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Industry Experts Have Ideas for Change on QDIA Proposal

October 2, 2006 (PLANSPONSOR.com) - While industry experts generally applaud the work done by Department of Labor (DoL) rulemakers on the recently released default investment option safe harbor proposal, they still have suggestions for change, including whether the protected options should include a short-term investment vehicle.

Department of Labor (DoL) officials last week released the proposed safe harbor rule governing default investment options that can be chosen by retirement plan sponsors for auto enrollment programs and scenarios in which employees fail to submit investment instructions (See DoL Releases Default Investment Option Safe Harbor ) .

The qualified default investment alternatives (QDIAs) in the proposal include:

  • lifecycle or targeted-retirement date funds,
  • balanced funds, and
  • managed accounts.

Larry Goldbrum, executive vice president and general counsel of The SPARK Institute, said the options make sense. He pointed out that plan sponsors can look at their retirement plan participant population and cater their default investment option choice to the general demographics.

The selections give plans sponsors flexibility, Goldbrum told PLANSPONSOR.com. They can choose the option good for the plan as a whole, such as a balanced fund, or select target date funds to cater to employee age ranges, or choose the managed account option to cater to the individual participant.

However, Dallas Salisbury, president and CEO of the Employee Benefit Research Institute, expressed concern about the QDIAs proposed. He said the main issue is how plan sponsors can properly default young and mobile participants who are likely to leave the plan soon and more likely to take their money out without having some kind of stable value or money market option. The worry is that without a stable value or money market-type option (or both), people will take out their money in a down market and have to take the loss.  Salisbury wants to add both a money market and a stable value option along with the three existing QDIA alternatives set out by the DoL.

Salisbury said he is also concerned that plan lawyers will pressure sponsors away from pushing for additional QDIA alternatives because of the safe harbor offered for the three approved options and the signals that the DoL hopes plans use the ones it has proposed.

While he said he certainly supports the DoL's stated goal of continuing to encourage long-term retirement saving, Salisbury argued that it is simply unrealistic in a day when plans offer loans and hardship withdrawals as ways for participants to take money out over the short term. "That's not how retirement plans are structured," Salisbury said of the existing rule proposal.

On that issue, Philip Suess, principal with Mercer Investment Consulting and segment leader for its DC business, notes the DoL is not ruling out money market or stable value default investments. The point is there is protection if the plan sponsor wants to move to equity vehicles as default options, but the department maintains money market and stable value vehicles are not imprudent.

The QDIA protections mirror protections given by 404(c), Suess points out. The DoL is telling plans to follow its suggested process for selection in funds and plan officials will not responsible for losses that may be incurred. Just like 404(c), the fiduciary still has responsibility in selecting and monitoring such funds. Also, just as compliance with 404(c) is voluntary if sponsors want to afford themselves its protection, choice of a QDIA is also voluntary.

Goldbrum agrees. He said stable value and money market vehicle providers may have felt they were overlooked, but the department was signaling a shift from short-term cash preservation to more long-term growth and was removing a barrier of concern about potential lawsuits if plan sponsors choose an equity-type investment.

Related to the QDIA choices, Rich Koski, managing director at Buck Consultants, said he was surprised the DoL went with target date funds because some have what he said is a high equity exposure and unusually high fees. He also questioned the DoL's instructions to consider the average participant in the plan as a whole when selecting a balance fund option since most of the people in the plan will not be defaulters. According to Koski, a balanced fund for defaulters should take into account those likely to use them - the younger, more mobile workers.

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