As a result, we believe that, as the 401(k) community gains experience with automatic enrollment, a variety of automatic plan designs will emerge to cope with specific circumstances. This article discusses three cases involving our clients.
The first is for a company that had a high level of turnover; the second is for a company that had low deferral rates for currently participating employees; and the third is for a company that was worried about the cost of matching contributions.
The High Turnover Case
The first situation involved a client in the retail industry, where turnover rates during the first year are very high. The company was reluctant to convert to automatic enrollment because of a concern about the administrative difficulty and cost of automatically enrolling participants, when many of them will leave within a matter of weeks or months … resulting in a large number of distributions of small amounts.
In order to obtain the benefits of automatic enrollment for its long-term employees, but to avoid the cost and difficulty of short-term turnover, the eligibility provisions of its plan were designed as follows:
For automatic enrollment, all employees who had not voluntarily enrolled would be automatically enrolled following one year of employment. (Of course, any automatically enrolled employee could opt out of participation.) By deferring the automatic enrollment date, the company was able to avoid most of the turnover while, at the same time, allowing concerned employees to voluntarily participate at an earlier date. In addition, the company was able to design a plan that will cover substantially all of its long-term workforce.
Low Levels of Deferrals
In the second situation, a large company in the real estate industry converted to automatic enrollment for all of its employees. In addition, the company wanted to adopt automatic year-to-year increases in deferral rates, so that participating employees would accumulate substantial retirement benefits (sometimes called "step up" or "escalator" deferral increases). However, the company was concerned that many of its long-term participants were deferring at low rates-and perhaps weren't aware of the need to defer at much higher rates in order to end up with a reasonable level of benefits.
To remedy that situation, the company decided that, for all currently participating employees (as well as for future participants), their deferral rates would increase at 1% per year until they reached 10% of pay.
Matching Cost Concerns
In the third situation, the company was concerned about the cost of adopting a safe harbor automatically enrolled plan. That is because the company wanted to use the matching contribution alternative and, if automatic enrollment resulted in a 90% participation rate (which it often does), the contribution cost would be too high. On the other hand, the company wanted the benefit of satisfying the ADP test (or discrimination testing) under the safe harbor.
The rest of the article is online at http://www.reish.com/publications/article_detail.cfm?ARTICLEID=733
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