DOL Issues Guidance on Lifetime Income Disclosure for Defined Contribution Plans

If you have a really good memory you might recall that way back at the end of last year Congress actually passed a significant retirement bill called the Setting Every Community Up for Retirement Enhancement Act (the “SECURE Act”). We prepared a brief article about the impact the SECURE Act would have on defined contribution accounts that you can find here.

COVID-19 and the employee benefit issues it has created seems to have overshadowed the SECURE Act, but the folks at DOL apparently remembered that they had been given a task. Section 203 of the SECURE Act amended ERISA to require that individual account balance plans add lifetime income disclosure to at least one participant account statement a year and the DOL was given until December 20, 2020, to provide plan sponsors with guidance on how these disclosures should be provided. The DOL has now released this guidance in the form of an interim final rule (IFR) along with a helpful fact sheet.

DOL Issues Guidance on Lifetime Income Disclosure for Defined Contribution Plans

Let’s Assume

The lifetime income disclosure illustrations are meant to provide participants with some idea of what their account balance would provide as a stream of income at retirement. The IFR provides plan sponsors with a set of assumptions and rules that must be used to prepare illustrations and comply with the disclosure requirements. These include:

  • The calculation will use a point-in-time current value of the participant’s account balance and does not assume future earnings.
  • It is assumed the participant would commence the lifetime income stream on the last day of the benefit statement period after the participant has attained age 67 (Normal Social Security Retirement Age for most individuals). If the participant is already over age 67 his/her actual age should be used.
  • The lifetime income illustrations must be provided in the form of a single life annuity based on the participant’s age and as a 100% qualified joint and survivor annuity presuming that the joint annuitant that is the same age as the participant.
  • Monthly payment illustration calculations will project forward using the current 10-year constant maturity Treasury rate (10-year CMT) as of the first business day of the last month of the statement period.
  • Assumed mortality for purposes of the calculation must be based on the gender neutral mortality table in section 417(e)(3)(B) of the Code – the mortality table used to determine lump sum cash-outs for defined benefit plans.
  • Plans that offer in-plan distribution annuities have the option to use the terms of the plan’s insurance contracts in lieu of the IFR assumptions. For clarification purposes, it is important to note that nothing in the lifetime income disclosure rules require that plans offer annuities or lifetime income options.
  • Plans must use model language provided in the IFR to explain the life-time income illustrations to participants.

Sweet Relief

The concept of lifetime income disclosure has been under consideration by Congress and federal regulators for many years and one concern has always been what would happen if the actual results a participant experiences is not as good as these projections. The IFR addresses this concern by providing that if plan sponsors and other fiduciaries follow the IFR’s assumption and use the model language to comply with the lifetime income disclosure rules those fiduciaries will not be liable if monthly payments fall short of the projections.

Something to Keep in Mind

Plan sponsors and participants should keep in mind that the product obtained as a function of complying with these lifetime income disclosure rules is going to yield something quite different than the results that would be achieved through an interactive projection of a participant’s account.  Many retirement plan vendors and financial planners will utilize projection tools that take into account future contributions and earnings as well as attempting to anticipate potential market fluctuations and interest rate changes rather than simply basing a projection on a static period of time. While a participant may find the figures that would be generated by this lifetime income disclosure useful as a year over year comparative tool the participant should also explore other planning tools for a more complete and robust retirement projection.

Timing & Effective Date

This IFR was publicly released on August 18, 2020, and it is expected to be published in the Federal Register very soon. Interested parties have been given 60 days to comment on what the DOL has set forth. The idea is that the DOL will take the comments it receives and make any adjustments it feels are merited to the guidance and then issue final regulations that will supersede the IFR. The guidance in the IFR will be effective one year after publication in the Federal Register. If you have any questions regarding these topics and updates, please contact John Lucas in the form below.

Published September 3, 2020

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Finally! An Answer to Local Taxation of Non-Qualified SERP Benefits in Ohio

Qualified retirement plan benefits paid by pension or 401k plans have always been exempt from local taxes in Ohio.  Non-qualified retirement plans (often referred to as “Supplemental Executive Retirement Plans” or “SERPs”) are often designed to enhance retirement benefits for executives over and above the benefits provided through the qualified plans offered by the employer.  Over the last several years there has been disagreement between cities in Ohio and SERP eligible executives over whether benefits paid by SERPs are retirement plan benefits, exempt from local taxes, or deferred compensation benefits, subject to local taxes when such benefits become vested using FICA and Medicare (“FICA”) taxation rules.

SERP participants have alleged that SERPs are retirement benefits which should be exempt from local taxes just like qualified retirement plan benefits. Cities have argued that non-qualified SERPs are taxable compensation to the executive. The disagreement rose into the public eye in 2015 in the case of MacDonald vs. Shaker Heights when the Ohio Supreme Court ruled in favor of MacDonald. The local tax ordinance in that case did not exclude SERPs and further, did not specifically define “pension benefits” which were exempt from local taxation. After this ruling, many cities amended their tax ordinance to define pensions as benefits paid only by a qualified retirement plan. Many taxpayers have argued these Ohio cities should not be able to tax retirement benefits….whether paid by a qualified or non-qualified plan. But there has been little or no guidance from Ohio on the issue…..until recently.

local taxation and non-qualified SERP benefits

What’s New in 2020?

Ohio House Bill 166 amended ORC 718 and clarifies the definitions of “pension” and “retirement benefit plan”. This prevents cities from defining such terms in their tax ordinances to require taxation of non-qualified pensions and retirement benefits.  All pensions and benefits paid out of a retirement benefit plan are exempt from local taxes if the benefits meet the following criteria:

  • The benefits are provided by the Employer and not through a deferral of wages by the employee;
  • The benefit payments must be due after or at termination of employment; and
  • The plan is designed to deliver the benefits because of retirement or disability

HB166 does not define “retirement”; therefore, it will be up to plan documents to define what constitutes a retirement. Retirement definitions vary from plan to plan, but it is typically defined by age and/or years of service. Wage continuation, severance payments, and payments of accrued vacation are specifically not included in retirement plan benefits.

Thus, whether paid by a qualified or non-qualified plan, if these criteria are met, the benefits are retirement plan benefits exempt from local taxes in Ohio. Eligibility for the exemption in SERPs is going to be a facts and circumstances analysis comparing the plan design to the criteria above and intent of the plan. The new rules were made effective January 1, 2020. SERP benefits taxed by municipalities prior to 2020 are not refundable. However, eligible SERP benefits which become vested on or after January 1, 2020, even if they have accrued over a long career, are exempt from local taxes.

