Thursday, November 28, 2019

Some Thanksgiving Thanks!

Thanksgiving has been called a “uniquely American” holiday, and while that may be something of an overstatement, it is unquestionably a special holiday, and one on which it seems appropriate to reflect on all for which we should be thankful.

So, as I look back at this past year:
  • I’m thankful that so many employers voluntarily choose to offer a workplace retirement plan – and that so many workers, given an opportunity to participate, do.
  • I’m thankful that a growing number of employers have chosen to automatically enroll valued workers into these programs, and that they are increasingly opting to establish a default contribution rate in excess of the “traditional” 3%.
  • I’m thankful that the vast majority of workers defaulted into retirement savings programs tend to remain there – and that there are mechanisms (automatic enrollment, contribution acceleration and qualified default investment alternatives) in place to help them save and invest better than they might otherwise.
  • I continue to be thankful that participants, by and large, continue to hang in there with their commitment to retirement savings, despite lingering economic uncertainty and competing financial priorities, such as rising health care costs and college debt.
  • I’m thankful that more plan sponsors are making it easier for workers to participate in retirement savings programs, and automatically enrolling them sooner and at higher default contribution rates.
  • I’m thankful for the strong savings and investment behaviors emerging among younger workers – and for the innovations in plan design and employer support that foster them. I’m thankful that, as powerful as those mechanisms are in encouraging positive savings behavior, we continue to look for ways to improve and enhance their influence(s).
  • I’m thankful for qualified default investment alternatives that make it easy for participants to benefit from well-diversified and regularly rebalanced investment portfolios – and for the thoughtful and ongoing review of those options by prudent plan fiduciaries. I’m hopeful that the nuances of those glidepaths have been adequately explained to those who invest in them, and that those nearing retirement will be better served by those devices than many were a decade ago.
  • I am thankful that powerful, impactful legislation like the SECURE Act can still pass the often-divided House of Representatives on a robust bipartisan basis – though I can’t help but be disappointed that, for the moment, anyway, the much-needed benefits have fallen prey to other matters.
  • I'm thankful for the increase in contribution and benefit limits - so that those who can afford to set aside more for retirement can do so (as we all strive to help our retirement funding keep pace with the cost of living).
  • I’m thankful for the development of our new Certified Plan Sponsor Professional(TM) credential, the support of our education partners in not only developing the program, but in partnering with us, and our various advisor networks to help distribute critical education to plan sponsors who, though tasked with an awesome task, are seldom provided the training or education commensurate with that responsibility. 
  • I’m thankful that figuring out ways to expand access to workplace retirement plans remains, even now, a bipartisan focus – even if the ways to address it aren’t always.
  • I’m thankful that the ongoing “plot” to kill the 401(k)… (still) hasn’t. Yet.
  • I’m thankful to be part of a team that champions retirement savings – and to be a part of helping improve and enhance that system.
  • I’m thankful that those who regulate our industry continue to seek the input of those in the industry – and that so many, particularly those among our membership, take the time and energy to provide that input.
  • I’m thankful for all of you who have supported – and I hope benefited from – our various conferences, education programs and communications throughout the year.
  • I’m thankful for the warmth with which readers and members, both old and new, continue to embrace the work we do here.
  • I’m thankful for the team at the American Retirement Association, and for the strength, commitment and diversity of the membership. I’m thankful to be part of a growing organization in an important industry at a critical time. I’m thankful to be able, in some small way, to make a difference.
 But most of all, I’m once again thankful for the unconditional love and patience of my family, the camaraderie of an expanding circle of dear friends and colleagues, the opportunity to write and share these thoughts — and for the ongoing support and appreciation of readers… like you.

Wishing you and yours a very happy Thanksgiving!

- Nevin E. Adams, JD

Saturday, November 23, 2019

A Valuable ‘Commodity’

I’ve been on the road a lot over the past several weeks – and I’ve noted a remarkably diverse range of prices in gasoline across various locales.

I think it’s fair to label gasoline a “commodity[i]” – what the dictionary describes as “a reasonably interchangeable good or material, bought and sold freely as an article of commerce.”

Oh, sure – you may have a preference for one brand or another, you may not care for the political allegiances of their ownership… but when push comes to shove, it usually comes down to price – because, after all, when it comes to gasoline, it’s pretty much the same stuff.

For years, recordkeeping services – complex and difficult as they can be to provide accurately and consistently (not to mention profitably) – have been characterized (some might say disparaged) as a “commodity,” while fee compression (and the aforementioned complexities) continue to fuel consolidation in that industry.

Honestly, as a former recordkeeper, I’ve never understood how anyone who had any real appreciation for a business as varied, complex, and demanding as that of keeping up – and keeping up accurately – with individual participant accounts over the course of a working career – would be willing to refer to those services as “interchangeable.” Or why any firm that provides those complex services in these challenging times would be willing to let others do so. Certainly any participant, plan sponsor, or advisor who has seen the integrity of that data put at risk by clumsy and inattentive hands can attest to the impact that a failure to do so. Indeed, I’m shocked by the leaders in our industry who label it as such – leaders that I think might well feel differently if they had spent even a small amount of time in those shoes.


Without question, recordkeeping is not only a challenging business, it is expensive to stay current with technology, to keep processes and programs current not only with changes both in the laws and regulations, but the nuances of individual plan designs. And as if that weren’t enough, cybersecurity has recently emerged as a significant threat – little wonder in view of the enormous amount of sensitive financial data to which these “commodity” producers are entrusted.

Where recordkeeping does seem to have been “transformed” into a commodity business is in the pricing of those services. Like the gasoline drawn from a pump, economists would tell you that, since commodity products are “interchangeable,” they compete (only) on price – and to do so (profitably) requires that that you have to achieve economies of scale – and the continued downward pressure on fees for those services continues to force firms to exit or flee to the embrace of larger players.

Further fueling those trends, the plaintiffs’ bar has latched onto the “commodity” concept, having (apparently) determined that it is “appropriate” to be compensated for these services by a flat per-participant charge ($35 seems to be their notion of “reasonable,” at least for the multi-billion-dollar plans targeted, though the courts don’t seem ready to buy into that presumption just yet).
I know that over the years there has been an ongoing attempt to “functionalize,” to break the complex process of recordkeeping (I tend to think of it as participant accounting) down into component parts like some kind of mass assembly line – and perhaps some quarters have done so successfully. Perhaps then, at least in some venues, that once ornate, vibrant (though often complicated and tedious) process has actually been reduced to one so regimented and segmented, so parsed out between segregated operational touchpoints that it might there truly be considered a “commodity.”

But my personal experience is that those who find themselves working with a service provider or TPA that views those critical services as a “commodity” will, in short order, wish they weren’t.

- Nevin E. Adams, JD

[i]Now, if you’ve ever had the opportunity to shop for groceries in different parts of the country, you pretty quickly become aware of some incredible price differences in a variety of items, including things as basic as produce or milk. But it’s gasoline that tends to draw my attention, not only because it’s something I buy regularly, but because I don’t even have to walk into a store to compare prices.