Hey, plan sponsors: Imagine for a moment that your active participants are Tom Cruise from Mission: Impossible (or Barbara Bain, Peter Graves and Martin Landau, for those of us who remember the classic TV series).
Consolidation Corner Blog
Consolidation Corner is the Retirement Clearinghouse (RCH) blog, and features the latest articles and bylines from our executives, addressing important retirement savings portability topics.
Have you ever received a letter with the notice “Time Sensitive Material! Open Immediately!” boldly splashed across the outside of the envelope, only to sigh with disappointment with what’s on the inside? While the disappointment of false advertising so often seems to be the case with “junk mail,” the warning turns out to be true when we examine the behaviors of retirement plan participants who have recently changed jobs.
In the wake of the Fiduciary Rule, providers of all stripes are broadly reevaluating their strategies for the participant and asset retention that is essential to growing their retirement plan businesses. Over the past two decades, providers have primarily looked to capture IRA rollovers as a means to grow retirement assets. The Department of Labor’s new Fiduciary Rule creates challenges to that model. However, there is another, largely untapped, pool of assets within providers’ reach that can fuel growth—premature cash-outs. Auto portability, and portability solutions in general, represent a new and unique way to tap that potential source of growth.
First, let’s review the definition of “leakage.” If we think of total 401(k) savings as a bucket of water, “leakage” refers to those retirement savings that, like water in a leaky bucket, are withdrawn from the U.S. retirement system every year. There are three holes in the bucket: cash-outs at the point of job change, hardship withdrawals, and loan defaults. According to the U.S. Government Accountability Office, one of these holes is much bigger than the other two combined—nearly 89% of all leakage is attributed to cash-outs that occur when a participant changes jobs. Hardship withdrawals and loan defaults together account for the remaining 11%.
The Department of Labor’s much-anticipated Fiduciary Rule is ushering in many changes across the retirement services landscape, and the new rules governing the “what, how and why” for advice at the time of a participant’s job change will undoubtedly transform the rollover-to-IRA market. However, a closer reading of the Fiduciary Rule sends a clear, if unstated, signal to plan sponsors, financial advisors and record-keepers—absent a compelling reason to roll over to an IRA, keep participants invested in a qualified defined contribution plan throughout their working lives.
As has happened so many times before, the Baby Boomer generation is once again drawing attention to an unmet need: a seamless way to consolidate their collection of retirement accounts into a single account, which is a necessary step to creating a sturdy retirement plan. Much has been written about how sponsors can improve both their plans’ overall health and their participants’ retirement outcomes by embracing roll-ins; nonetheless, the account-consolidation process remains time-consuming and expensive for most participants.
In a previous blog post, we asked, “Why dump mandatory distributions in a landfill when you can recycle?” As we wrote then, sponsors exercising their authority to automatically roll over separated participants’ small balances into safe harbor IRAs—without encouraging participants to take their retirement account savings with them at the point of job change, or facilitating “auto portability” to make plan-to-plan asset transfers a seamless process—are doing themselves and their participants a disservice in the long run.
Have you ever wondered why so few participants move their old 401(k)s into their current employers’ plans? Or why so many participants prematurely cash out their retirement savings accounts, regardless of taxes and penalties? Or why job-changing participants leave their savings behind only to lose track of them—as if their assets for retirement belong on some remote desert island away from all their other savings?
Auto enrollment, codified in law by the Pension Protection Act of 2006, was drafted with the best of intentions—to increase Americans’ retirement savings—but it has had the unintended consequence of impairing plan effectiveness. By proliferating small accounts in plans, auto enrollment has caused a decrease in average account balances throughout the U.S. retirement system. Adding to the urgency of this issue is the rising rate of auto enrollment adoption across defined contribution plans of all sizes, but particularly among larger plans.
We humans are not islands. Everything we do affects the people, neighborhoods and ecosystems around us in some way. One act of kindness for another person can inspire the recipient to perform a good deed for someone else, and through a ripple effect, many others can benefit.