Every plan, and every investment committee, is unique — and yet, conducted properly, there are inevitably areas of commonality.
As the quarter draws to a close and preparations for these meetings get underway, here are some questions that could enhance the discussion, if not the outcome, of your next meeting.
1. Do we really need to have all these funds on the menu?
We know that participants tend to hold four or five funds on average, regardless of how many choices are on the menu. And for years we’ve known that the more choices participants have, the more difficult it is for them to make choices. (Remember the famous study about jam choices?) Sure, it can be hard to let go of a fund, especially if some participants have invested money in that option. But what tends to happen over time is a kind of fund menu inflation, where new funds get added but old ones never leave.
The funds on your menu should have a purpose. If they don’t — even if they once did — you aren’t doing anyone a favor by cluttering up the menu. And you could be leaving in place a non-performing ticking time bomb that could lead to problems later on.
2. Are there less expensive share classes available for the funds on our investment menu?
Arguably, this is the question that the defendants in Tibble v. Edison should have asked, and spared themselves a lot of time and litigation. The bottom line is, if there’s no difference in a fund choice (particularly when it’s just a different share class of the same fund) other than price, why is the more expensive one on your menu?
3. How much are our participants paying for this plan?
Odds are that most of the fees paid by the plan are investment-related, and with all the additional fee disclosures floating around, you’d like to believe that the committee already knows the answer to this question.
In my experience, however, it’s one thing to invoke a sterile “x basis points” assessment and another thing altogether to stop and do the math to put a gross dollar figure on the total cost to the plan. Or maybe even how much the average participant in the plan is paying in dollars and cents.
4. What services are we buying with those fees?
There’s been a lot of focus on fees lately — but fiduciaries are charged with ensuring that the fees and services rendered are reasonable. And I’ve never understood how you can figure out if fees are “reasonable” if you don’t know what you are paying them for.
5. Do we all need to be on this committee?
Over time, committees have a tendency to expand, sometimes based more on factors like internal organizational politics than on valuable perspectives or expertise. But human dynamics are such that the larger the group, the more diffused (and sometimes deferred) the decision-making.
As for how to trim the “fat” from the committee, sometimes all you have to do is remind committee members that plan fiduciaries have personal liability (see “5 Things Plan Sponsors Should Know”).
6. Who’s taking notes?
Finally, if you’re having a committee meeting, you’ll want to document all decisions that are made and the rationale behind each one. Prudence is process, after all — and it often starts with asking the right questions.
- Nevin E. Adams, JD