These are the 'Five Ways' as the author wrote them, and my comments in red.
1.) A Focus on Fees. New 401(k) fee disclosure rules are a good first step, but employers and participants need to focus on investment costs in plans, as investment costs represent 84% of a plan's fees. Unnecessarily high fees will eat away at the value of retirement savings over time. This is a true (albeit obvious) statement. I think more important for employer's to understand is the relationship between investment costs and subsidies delivered to service providers like record keepers, TPAs and custodians. It's great to compress investment expenses by selecting institutional class investments and the like. We are certainly advocates here, but a dialogue about the reaction of the vendors on billable costs needs to be assessed as well. If the service provider fees are unaffected by swapping expensive funds for inexpensive "equivalents", that makes a lot of sense to do. If it results in an increase of billable costs to the employer, it must be well vetted before implementing.
2.) Mandates for savings. The single most effective step that Congress could take to increase retirement savings is to set mandates requiring employers to offer some form of a retirement savings vehicle along with mandating an employer match and employee participation in the plan. By providing access to a savings vehicle, forcing contributions at some level and automatically enrolling participants on day one, mandates will jump-start retirement savings for millions of Americans. This is a great idea in theory, one that we've actually posited at our firm quite a bit. See this article that I co-authored a few years ago that identifies Savings Rate as the significantly most important factor in creating Retirement Success
linked here --> https://www.unifiedtrust.com/documents/PositiveOutcomesFactorsv43.pdf
Many states have considered mandating employer sponsored retirement plans at the state level. The furthest along on this is California. Mandating an employer match or mandating employee participation in the plan will prove more difficult. Many employers, if mandated to contribute to the plan, will do so by way of reducing current employee salaries accordingly. Ultimately, this will not necessarily help the employees and may, in fact, hurt them. Similarly, mandating employee contributions to the system has been done before, it's called Social Security. The difference offered here is that this forced contribution would be in a privatized 401(k) setting. Yes it will jump-start retirement saving, but may come at a current lifestyle price. This is a very slippery slope, and my sense is that if they go down the path of mandating contributions, it most likely won't be to the benefit of the private system, but rather it will likely be done in a public setting benefiting the govt.
3.) Defined investment options for workers. The 401(k) has opened the door to broad investment choice, but many workers feel confused rather than empowered by the options. One solution is to simplify the investment process by automatically enrolling participants in a professionally managed investment program providing most workers with an appropriate investment for their situation based on all investment assets, not just those in the retirement plan. For those wanting to go it alone, there would be an option to do so. Actually, I wholeheartedly agree with this point. In fact, this actually already exists.....allow us a little self-promotion. Our firm, Unified Trust Company has a system that works precisely as described. Here is a link that can introduce the concept that we call The UnifiedPlan --> https://www.unifiedtrust.com/up/index.cfm
4.) Restricting distributions. Under the rules, it is too easy for workers to take withdrawals from their 401(k)s, and as a result, too many participants treat their retirement savings like a checking account. Over time, and with the power of uninterrupted compounding, individual 401(k) accounts are likely to grow and be put to use as intended — to provide an income stream in retirement. Yes, right now within the rules a plan may allow for Loans or In-Service Withdrawals. I think that many of us practitioners would like to do away with loans altogether. I've heard them referred to as the bane of retirement plan record keeping. That said employers can eliminate them altogether from their respective plan now, if they choose to. Many do not because they fear that taking that extreme position will cause lower participation, and in some cases they are correct. I would submit that a good idea is to allow for either loans or an in-service distribution feature, but not both. Further, I'd suggest that employers explore restricting the loans in some way or otherwise set the loan policy so that taking one is undesirable. A few ideas:
- Maximum of one loan outstanding at a time
- Condition the loan as a Hardship loan, only approve if a verified hardship exists
- Set the interest rate to the loan as something high, for example Prime plus 2 or even higher