It’s not all about “the Benjamins,” but a recent analysis of
the nation’s private retirement system certainly puts a lot of emphasis
on the accumulation of aggregate assets in retirement plans.
The Morningstar report—“
Retirement Plan Landscape Report, An In-Depth Look at the Trends and Forces Reshaping U.S. Retirement Plans”—is extraordinarily diverse and comprehensive
[i] in
its assessment—though while the report’s authors seemed to be striving
for a balanced assessment, the overall sense was one of a leaky boat.
No Surprises
There were some findings that seemed to surprise the authors that
didn’t strike me as all that remarkable. Apparently (I hope you’re
sitting down for this one) larger plans pay lower fees (expressed as
basis points) than smaller plans. They are also more likely to invest in
collective investment trusts (which tend to have lower fees, though
that isn’t necessarily the case).
What I did find surprising was Morningstar’s assessment that
those smaller plans pay, on average, “just” 88 basis points (compared
to the 41 basis points estimated for larger plans)—indeed, I found both
numbers pretty reassuring. On the other hand, “averages” can often
obscure reality, and the authors also found that smaller plans also
feature a much wider range of fees between plans—with roughly a third of
those plans costing participants more than 100 basis points in total.
And make no mistake: Those higher fees are—literally—a “toll” on
retirement. The Morningstar report says that two workers who save the
same amount and invested the same way might well result in an individual
who worked for a smaller employer (and who participated in a smaller
plan) having 10% less in retirement savings. That’s a hefty price to
pay—but then this is hardly the only area in life where larger
purchasers are able to obtain a volume discount.
ESG ‘Risk’
There was also little surprise in the finding that “Plan sponsors
appear to have shied away from considering environmental, social and
governance (ESG) information and analysis, in part because of regulatory
uncertainty.” Oddly, Morningstar’s analysis—here they leverage their
own ratings system to ascertain funds that might be considered to be
exposed to ESG “risk”[ii]—produces a number that, while well short of what Morningstar would apparently deem prudent,[iii] still
notes that “as many as 48% of retirement plans with at least 100
participants already offer investment strategies that use ESG analysis
to evaluate investments”—though that belies the results of most industry
surveys (including PSCA’s 64th Annual Survey of 401(k) and Profit Sharing Plans). On
the other hand, the report acknowledges that this includes funds with a
“broad definition” of ESG—funds that presumably take those type factors
into account without touting that as an explicit emphasis (and perhaps
without the awareness and focus of plan fiduciaries). Regardless, and
undoubtedly for the reasons cited by the report, there’s little question
that plan sponsors outside of the public and non-profit sectors have
indeed shied away from ESG. At least for the moment.
Assets Oriented
There was, however, some interesting new ground in the apparent
“churn” in the system. The report states that more than 380,000 plans
closed during the period from 2011 to 2020—a result it attributes
largely to employers going out of business. While that is certain a
point of vulnerability for those previously covered by those plans (not
to mention the presumed loss of employment), the solution for that lies
beyond the retirement system per se.
As we have noted consistently, the report expresses concerns about
coverage and the access to workplace savings, but ultimately
differentiates its focus from traditional retirement system analysis by
focusing on the size and flow of the system, as measured by assets.
Indeed, and as noted above, the report seems particularly obsessed on
the subject of assets—not on an individual level, or on obtaining a
measure of retirement income adequacy, but on the premise that more
assets mean the ability for plans in the system to negotiate for lower
fees (and, on a related note, to opt for investment types, notably CITs,
that have lower expenses). But while the emphasis was intriguingly
unique, it’s also the basis upon which these authors affix the “fragile”
label to the system, as if “the system”—as measured by assets—must
constantly grow in order to be considered healthy.
Now, there were some jaw-dropping numbers behind this premise—the
report claims that there have been outflows of more than $400 billion a
year since 2015, at least as reported by plans in their annual filings.
However, at a time when 10,000 Boomers are said to be heading off into
retirement every day, one might well expect a lot of them to be taking
their retirement savings with them.
‘Out’ Flows?
The concerns expressed in Morningstar’s analysis seems to assume that
much of the outflow is pre-retirement “leakage”—though they seem
equally concerned about rollovers. Why? Well, once again they write
that, “More assets in the defined-contribution system would help more
sponsors gain the leverage to demand lower fees from asset managers and
drive down costs for end investors.” While true enough, it seems an odd
anchoring.
Indeed, in commenting on their assumptions, the authors comment that
while they believe their estimates are “conservative,” and that “any
errors understate the massive detectable flow of money out of DC plans,”
they also admit that it is “…clear from Internal Revenue Service data
that most flows out of plans are for rollovers rather than cash-outs…,”
though they concede you can’t draw a distinction there between cash-outs
and rollovers with the Form 5500 data.
Indeed, while 30,000-foot assessments of the retirement savings
landscape are not unique, in looking nearly exclusively at the total
pool of assets in that system and its implications, Morningstar’s
report makes no attempt to correlate those assets to the needs of the
individuals covered by the system.
‘Pool’ Rules?
That asset-focused prism leaves it to claim that the entire system
“relies on a few thousand employers to cover most people saving for
retirement,” as though that’s a unique vulnerability. But the defined
contribution retirement system is not one gigantic pool that must
satisfy all obligations. Sure, it would be great if more employers,
specifically more small employers, saw fit to offer a plan—but the fact
that they don’t doesn’t put “the system” at risk.
But those who do have these programs, and take advantage of them,
face no jeopardy as a result (although they may well wind up being taxed
at higher rates in the future). The U.S. DC system doesn’t “rely” on
new employers to offer plans to compensate for those that are no longer
doing so—though arguably the coverage gap, and the lack of ready access
that results, are an issue of general concern.
All in all, the report offers an interesting assessment of “the
system”—more thoughtful and comprehensive than most, though the
obsession with total assets seems a bit myopic, and as one might expect a
lot of assumptions, perhaps of necessity in a report as broad as
this.
In sum, while its conclusions are perhaps a bit “fragile” upon which
to build a firm assessment, there’s plenty there to warrant
discussion—and action. But is the system "Fragile" - only for those who
aren't part of it.
- Nevin E. Adams, JD
[i] While
much of the report focuses on DC plans, the Morningstar researchers
also intriguingly acknowledge that more than 33 million people are or
will receive benefits from defined benefit plans as of 2019, and that DB
plans accounted for more than 30% of distributions paid to participants
in 2019 and they do not appear to have peaked. It even notes that
approximately 8.8 million people who are no longer working are still
entitled to future benefits and 11.7 million people who are still
working will eventually receive benefits. Looks like those “dead”
pension plans still have a lot of life in them!
[ii] The
percent of assets that are in the various categories of ESG risk
assigned by the Morningstar® Sustainability Rating™ for funds, sometimes
called the globe rating.
[iii] In
fact, the report comments, “…sponsors have left the U.S.
defined-contribution system in the aggregate tilted toward investments
with more ESG risk—which is the degree to which companies fail to manage
ESG risks, potentially imperiling their long-term economic value. Plan
sponsors may wish to reexamine their investment choices using an ESG
lens.”