Grading on a ‘Curve’

A recent analysis of world pension systems gave America a passing grade, but not a good one.

The latest—the Mercer CFA Institute Global Pension Index[i]—gave the United States a C+ (though a B in adequacy!) ranking our retirement “system” well down (22^nd) in the list of 47 retirement income systems around the world. 

This particular index is comprised of three sub-indices: adequacy, sustainability and integrity, which the authors say are used to measure each of the retirement systems against some 50 “indicators.”[ii] Of course, people are entitled to establish whatever criteria they think is reasonable in such matters, but those who would accept their grading at face value would be well-advised to consider both the assumptions and weighting applied to derive those outcomes. To the sponsors’ credit, the 144-page document provides lots of opportunity to do just that.

Perhaps the biggest challenge of a system like ours matched up against some of these other systems is the sheer diversity not only of our population, but the system itself. The coverage gap[iii] we’re focused on closing presents a considerable disadvantage compared to systems that employ nationwide mandates.  And, let’s face it, the funding issues of Social Security loom ever larger, and undermine the “sustainability” measure of this index, if not the “integrity.” 

If one were to take the recommendations of these authors to heart, in order to boost our grade, we’d need to make people contribute more, make them wait longer to get their benefits, pay them (particularly lower-income workers) more benefits, increase vesting so that they earn more benefits faster, and limit their ability to tap into those retirement benefits before retirement—both by leakage, but also in requiring that some part of those benefits be taken as an income stream.

Said another way, provide more government benefits and make people put in more (and don’t let them take it out) so that they will have more later. This, by the way, has been a consistent recommendation (though perhaps worded more eloquently) of this index.

One thing that is NEVER mentioned, or even acknowledged in this report is the cost of these measures, the taxes imposed to produce them. Or the willingness of the population to undertake them to the exclusion of other considerations. They aren’t, ironically enough, “means” tested.

That’s not their responsibility, of course. Arguably presenting these retirement system alternatives around the world provides policymakers and the populace alike with a broader perspective—ideas and approaches to consider, albeit those concocted in a pristine laboratory environment where costs and personal choice are of no matter—only the largesse of benefits. 

But for those of us living in the real world, and those still working on implementing the tools in the SECURE Acts—I’d give this assessment a grade of “incomplete.”

- Nevin E. Adams, JD

 

---

[i] In case you’re wondering, Netherlands, Iceland, Denmark & Israel topped the list (again), all receiving an “A” grade, at least based on the criteria and weighting adopted by the index. The index has been published for a number of years now, and while Mercer’s role has been consistent, different parties (now the CFA Institute) have partnered in its production over the years.

[ii] The report explains that each system’s overall index value is calculated by taking 40% of the adequacy sub-index, 35% of the sustainability sub-index and 25% of the integrity sub-index—weightings that they say “have remained constant since the first edition of the Index in 2009.”

[iii] Indeed, it would be naïve to gloss over the gaps in retirement security that a largely voluntary system exposes. Not that anything (beyond inertia and human nature) prevents every American worker from opening their own retirement account. But we know, and the data supports, that even modest income ($30,000-$50,000/year) workers are 12-15 times more likely to do so when they have the opportunity to do so via a workplace plan. In fact, there’s plenty of impetus in the provisions of the SECURE and SECURE 2.0 Acts to encourage the formation of those plans.

A Day for TPAs

It might not have made it to your calendar, but last week (October 17) was National TPA Day. 

The timing is no accident—yesterday would have been for many calendar-year ERISA plans the (extended) deadline for filing the annual ERISA 5500 form.[i] Like April 15 for CPAs, that date—and timing—are of enormous consequence. And with that annual deadline in the rearview, third-party administrators everywhere can, perhaps, heave a huge sigh of relief. Maybe even throw a little “party.”

The relationship between advisors and TPAs is complex, and one in which there seems to be little middle ground. For every advisor that tells you how many times their TPA partner has gotten them out of a real mess—and for every TPA that applauds the leadership demonstrated by their advisor teammate—well, there seems to be one that either dismisses the TPA’s propensity for a mistimed focus on minutiae that is the essence of being a dutiful TPA, or one that frets that an advisor’s focus on the “big picture” obscures significant operational and administrative issues.

There is, in fact, a certain yin and yang to the perspectives of the two roles—and just like the concept that originated in Chinese philosophy (describing opposite but interconnected, mutually perpetuating forces)—successful (and legal) plan design and operation require a balance. Where plans often fail is when one or the other dominates. 

Just as advisors are often (and inaccurately) seen as the sole fiduciary in a plan once they’re hired, TPAs are generally assumed to be attending to all of the particular details of accurately running the plan; we’re talking about things like ensuring that the terms of the plan document are adhered to, that non-discrimination tests are properly applied, and that contributions are timely deposited. The lines are often blurred between TPA and recordkeeper—the latter technically being a TPA, though these days the level of services can differ dramatically. 