Taxation Timing

SERPs are subject to FICA taxes under special rules….the present value of the benefit is generally taxed when the benefit becomes vested, even if this is prior to payment.  There is an exception for non-account balance plans which benefits cannot be determined until retirement.  Ohio local taxes follow the FICA rules for tax timing. HB166 did not change these tax timing rules. However, if the benefits qualify as “pension” and “retirement benefit plans” under HB 166, the benefits are exempt from local tax if vested on or after January 1, 2020. Starting in 2020, collection and remittance of city income taxes for an eligible SERP is no longer necessary, assuming it meets the facts and circumstances analysis.

Ineligible Benefits

Examples of executive benefits that would be ineligible for the local income tax exclusion:

  • Benefits provided through elective deferrals on the part of the employee
  • Any payment of benefits prior to termination of service, retirement or disability
  • Benefits delivered through long term incentive plans, such as phantom stock plans, which do not promise benefits because of retirement or disability
  • Benefits under a plan which provides a participant with an election to be paid prior to retirement or disability, even if the participant did not make the election
  • Severance payments, payments made for accrued personal or vacation time, and wage continuation payments.

Outcomes

As a result of HB 166, the taxation of SERPs by Ohio municipalities has been resolved. Properly designed SERP benefits will be exempt from income tax by Ohio municipalities, just like qualified retirement plan benefits.

Many employers currently have a SERP; those plans should be evaluated to determine if it meets the exemption criteria. Employers should stop reporting and withholding local wages and taxes starting in 2020 if they deem the plan(s) to be a “retirement benefit plan”.

Some school districts within Ohio have their own income tax.  There are no changes to the taxation of school district income tax as a result of HB166. School District Income taxes follow Ohio taxing guidelines rather than FICA, so participants would be taxed when benefits are paid.

For questions regarding the impact of this legislation on your organization’s Non-Qualified SERP Benefits or how to navigate these changes, please contact the Findley consultant you normally work with, or Brad Smith below.

Published May 28, 2020

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Three Compelling Reasons to Consider Pension Plan Mergers

If you have more than one pension plan you are administering, consider a pension plan merger to potentially reduce plan administrative, Pension Benefit Guarantee Corporation (PBGC), and future plan termination fees. Sound too good to be true? Read on.

While the total number of pension plans may have dwindled over the past few decades, several companies still sponsor not only one, but multiple pension plans for participants within their organization. Most typically this is the result of a decision made years ago when the retirement plans were created or acquired – either to intentionally separate participants with different benefit formulas such as Hourly Plans for union employees earning a service related benefit, Salaried Plans for employees earning a pay related benefit, or as a result of an acquisition where the plans benefitting employees are not original employees of the parent company.

While there may have been reason to keep the plans separate in the past, it might be time to reevaluate and consider whether a pension plan merger might be beneficial.

“It might be time to reevaluate and consider whether a pension plan merger might be beneficial.”

What is a Pension Plan Merger?

A pension plan merger is the consolidation of one or more pension plans into a single, previously existing pension plan. 

Consider Company X who maintains 3 pension plans: 

  • Plan A benefits all Hourly, union employees
  • Plan B benefits all Salaried employees
  • Plan C benefits all participants acquired by Company Y

A pension plan merger is the transfer of all retirement plan assets and liabilities from Plans A and/or Plan B into Plan C (or some other similar combination) and as a result, Plan A and/or Plan B would cease to exist.

Pension Plan Merger Example

Going forward, annual requirements remain only for the consolidated plan. Because the merger cannot violate anti-cutback rules, there is no negative impact to the retirement plan participants. Protected benefits such as accrued and early retirement benefits, subsidies, and optional forms of benefits cannot be reduced.

Why Should We Consider Merging Pension Plans?

Reason #1 : Reduced Administrative Fees

Each qualified pension plan has several annual requirements, regardless of size. Combining plans can reduce total administrative fees by minimizing the redundancy of the annual actuarial, audit, and trustee work:

  • Annual valuations: Funding, accounting, and ASC 960
  • Government reporting: IRS Form 5500 and PBGC filings
  • Participant notices: Annual funding notices
  • Annual audit: Plan audit for ASC 960 and financial accounting audit
  • Trustee reports

Merging plans can streamline many processes, reducing fees for these services compared to operating separately.

Reason #2 : Potential PBGC Savings

Plan sponsors with both an underfunded and overfunded plan can reduce PBGC premiums by sharing the excess retirement plan assets of an overfunded plan with one that is underfunded. Annual premiums are due to the PBGC (Pension Benefit Guarantee Corporation) for protection of participant benefits in the event the plan sponsor is unable to fulfill their pension promises. Plans that are fully funded pay only a flat rate premium based on headcount. Underfunded plans pay an additional variable rate premium (VRP) based on the total unfunded liability for the plan (capped by participant). Merging an underfunded and overfunded plan can create a combined fully funded plan, eliminating the variable portion of the cost or premium due to the PBGC as shown:

Consider Company X who maintains 2 pension plans: 

  • Plan A has 580 Hourly participants with a PBGC shortfall of $10 million as of 1/1/2019
  • Plan B has 1,160 Hourly participants with a PBGC excess of $10 million as of 1/1/2019
  • Plan A merges into Plan B with 1,740 participants and no shortfall as of 1/1/2019
Impact of Pension Plan Merger on PBGC Premiums

By merging Plan A into Plan B, the shortfall is eliminated and PBGC premiums due are dramatically reduced with considerable financial impact.

Reason #3 : Plan Termination on the Horizon

Similar to the administrative savings of merging two ongoing pension plans, there will likely be reduced fees related to the process at termination. The final step in distributing retirement plan assets will be the agreement between the insurance company taking over the responsibility for all future benefit payments of remaining participants. Merging plans will consolidate the transaction and increase the number of participants affected, potentially resulting in annuity purchase cost savings to offset the underfunded liability  at final distribution. If plan termination is on the horizon, especially for two small to mid-size pension plans, a plan merger may prove to be a valuable first step with potential positive financial impact.

We Want to Merge our Pension Plans…Now What?

