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Asset Mix:Preventing a Fee Backlash

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Above-Average Fees 

What should a sponsor do if the plan has above-average fees? “The first thing sponsors need to know is why. There are reasons certain plans have higher costs—maybe a plan has really poor demographics, maybe it has very low balances,” Itzoe says. “The second thing is to say, ‘What steps can we take to reduce and restructure the fees? Can we get into lower share classes? Can we utilize passive funds?’ Third, is there any way to pay some of the fees outside of the plan [with the employer taking care of some plan fees]?” The last thing, Itzoe says, is that if you cannot, or are not willing to, restructure the fees or pick up some costs, it is important to figure out a very clear, well-crafted explanation for participants.

For plans with an above-average plan fee, sponsors “need to demonstrate the value that participants are paying for,” Reese says. “If they have something that, compared to other plans, is above average or unique, explain that. They just need to be very specific, highlighting the positives and the unique things.”

Hoffman thinks plan sponsors’ fiduciary concerns, especially education versus advice, will prevent many from offering too much detailed, comparative fee information. “There is an issue with regard to where you draw the line and what information is educational and what information potentially constitutes investment advice,” he says.

Open for Discussion 

Advisers such as Pensionmark have a solid idea of what information sponsors can expect participants will want, beyond an initial educational piece, because they have been proactive in approaching fee disclosure and have made disclosures ahead of the legal requirements. Usually, only a few participants call to discuss fees further, Duex says. “Probably only 1% or half of 1% of participants care, but for those who do care, it does not matter how many memos you put in front of them; to get their questions answered, they need to call someone,” she says.

Questions often relate to a couple of main areas. “A lot of times it is, ‘I read ­something…’” Hammond says, adding that a participant may have done online research about 401(k) fees. “People who read through that [information] are generally trying to find some kind of benchmark on their own,” he says. They may have come across an article mentioning a large plan’s very low expense number but may not understand that plan fees can differ, based on such factors as plan size, Duex says.

Participants also often need guidance through their own statements and an explanation of specific fees, such as brokerage-window. “They want you to walk them through the calculation,” Hammond says.

Judy Ward
editors@plansponsor.com

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