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.
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 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.
How many of us will be so fortunate as to participate in an employer-sponsored retirement plan every day of our working careers? Or, for an even more uncommon scenario, how many of us will work for the same company for 30 or 40 years? Yet, as has been amply established by the Employee Benefit Research Institute (EBRI), those who can raise their hands and respond “yes” to either of these questions routinely show up in the top decile of savers who are well-prepared for retirement—and these participants provide a clear blueprint for retirement-saving success.
Give ‘Em What They Want—And Need!
Warren Cormier, CEO of Boston Research Technologies, recenty published a research study that revealed that a large majority of plan participants are receptive to consolidating their retirement savings accounts in their current plans.
Plan sponsors can help themselves and their participants over the long term by rolling balances of $5,000 or less from inactive participants into safe harbor IRAs. However, for various reasons discussed below, many safe harbor IRAs don’t live up to their name and could leave sponsors with unexpected fiduciary liability.
Mandatory distributions from employer-sponsored plans are a creation of regulation—specifically, a section of ERISA that allows plan sponsors to distribute accounts with less than $5,000 out of a qualified plan and into a safe harbor IRA. If plan sponsors follow the rules, they are protected from legal recourse, and the rules are simple: act in a fiduciary manner when choosing a provider for their program. However, that word—“fiduciary”—is often hard to define and can be interpreted in many ways, so it begs the question: “How does a sponsor best fulfill that responsibility in the context of a mandatory distribution program?”
The Pension Protection Act of 2006 created a safe harbor for retirement plan sponsors to automatically enroll employees in their plans. This provision was designed to help plan sponsors and participants over the long term, and it has—but it also unintentionally fueled a surge in small accounts, hurting both constituencies.
Retirement plan sponsors can reap significant rewards from the automated, two-way flow of retirement savings accounts into and out of plans. This “automated portability” spawns important downstream benefits for sponsors—but sponsors can only capture them by choosing to recycle mandatory distributions rather than continuing to dump them into an already sizable landfill of micro-balance safe harbor IRAs (see Employee Benefit News previous blog post titled Why Dump Mandatory Distributions In A Landfill When You Can Recycle?). This article focuses on one of those benefits—the decrease in plan costs obtained through the increase in a plan’s average account balance.