In most scenarios, the process is fairly straightforward. There will be a few adjustments required to the valuation process in the first year, but going forward will operate as usual. Participants will be notified of the change, but there will be no difference to the way that their benefits are calculated or administered.  

The plan sponsor will also be required to do the following:

  • Execute a plan amendment describing the plan merger
  • Modify the plan document to reflect the new consolidated plan
  • File Form 5310-A with the IRS no later than 30 days prior to the merger

Regardless of the size of the plan, a plan merger may be a step in the right direction toward simplifying the administration and cutting costs for many organizations sponsoring more than one pension plan.  Merging multiple pension plans is most often one example in the pension world where less is more. Finally, there are instances where a merger may result in increased costs (PBGC premiums) or may present other challenges.

Each situation is unique so don’t make any assumptions without consulting your actuary. And don’t overlook the importance of a communications strategy to inform participants of any changes which take place.

Questions? For more information, contact the Findley consultant you normally work with, or contact Debbie Sichko at debbie.sichko@findley.com, 216.875.1930.

Published on August 15, 2019

© 2019 Findley. All Rights Reserved.

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Could You Be Supporting a Hidden Retiree Health Plan?

A retiree health plan is when ex-employees are provided for or allowed to purchase health care through their former employer. 

Sponsoring a hidden retiree health plan happens more often than you might think. Having even an informal policy of extending active health benefits to retirees and charging the “full” active premium or supplementing retiree health benefit coverage for some time are two examples of creating a retiree health benefit plan and incurring the accompanying plan liability for health benefits promised in the future.

Could You Be Supporting a Hidden Retiree Health Plan?

Examples

1) ABC Company has a fully insured medical plan for its active employees. ABC pays 60% of the premium. The employees pay the rest. The employee handbook has a paragraph that reads, “If you retire from active service after age 60 with 15 years of service, you may remain in the health insurance plan until age 65. You will pay the employer and employee portion of the premium.”

2) Ten years ago, XYZ Company had an executive retire at age 60. He had been with the company for 17 years. He was allowed to stay on the active medical plan until age 65. He had to pay the employer and employee portion of the premium. All staff received an email at the time stating that this was now available to all employees who retire after age 60 with 15 years of service. The language in the email never made it in the employee handbook, but it was a well-known policy.

3) MNO Corporation has a collective bargaining agreement with its union that provides $150 per month for medical coverage for anyone who retires before age 65. Coverage ends at age 65, and the participants must purchase the coverage from MNO.

ABC, XYZ, and MNO have retiree medical plans and might need to recognize a liability on their balance sheets and annual expense on their income statements for the promised benefits.

Why is There a Liability?

The question often asked in regards to ABC and XYZ is, “The retiree pays the full cost of the premium. It costs the company nothing. Why is there a liability?”

There are two parts to the answer. The first part is in the way the premium is calculated for the active health plan. The insurance company calculates the premium rates for the entire population, including retirees. Since these retirees are older, their premium amounts are higher than for younger employees in the plan. Without the retirees in the plan, the total premium would be lower, and thus, the employer portion would be lower.

Looked at another way, if you could calculate a hypothetical premium rate for just the retiree group, it would be much higher due to their ages. The difference between the hypothetical premium level and the “full” active premium charged for medical coverage is called a “hidden subsidy.”

The second part is from the accounting standard ASC 715-60-05-2 which states, “a postretirement benefit plan is an arrangement that is mutually understood by an employer and its employees whereby an employer undertakes to provide its current and former employees with benefits after they retire in exchange for the employees’ services over a specific period of time.”

This second part of the above answer also applies to the MNO Corporation example. Their annual cost for the retirees may seem minimal and recorded as an annual payroll and benefits cost along with the active medical plan. However, for all three companies, the retirees are not receiving benefits as a part of their compensation while working. The retiree benefits accrue while working but are paid after retirement.

This promise of future benefits can trigger a liability to recognize on the balance sheet and an annual expense that runs through the income statement.

How Does an Employer Know if They Need to Recognize a Liability?

The employer should discuss it with their auditors. Depending on the circumstances, an auditor could consider it de minimus or may request that an actuary measure the liability before providing an opinion about the impact on the company financials.

Options

If the auditor does not consider it de minimus, in arrangements like ABC’s or XYZ’s, a company could charge the retiree more than the active premium –something more like the above hypothetical premium. (An actuary or healthcare consultant can help you set a hypothetical rate.) The hypothetical rate would remove the “hidden subsidy” and reduce the costs to a de minimus level. Additionally, the increased cost of coverage may cause retirees to look elsewhere for more affordable coverage.

Alternatively, if the employer wants to keep an arrangement that is not de minimus, then it will need to engage an actuary to perform annual valuations for financial reporting purposes.

If you have questions or would like to discuss any formal or informal arrangements you have in place for your retirees, contact David Davala at 216.875.1923 or David.Davala@findley.com.

Published July 12, 2019

© 2019 Findley. All Rights Reserved.

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Retirement Savings Opportunities for High Earning Owners and Professionals

Overview: For successful small businesses, a 401(k) plan combined with a cash balance plan can provide opportunities to:

  • Build wealth and retirement savings for the owners/ professionals with much greater contributions than through a 401(k) plan alone
  • Save on federal, state, and local taxes through higher deductible contributions
  • Protect substantial assets from creditors or legal action
  • Provide attractive retirement benefits for nonowner
  • Attract and retain talented employees
  • Enhance financial well-being and retirement readiness for all participants

The Tax Cuts and Jobs Act substantially reduced corporate tax rates for C corporations, and added a complex set of rules on deductions for pass-through entities such as partnerships, LLCs, and S corporations. Fundamentally, tax reform enacted a slightly lower individual tax rate (top brackets reduced from 39.6 percent to 37 percent) for high-earning owners, which means that these plans are still tax effective, while the substantial long-term benefits remain unchanged. Business owners who are currently sponsoring or planning to set up a 401(k) plan and cash balance plan should talk with their tax advisor and actuary, to see if any changes to plan design or their business structure are desirable.

Impact of the Tax Cuts and Jobs Act

A lot has been written and said about the Tax Cuts and Jobs Act and the tax rule changes that affect businesses. In this article, we focus on the very fundamental aspects of these changes.

C corporations now have a flat 21 percent income tax rate and pass-through entities now have a 20 percent deduction on qualified business income. This 20 percent deduction is limited or phased-out based on the type of business and business income through very complex rules. For taxpayers in the top individual income tax bracket of 37 percent, this 20 percent deduction can be viewed as a 7.4 percent (20 percent of 37 percent top individual income tax rate) rate reduction.

