starting on or after November 1, 2011. Participants must be given a chart every year that shows information about each available investment option, including its expense ratio and performance.
Expenses are certainly important when evaluating investment options, but they shouldn’t be the only consideration. What really matters is how effective an investment will be in contributing to long-term retirement savings.
Here’s a hypothetical example provided by my colleague Dan Notto, our firm’s Senior Retirement Plan Counsel, which highlights the potential problem in focusing only on fees. The new disclosure will display expenses stated as an annual percentage and as a dollar amount for a one-year period based on a $1,000 investment. Let’s say a participant finds that the target-date fund he’s invested in costs $8.00 yearly per $1,000, while employer stock costs only 20 cents yearly per $1,000.
The participant might decide to reduce his investment costs by shifting 20% of his plan assets from the target-date fund to employer stock. But such a heavy concentration in a single stock would drive up the risk of his plan investments. There’s a good reason why target-date funds, not employer stocks, are qualified default investment alternatives.
This isn’t a far-fetched example. In a survey of over 1,000 US DC plan sponsors that we’ll be releasing soon, only 27% of respondents said that their participants are very comfortable or comfortable with investing. The vast majority of participants are what we refer to as “Accidental” investors, who are uncomfortable making investment decisions.
These participants need the right guidance on how to consider the new fee information. Fortunately, our survey also found that plan sponsors are ready to provide it: 85% said that helping employees make effective investment decisions is very important or important. That help will probably be provided through sponsors’ call centers, because behavioral testing has shown that participants are more likely to pick up the phone and ask a question than to read through fee disclosures.
Notes, flyers, educational materials and call-center scripts are ways plan sponsors can encourage participants to consider all the relevant factors—not just cost—when making investment decisions. If participants have access to a financial advisor, this can be an added resource, offering more investment education or advice than plan sponsors are willing to offer.
Under related 408(b)(2) rules, which I discussed in an earlier post, plan sponsors will be responsible for ensuring that investment fees are reasonable. When fees turn up in quarterly statements, participants will be better informed as to the impact of those fees. Plan sponsors can be a big help in guiding participants to consider fees in the proper context when making investment choices.
“Target date” in a fund’s name refers to the approximate year when a participant expects to retire and begin withdrawing from his or her account. Target-date funds gradually adjust their asset allocation, lowering risk as participants near retirement. Investments in target-date funds are not guaranteed against loss of principal at any time, and account values can be more or less than the original amount invested—including at the time of the fund’s target date. Also, investing in target-date funds does not guarantee sufficient income in retirement.
The views expressed herein do not constitute research, investment advice or trade recommendations and do not necessarily represent the views of all AllianceBernstein portfolio-management teams.
Seth J. Masters is Chief Investment Officer of Defined Contribution Investments and Asset Allocation at AllianceBernstein and Chief Investment Officer of Bernstein Global Wealth Management, a unit of AllianceBernstein. Dan Notto is Senior Retirement Plan Counsel, also at AllianceBernstein.