Thus for most high-earning owners and professionals, the evaluation of the tax effectiveness of their 401(k) and cash balance plan will involve only a change in tax rate from 39.6 percent to 37 percent. We’ve seen that this may cause subtle changes in design and contribution levels, but it does not change fundamental decisions on whether to adopt one or both plan types.

To illustrate how the combination of a 401(k) and cash balance plan can be used, let’s look at a case study of a professional firm we’ll call ABC Services.

Case Study:  ABC Services

Cash Balance  Plan Contribution Chart

ABC Services is a partnership of any type of business professionals such as accountants, doctors, or lawyers. There are three partners in the business, each owning one-third of the practice. The firm has a number of nonowner professionals we’ll call associates. The firm employs other staff as well.

The partners at ABC have these goals for their retirement program:

  • Partners – Adam and Bill (both age 55) would like to maximize their retirement savings. Carol (age 45) needs more current income and less saving for retirement. No partner wants to subsidize the retirement benefit of the other partners.
  • Associates – the associates are ages 30 to 45. Associates prefer current compensation over future retirement benefits. ABC wants to minimize retirement plan contributions to this group.
  • Staff – ABC hires relatively young staff and experiences moderate turnover among this group. ABC wants to offer a market-competitive level of retirement benefits to attract staff employees.

Tables 1A and 1B show the employer contributions provided under the 401(k) and cash balance plans established by ABC. Each participant can make salary deferral contributions to the 401(k) plan up to the IRS limits, including additional catch-up contributions for individuals age 50 and older.

Table 1A: Annual contribution amounts for ABC partners

 

Eligible Pay

Salary
Deferrals
Employer 401(k)
Contributions
Employer
Cash Balance
Contributions
Total
Employer
Contributions
Total
Retirement
Contributions
Adam $280,000 $25,000 $14,000 $140,000 $154,000 $179,000
Bill $280,000 $25,000 $14,000 $140,000 $154,000 $179,000
Carol $280,000 $19,000 $14,000   $35,000   $49,000   $68,000

*Subject to IRS limits

Table 1B: Annual employer contributions, as a percentage of eligible pay, by employment category

  Employer 401(k)
Contribution
Employer Cash Balance
Contribution
Total Employer
Contribution
Partners      
Adam 5% 50.0% 55.0%
Bill 5% 50.0% 55.0%
Carol 5% 12.5% 17.5%
Associates 0%      0%       0%
Staff 5%   2.5%    7.5%

How well does this retirement program accomplish ABC’s objectives?

  • Partners – Adam and Bill are able to receive contributions of (and defer tax on) $179,000 each year. Carol accomplishes her goal by having a meaningful, but significantly lower, contribution amount of $68,000 per year with flexibility to change her contribution amounts through the 401(k) plan.
  • Associates – ABC minimizes retirement contributions for associates by providing a separate, employee deferral only 401(k) plan for associates, and excluding the associates from the cash balance plan.
  • Staff – ABC offers a strong benefit to this group in order to attract and retain staff employees. The plan design provides employer contributions of 7.5 percent of pay for staff, plus employee 401(k) salary deferrals and  catch-up contributions if the employee is at least age 50.

What Types of Employers Should Consider a 401(k) Cash Balance Plan?

We’ve noted that any successful business can consider implementing a 401(k) and a cash balance plan. We find, however, that businesses with the following characteristics are the most likely to see the benefits of implementing these plans together:

  • The business owners are age 40–64
  • The business has had consistent cash flow and profitability
  • The future of the business looks good, with positive cash flow and profitability over the next five years
  • The ratio of nonowner employees to owner employees is relatively low
  • The business has a 401(k) plan in place and is making employer contributions currently

Also, we frequently hear these goals in discussions with owners of successful businesses:

  • We want (or need) to save more for retirement than the current IRS annual limit imposed on the 401(k) plan
  • We want to reduce our current taxes
  • We need protection of assets from creditors, or in the event of a lawsuit
  • We want to recognize and reward key staff
  • We want to attract and retain the best employees

By implementing a 401(k) plan and cash balance plan with advanced plan designs, successful businesses can meet their owners’ goals for wealth building and retirement savings and offer an attractive and cost-effective retirement program to their employees.

Looking Closer at Cash Balance and 401(k) Plans

Qualified retirement plans are divided into two categories: defined benefit (DB) plans and defined contribution (DC) plans. Cash balance plans are a typical DB design for small businesses and professional firms, while 401(k) plans are a common DC plan design.

A cash balance plan is structured to look like a DC plan with each participant having a recordkeeping account that receives employer contributions and interest credits. These interest credits are often defined and guaranteed by the plan.

Common Features

Since both 401(k) and cash balance plans are types of qualified retirement plans, they share a number of common features that are important for employers and participants:

  • Contributions are tax-deductible
  • Trust earnings are tax-deferred
  • Trust assets are protected from the claims of creditors
  • Distributions are usually immediately available after termination, retirement, death or disability
  • Lump sum distributions may be rolled over to a successor plan or another tax-advantaged plan
  • Distributions are not subject to FICA or FUTA tax

Key Differences

Table 2 highlights the key differences between 401(k) and cash balance plans:

401(k) Plans Cash Balance Plans
Contributions (based on 2019 limits) Contributions
Participants can save up to $19,000 in before tax or Roth (after tax) employee savings

Participants age 50 or older can save an extra $6,000 in catch-up contributions

The employer and employee contributions can be up to $56,000 ($62,000 including catch-up contributions)

Employer contributions (match and profit sharing) are usually discretionary
Contributions can be far greater than current 401(k) limits, depending on the owner’s/professional’s current age

The cash balance account is guaranteed
Additions to the cash balance account are based on pay credit and interest rate factors defined in the plan document

Employer contributions are required
Investments Investments
Participants usually direct the investments in their 401(k) account

The participant chooses their investment strategy and bears the investment risk
Assets are invested in a pool for all participants in the plan, usually with a conservative investment strategy

Plans are allowed to credit the actual performance of the portfolio to participants’ cash balance accounts (certain restrictions apply)

The employer sets investment strategy and often bears all the investment risk
Accounts Benefits
The participant’s account value is based on contributions and actual investment returns (or losses) The participant’s account has guarantees; the account is based on contributions, interest credits as defined by the plan, and minimum guarantees required by law

Distribution

Distribution

In-service distributions are allowable for hardship or upon reaching age 59½

Distributions are usually as a lump sum, some plans allow for installments or purchase of an annuity

Participant loans are often available through the plan


In-service distributions are allowable at or after age 62

Distributions are usually made as a lump sum, annuity options are available through the plan

Loans are usually not offered

Other Considerations

With examples showing the benefits of implementing a 401(k) plan and cash balance plan to owners and their employees, the natural question is: why not implement these plans?

Business owners considering these plans should also discuss these issues with their actuary, tax advisor, and plan consultants:

  • Higher contributions for nonowner employees will likely be required
  • There will be higher administrative costs for a second plan, including hiring an actuary to certify the minimum funding required of the cash balance plan
  • There may be PBGC premium expense for certain plans and employers; however, PBGC coverage can result in additional deductible contributions
  • There are annual required minimum contributions for the cash balance plan
  • Volatility in the investments held by the cash balance plan can lead to volatility in the required minimum contributions
  • Funding levels must be managed to avoid certain restrictions on distributions

In Summary

The combination of a 401(k) plan and a cash balance plan is often the best solution for a successful business wishing to provide substantial tax-deferred savings for key individuals. This combination of plans is easy to understand and can provide surprising flexibility along with increased contribution limits.

The case study shown in this article shows the retirement accumulation potential of implementing a 401(k) and cash balance plan. Other cost-effective plan designs are generally available; for more information, please contact your Findley consultant.

Published on June 7, 2019

© Copyright 2019 • Findley • All rights reserved

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Building Toward a Better Retirement: Choice Architecture and Plan Participants

Overwhelming. That’s normally the first response plan participants give as to why they didn’t start saving for retirement. HR professionals and retirement consultants have heard it before, “Too many options; too many decisions; I wasn’t sure what these words even meant.” Effectively helping plan participants prepare for retirement takes designing the message in a different way.

Choice architecture is a term used to describe how decisions can be influenced by the layout, order, and variety of the choices presented. This concept can be used to help steer retirement plan participants into better decision-making. Plan sponsors can use choice architecture to their advantage by improving how participants’ choices are presented and by using smart default options.

An important first step is to consider what obstacles often prevent employees from joining a plan or increasing their savings. A white paper from Wells Fargo, Driving Plan Health says, “Knowing which plan features, communications, and digital tools are designed to address these various psychological barriers is an important first step and can help guide the selection of which features and tools to use.”[1] The plans that have solved for these types of problems, leveraging design elements, usually produce the best retirement outcomes for their employees.

Make their first choice automatic

Automatic enrollment and annual re-enrollment can be used to overcome inertia of participants by automatically putting them into the plan when they first become eligible. The participants must take action to opt out if they do not want to participate; this often results in much higher 401(k) participation rates than plans which don’t use automatic enrollment.

Retirement outcomes for participants can be further improved by implementing automatic deferral increases. This helps those participants who do not take initiative in managing their savings.

Finally, qualified default investment alternatives (QDIA) can be tailored to meet the needs and investment styles of different workforces. Offering QDIAs allows participants to accumulate far greater savings in the form of investment earnings than if they left their funds in cash or a stable return fund. In the article, Choice Architecture and Participant Investment Decisions, Vanguard notes, “Sponsors seeking to change behaviors of longer-tenured participants may wish to consider reenrollment into a low-cost default option, as that is one way to counteract the profound inertia influencing longer-tenured participants’ investment holdings.”[2]

Incentivize their saving goals

Once enrolled, there are many choices participants must make. How those choices are presented to them can make a huge difference in long-term savings. For example, the Save More Tomorrow program gives participants a nudge to save more by having them establish their own future defaults today. The defaults selected happen automatically in the future when a raise occurs, so the participant never has a decrease in take-home pay.[3]

Another common way to incentivize participants to save more is to offer employer matching or profit sharing contributions that are tied to their 401(k) deferral rates—the more they defer, the more the employer gives them.

There are always some participants who select their investments when they first enroll and never touch them again. Auto-rebalancing can be used to return the accounts to their intended asset allocation, often increasing returns and keeping risk in check.

Smart design leads to smart decisions

An article by Voya suggests using a Reflective Index to help apply choice architecture to the plan. It is possible to automate the determination of a participant’s decision-making style. The Reflection Index evaluates participants on three decision-making style indicators: attention, information gathering, and making tradeoffs. The assessment gives insight into how participants in different plans are making decisions. Voya states, “By leveraging the insights of behavioral science and the data of the digital world, we can tailor our suggested ‘course corrections’.”[4] Plan sponsors can use the index to help them make plan design decisions. For instance, plans where more participants are characterized by a reflective decision-making process should encourage their participants to re-evaluate their elections based on additional personalized information; whereas re-enrollment might be a better solution for plans if most participants are characterized by an instinctive decision-making process. “By making it easier for their participants to make the right decision, we can offer them another chance at a successful retirement.”[5]

Something we may not think of as affecting a participant’s retirement plan choices is the website design. Participants’ interactions on websites can be tracked; then small changes can be made to lead participants to better choices. Simple changes to implement might include locating relevant plan information where the participant is being prompted to make a choice, making the language of enrollment options as simple as possible, or using a “traffic light” color design to guide choices.

One size doesn’t fit all when it comes to participant communication. Tailor the plan’s communications to have language and information designed for your workforce. This will help grab the participant’s interest and improve the communication’s overall effectiveness.

Saving to and through retirement

Choice architecture can be used not only to optimize auto features but also to help eliminate the loss of funds. Retirement Clearinghouse has recently developed a program which helps participants keep track of their retirement funds as they move from job to job. For smaller account balances, which might otherwise get cashed out or rolled to an IRA by default, this program captures and tracks these assets by moving terminated participants’ account balances with them to their new employer’s plan—all by default.[6]

Another way savings can be preserved is by limiting opportunities to withdraw from the plan through loans, hardship withdrawals, in-service or termination cash outs.

Finally, choice architecture can even influence the age at which a participant might begin to draw down their savings. Using a “consider the future first” checklist of eight reasons to claim benefits later, The TIAA Institute encourages some participants to delay claiming their benefits for up to 18 months.[7]

In perspective

Whether a participant logs in once and makes a single choice or is making a lifetime of choices, there are many ways employers can use choice architecture to assist all types of decision-makers when they do engage. Understanding your employees and tailoring the approach can help them make the best decision–ultimately improving retirement readiness.

Questions? Contact the Findley consultant you normally work with or Laura Hohwald at Laura.Howald@findley.com or 615.665.5349.


[1] “2018 Driving Plan Health.” Wells Fargo, 2018. Accessed January 2019.

[2] Pagliaro, Cynthia, and Stephen Utkus. “Choice Architecture and Participant Investment Decisions.” The Vanguard Group, May 2018. Accessed January 2019. www.oecd.org/els/health-systems/Obesity-Update-2017.pdf.

[3] Thaler, Richard, and Shlomo Benartzi. “Save More Tomorrow™: Using Behavioral Economics to Increase Employee Saving.” American Journal of Education, Feb. 2004. Accessed January 2019. www.journals.uchicago.edu/doi/abs/10.1086/380085?journalCode=jp.

[4] Benartzi, Shlomo. “Using Decision Styles to Improve Financial Outcomes.” Voya. 2019. Accessed January 2019. www.voya.com/behavioralfinance.  

[5] Ibid.

[6] “Moving Retirement Forward.” Retirement Clearinghouse. January 2019. Accessed January 2019. https://rch1.com/.

[7] Johnson, Eric, Kirstin Appelt, Melissa Knoll, and Jon Westfall. “Preference Checklists: Selective and Effective Choice Architecture for Retirement Decisions.” TIAA Institute. June 2016. Accessed January 2019. https://www.tiaainstitute.org/sites/default/files/presentations/2017-02/ti_selective_effective_choice_architecture_for_retirement_decisions.pdf.

Posted on March 13, 2019

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IRS Releases 2018 Required Amendments List for Qualified Retirement Plans

The Internal Revenue Service (IRS) recently issued Notice 2018-91, which contains the Required Amendments List for 2018 (2018 RA List). The 2018 RA List does not reflect any changes in qualification requirements. This means that for individually designed plans there are no required amendments due to changes in qualification requirements under the current list.

As a reminder, in Revenue Procedure 2016-37, the IRS stated that it intends to publish annually a Required Amendments List (RA List). The RA List establishes the date that the remedial amendment period expires for changes in qualification requirements contained on the list. For an individually designed plan, the remedial amendment period for a disqualifying provision resulting from a change in qualification requirements listed in the  RA List generally extends to the last day of the second calendar year beginning after its issuance.

The RA List includes statutory and administrative changes to qualification requirements first effective during the plan year in which the list is published. The RA List does not include:

  • statutory changes for which the IRS expects to issue guidance (which would be included in a future RA List);
  • changes to qualification requirements that allow (but not require) optional plan provisions; or
  • changes in tax laws that affect qualified plans but do not change qualification requirements (for example, changes to the tax treatment of plan distributions).

Certain annual, monthly, or other periodic changes to amounts and items are considered to be included on the RA List for the year in which the changes are effective, even if not directly referenced on the RA List. Examples of these periodic changes include the various dollar limits that are adjusted for cost of living increases, such as those provided in Code Sec. 415(d); Code Sec. 417(e)(3) spot segment rates used to determine the applicable interest rate; and the Code Sec. 417(e)(3) applicable mortality table. However, the IRS expects that few plans have provisions that need to be amended for these changes.

Questions? Contact the Findley consultant whom you normally work with or Sheila Ninneman at sheila.ninneman@findley.com, 216.875.1927.

IRS Issues Proposed Regulations on Hardship Distributions

Just in time for 2019, the IRS has complied with a directive it was given by Congress in the Bipartisan Budget Act of 2018 (BBA 2018) and provided needed guidance on changes to 401(k) hardship withdrawal rules. These changes increase a participant’s access to hardship withdrawals and eliminate some burdensome administrative requirements. The guidance was issued in the form of proposed regulations. However, given the need 401(k) plan sponsors have to address these issues, it is reasonable to assume that the final regulations will not change much. Below is a summary of the guidance.

Deemed Immediate and Heavy Financial Need Safe Harbor

In determining whether a participant has incurred a hardship that would permit a withdrawal from a 401(k) plan, most plans follow the IRS safe harbor rules for determining what constitutes a deemed immediate and financial need. The newly proposed regulations modify this safe harbor list of expenses by:

  • adding “primary beneficiary under the plan” as an individual for whom qualifying medical, educational, and funeral expenses may be incurred. This updates the regulations to include a change made by the Pension Protection Act of 2006 that the IRS did not address in previous guidance.
  • modifying the expense listed in existing regulations that relates to damage to a principal residence that would qualify for a casualty deduction under Code Section 165 to eliminate, for this purpose, the new limitations to casualty loss deduction rules added by the Tax Cuts and Jobs Act, which required that the loss be attributable to a federally declared disaster.
  • adding a new type of expense to the list relating to expenses and losses incurred as a result of certain disasters if the participant’s principal residence or principal place of employment is in a federally declared disaster area.

Special applicability rule. Under a special applicability provision, the revised list of safe harbor expenses may be applied to distributions made on or after a date that is as early as January 1, 2018.

Distribution Necessary to Satisfy Financial Need Safe Harbor

Most 401(k) plans follow the IRS safe harbor rules for determining whether a distribution is necessary to satisfy the participant’s financial need rather than relying on the more complicated facts and circumstances test. Before 2019, IRS guidance provided that plans using this safe harbor had to:

  • require a participant first take out any plan loan that was available, and
  • suspend 401(k) contributions for a period of 6 months after a participant’s hardship withdrawal.

BBA 2018 specifically instructs the IRS to eliminate these two requirements from the safe harbor standard. The IRS responded to this directive by replacing the safe harbor and the facts and circumstances tests with one general standard for determining whether a distribution is necessary to satisfy a participant’s financial need. Under this new general standard:

  • a hardship distribution may not exceed the amount of an employee’s need (including any amounts necessary to pay any federal, state, or local income taxes or penalties reasonably anticipated to result from the distribution);
  • the employee must have obtained other available distributions under the employer’s plans; and
  • the employee must show that he/she has insufficient cash or other liquid assets to satisfy the financial need. A plan administrator may rely on such representation unless the plan administrator has actual knowledge to the contrary. The requirement to obtain this representation only applies to a distribution made on or after January 1, 2020.

Further information on suspensions – Although BBA 2018 makes the elimination of the 6-month hardship suspension effective January 1, 2019, the IRS clearly recognizes the administrative burden that some plans will face to implement system changes. Therefore, the IRS provides plan sponsors some flexibility in implementing the elimination of hardship suspensions as follows:

  • Plans may be amended to eliminate hardship suspensions on or after January 1, 2019.
  • The plan amendment may provide that all suspensions be immediately lifted (including for participants whose hardship suspension began in the second half of 2018). Alternatively, a plan may require that participants under a 6-month suspension have to complete that suspension period.
  • All plans must eliminate the 6-month suspension by January 1, 2020.

Expanded Sources for Hardship Distributions

The proposed regulations expand the sources of contributions that a plan may make available for a hardship withdrawal. After 2019, the amounts available may include QNECs, QMACs, safe harbor contributions, and earnings on all amounts available (including earnings on elective deferrals), regardless of when contributed or earned. This expansion of sources of funds available for hardship withdrawal is not a requirement. Plan sponsors may want to continue to limit the type of contributions available and whether earnings on those contributions are included.

403(b) Plans

The IRS generally extends these new hardship rules to 403(b) plans while noting that BBA 2018 did not actually amend Section 403(b)(11). Since Congress did not change the 403(b) plan rules, the IRS takes the position it has no authority to make certain changes to 403(b) plan rules. This results in a couple of operational differences between 401(k) and 403(b) plans with respect to these hardship changes:

  • Income attributable to 403(b) plans continues to be ineligible for hardship withdrawals; and
  • QNECs and QMACs that are held in a custodial account are not eligible for hardship withdrawal.

Applicability Dates

The proposed regulations generally apply to distributions made in plan years beginning after December 31, 2018. Certain special applicability rules are discussed above for (1) the safe harbor list of expenses and (2) suspensions.

The elimination of suspensions is the only required change made by these regulations and it must be done by January 1, 2020. The other rules that expand access to hardship withdrawals are optional provisions the plan sponsor can choose to change or leave as they are.

Plan Amendments

The IRS expects that if the proposed regulations are finalized as they have been proposed, plan sponsors will need to amend their plans’ hardship distribution provisions. Revenue Procedure 2016-37 specifies the deadline for amending a disqualifying provision. For example, for an individually designed plan that is not a governmental plan, the deadline for amending the plan to reflect a change in qualification requirements is the end of the second calendar year that begins after the issuance of the Required Amendments List that includes the change. A plan provision that is not a disqualifying provision, but is integrally related to a plan provision that is a disqualifying provision, may be amended by the same deadline applicable to a disqualifying provision. The annual Required Amendments List is generally issued each December.

A plan amendment that is related to the final regulations, but does not contain a disqualifying provision, including a plan amendment reflecting (1) the change to Code Section 165 (relating to casualty losses) or (2) the addition of the new safe harbor expense (relating to expenses incurred as a result of certain federally declared disasters), will be treated as integrally related to a disqualifying provision. Therefore, all amendments that relate to the final regulations will have the same amendment deadline.

Proposed Regulations, Subject to Change

This IRS guidance is in the form of proposed regulations that are subject to change. The IRS has requested public comments on the proposed regulations and will schedule a public hearing, if requested in writing by any person that timely submits written comments.

Questions? Contact the Findley consultant you normally work with or John Lucas at john.lucas@findley.com, 615.665.5329.

Posted November 30, 2018

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Reminders of What’s New for Plan Sponsors in 2019

Retirement and health and welfare plan sponsors have a relatively short list of employee benefit changes that begin on or around January 1, 2019. However, some changes were announced so long ago that they could be easily forgotten; here’s a refresher.

For Sponsors of Disability Welfare Plans and Retirement Plans that Provide Disability Benefits

Background

New claims procedures regulations for disability benefits claims, after multiple delays, have finally been set. The Department of Labor (DOL) requires that the new procedures apply to disability claims that arise after April 1, 2018. The rules generally give disability benefit claimants the same level of procedural protections that group health benefit claimants have after the enactment of the Affordable Care Act (ACA). Its aim is to protect disability claimants from conflicts of interest; ensure claimants have an opportunity to respond to evidence and reasoning behind adverse determinations; and increase transparency in claims processing.

What Do Plan Sponsors Need to Do

For most plan sponsors, ERISA claims procedures are described in their summary plan descriptions. That means that the new disability benefit claims procedures require a summary of material modifications. Certain other plan sponsors will want to consider amending their plans to provide that the disability determination under their plan is made by a third party, such as the Social Security Administration or their long-term disability benefits insurer. Plan sponsors are advised to adopt any necessary amendments on or before the last day of the plan year that includes April 2, 2018. For calendar year plans, the amendment deadline is December 31, 2018.

For Sponsors of Retirement Plans

Hardship Withdrawals

Background

Both the December 2017 Tax Cuts and Jobs Act (TCJA) and the February 2018 Bipartisan Budget Act (BBA) made important changes to hardship withdrawals, which can be provided in 401(k), 403(b), and 457(b) retirement plans. The TCJA change made hardship withdrawals more difficult to get for casualty losses, because the damage or loss must be attributable to a federally declared disaster. For more information see our article here. BBA changes generally make hardship withdrawals much more attractive and easier to administer by eliminating certain hurdles for plan participants.

What Changed for Plan Participants

Plan participants no longer need to take the maximum available loan under the plan before requesting a hardship withdrawal for plan years beginning in 2018 (January 1, 2018 for calendar years). Effective on the first day of the applicable plan year beginning in 2019 (January 1, 2019 for calendar year plans), BBA eliminated the rule requiring that employees who take a hardship distribution must cease making salary deferrals for six months. In addition, BBA created a new source of funds for hardship withdrawals— any interest earned on salary deferrals. These hardship withdrawal changes are described here.

What Do Plan Sponsors Need to Do

The TCJA change to hardship withdrawals is an administrative one that impacts internal procedures.  However, BBA changes to hardship withdrawals are likely to require a plan amendment to be adopted on or before the end of the 2019 plan year (December 31, 2019 for calendar year plans), and a summary of material modifications to be issued soon thereafter.

402(f) Special Tax Notices

Background

On September 18, 2018, the Internal Revenue Service (IRS) issued updated model notices to satisfy the requirements of Internal Revenue Code (Code) Section 402(f). The modifications are the result of the TCJA, which extended the time within which a participant can roll over the amount of a plan loan offset to effect a tax-free rollover of the loan offset amount. The new extended period applies to accrued loan amounts that are offset from a participant’s account balance at either plan termination or the termination of employment. A detailed description of these changes and links to the new model notices can be found here.

Defined Benefit Plan Restatements

In March 2018, the IRS released Announcement 2018-15, stating that it intends to issue opinion and advisory letters for preapproved master and prototype (M&P) and volume submitter (VS) defined benefit plans that were restated for plan qualification requirements listed in the 2012 Cumulative List. An employer that wants to use a preapproved document to restate its defined benefit plan will be required to adopt the plan document on or before April 30, 2020.

403(b) Plan Restatements

The deadline to restate preapproved 403(b) M&P and VS plans is March 31, 2020, according to Revenue Procedure 2017-18. 403(b) plans can be sponsored by a tax-exempt 501(c)(3) organization (including a cooperative hospital service organization defined under Code Section 501(c)), a church or church-related organization, and a government entity (but only for its public school employees). For more detailed information, see our article here.

VCP Applications

On September 28, 2018, the IRS issued Revenue Procedure 2018-52, which provides that beginning April 1, 2019, the IRS will accept only electronic submissions to its Voluntary Compliance Program (VCP) under the Employee Plans Compliance Resolution System (EPCRS). The new procedure modifies and supersedes Revenue Procedure 2016-51, which most recently set forth the EPCRS, a comprehensive system for correcting documentary and operational defects in qualified retirement plans. Revenue Procedure 2018-52 provides a 3-month transition period beginning January 1, 2019, during which the IRS will accept either paper or electronic VCP submissions.

2019 Plan Limits

In Notice 2018-83, the IRS issued the cost-of-living adjusted limits for tax-qualified plans. A number of these limits were increased from 2018 levels. For a detailed listing of these limits, see our article here.

For Sponsors of Health Plans

The IRS issued Revenue Procedure 2018-34 in May 2018, which sets the 2019 affordability threshold for the ACA employer mandate at 9.86 percent. Coverage is affordable only if the employee’s contribution or share of the premium for the lowest cost, self-only coverage for which he or she is eligible does not exceed a certain percentage of the employee’s household income (starting at 9.5 percent in 2014, and adjusted for inflation). See our detailed article here.

For Sponsors of High Deductible Health Plans (HDHPs)

In May 2018, the IRS announced in Revenue Procedure 2018-30 the 2019 limits for contributions to Health Savings Accounts (HSAs) and definitional limits for HDHPs. These inflation adjustments are provided for under applicable law. For a more detailed description of the increases, see our article here.

What Do Plan Sponsors Need to Do

Plan sponsors should review their employee benefit plans to determine if any of them are affected by the changes listed above.

Questions?

Please contact the Findley consultant you regularly work with or Sheila Ninneman at Sheila.Ninneman@findley.com or 216.875.1927.

Posted November 12, 2018

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Co-Fiduciary: The Importance of an Independent Investment Advisor

Fiduciary—it’s a word that keeps retirement plan sponsors up at night. With so much buzz around fiduciary duties in the past few years, organizations, large and small, have moved towards relying on outside organizations to assist with fiduciary responsibilities. One important partner a plan sponsor can lean on is an independent retirement plan investment advisor to ensure your plan is providing quality investments and paying reasonable fees.

 

According to the PLANSPONSOR 2016 Defined Contribution Study, 68% of all plans utilize the services of a financial advisor or institutional retirement plan consultant. Why, you may ask? An independent investment advisor can:

  • Limit liability – per the Department of Labor (DOL), the fiduciary (plan sponsors and their committees) retains the responsibility for selecting and monitoring the investment alternatives that are made available under the plan. By engaging an advisor, you can share that fiduciary duty.
  • Give independent guidance – relying on your recordkeeper’s standard lineup may be a conflict of interest if proprietary funds are included. An advisor can help you avoid this conflict of interest by providing guidance on which funds to include based on objectives, expenses and performance.
  • Provide expertise – usually committees/plan sponsors don’t have the time or expertise in fulfilling the role of investment expert. Hiring an advisor does not eliminate your fiduciary responsibilities, but if you do your due diligence in hiring a reputable advisor, you can rely on their expertise as a co-fiduciary.

What should an advisor do for me?

If you are currently getting investment ‘advice’ through your bundled provider, you may be wondering what exactly you are paying for and why you may need an independent advisor. A good investment advisor will have the experience, client references, and reputation in the retirement plan market and will take a consultative approach to determine and monitor the most appropriate investments for the plans and the participants. You can expect that your advisor will:

  • Provide training regarding what a fiduciary is and what the committee/plan sponsor’s responsibilities are as a fiduciary.
  • Develop and maintain a plan’s Investment Policy Statement (IPS).
  • Select investment funds based on performance, expense, and risk tolerance.
  • Monitor fund performance in compliance with the IPS.
  • Benchmark plan fees.
  • Assist in negotiating fees and optimizing your recordkeeper’s services. By working with advisors that are dedicated to the retirement plan industry, they will add more leverage to the conversation because they know the fees and services your providers may offer their other clients of similar size and demographic.
  • Facilitate committee meetings (including taking minutes).
  • Keep the committee/plan sponsors apprised of
    developments in the retirement plan marketplace
    and trends in plan design and administration.
  • Assist with the participant education and
    communication strategy working in tandem with your
    recordkeeper.

How do I find an advisor?

To find an independent advisor that is a good fit for your plan, a Request for Proposal (RFP) is a good tool to evaluate advisors. RFP questions should be carefully selected to ensure the responses help highlight advisor’s strengths in the areas most important in meeting the committee/plan sponsor’s objectives.

Advisors selected to receive the RFP should be advisors dedicated to the retirement plan industry, have a book of business with plans similar in size to your plan, and have the resources to assist with the level of participant education and communication needed by plan participants. Don’t ever make the final selection based
solely on fees. Fees are commonly negotiated. Once the advisor field has been narrowed, the committee/plan sponsor should select a few advisors to meet in person and hear about their value proposition directly from the advisor’s team. Personality and personal connection are important since you will be sitting across the table from the advisor every quarter.

Questions or interested in finding an advisor for your plan, but don’t know where to start? Contact the Findley consultant you normally work with or contact Kathy Soper at Kathy.Soper@findley.com or 419.327.4106.

Posted September 11, 2018

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