Over time the role of TPA has been diminished in the eyes of many. Sure, they deal with a lot of technical “minutiae”—we’re talking deep in the “weeds” here. The classic reference is you ask what time it is, and they (some, anyway) first want to explain to you how a watch is made. That said, the role of plan administrator—perhaps a better label would be compliance administrator—is essential—critical—to the smooth, effective and efficient running of a plan—and on aspects that,[ii] odds are, your recordkeeper (another critical role, but one often focused on other things) isn’t always. They can even help you find—and keep—clients!

That said, TPAs come in all shapes and sizes—and like advisors—have different service models, areas of specialization and, yes—personalities. If you’ve had a bad experience—you’re not alone. But for my money, if you want to be able to focus on the plan issues that truly require your expertise—rather than your attention—you’ll find that all to be easier with the assistance, support, and guidance of a qualified TPA.[iii]

If you’ve found a good one (or two)—be sure to give them a hug—and maybe a cake. It’s National TPA Day, after all… 

- Nevin E. Adams, JD

Additional TPA Resources: 

Finding the Right TPA Partner

Bundled Versus Unbundled: 5 Myths

Resource ‘Full’?

What’s in a Name?   

 

---

[i][i] Credit the folks at John Hancock for—to my eyes, anyway—making TPA Day a “thing.”

[ii] Things like that: 

1. All eligible workers are included in the plan—as required by law—and ineligible workers are not unduly credited with benefits?
2. Compensation used as the basis for contributions and/or eligibility is accurate, in accordance with ERISA and IRS limits, both with regard to amount (how much) and individuals (who)?
3. The plan’s allocation of benefits meets legal requirements and the correct individuals receive the correct amount(s), thus preventing the need for corrective measures and penalties? 
4. The amount(s) allocated to individual participant accounts match the actual dollars deposited into the plan/trust. Additionally, to ensure that contribution deposits are made to the plan/trust in accordance with legal requirements, forestalling legal fines and penalties?
5. The appropriate plan notices are timely delivered to the applicable individuals in accordance with legal requirements, providing them with important plan information and instructions (and preventing the application of penalties for failing to do so)?
6. Employees are properly categorized as to their status as highly compensated employees (HCEs), key employees (for top-heavy testing) and spousal/familial relationships so that the allocation of benefits and eligibility is appropriate and consistent with legal requirements?
7. The tax filings related to the plan (Form 5500, 8955, 5330, etc.) are filed accurately and on time in order to comply with the legal requirements regarding the plan, and thus avoid fines and penalties?
8. The amounts distributed as loans or distributions are consistent with the vesting schedule of the plan, in accordance with plan parameters and legal limits—and that the needed authorizations are obtained?

[iii] And here’s a resource that can help you validate/align expectations of service; HERE.

Mark Your Calendars!

Social media routinely reminds me that I’m teetering on the brink of overlooking key remembrances—days in the year to honor sons, daughters, puppies, dogs, kittens, and…well, you name it. And we have whole months set aside to acknowledge the contributions of women, black history, and Hispanic heritage—but there’s another you might have missed…

As it turns out, October is National Retirement Security Month—a “national effort to raise public awareness about the importance of saving for retirement.” More specifically, to provide an opportunity for employees to reflect on their personal retirement goals and determine if they're on target to reach those goals—and for those who work with those employees to help them do so.

Now, while the need isn’t new, the calendar acknowledgement is, at least relatively so. The notion was raised in 2006 by then-Sens. Gordon Smith (R-OR) and Kent Conrad (D-ND)—though at that time it was “just” a week. However, in 2020, the National Association of Government Defined Contribution Administrators took it even further and updated its legislative priority to advocate to change it to National Retirement Security Month, instead of only the week.   

That said—and despite the hard work, talented designs, and sponsorship of a number of large and reputable financial services organizations, I suspect many of you haven’t even heard of it. More’s the pity.

Key Objectives

Traditionally, the week is focused on three key objectives:

• making employees more aware of how critical it is to save now for their financial future;
• promoting the benefits of getting started saving for retirement today; and
• encouraging employees to take full advantage of their employer-sponsored plans by increasing their contributions.

Now, if you’re reading this (and you are, aren’t you?), odds are that you’re all too aware of the challenges that confront our nation’s retirement savings system. I’d go so far as to wager that just about everybody taking the time to read this post thinks about those items every working day, and doubtless spends a good part of their week trying to advance those causes—so, what’s the point of a month devoted to that emphasis?

What If?

The point, of course, is not for us—but for those who don’t have these issues on their mind every day. Because, even if we should be thinking about this every day of the year, special “events” like National Retirement Security Month give those of us who do a chance to, as a collective group of professionals, remind those who don’t of the importance of thoughtful preparations for retirement.

Better still, with the plan design improvements available today, you might only need one week—or one hour—of getting an individual—or group of individuals—to think about those messages.

Consider, for example, what if that period of focus got an individual (or, better still, a group of individuals) to enroll in their workplace retirement plan? What if it led an employer to embrace automatic enrollment, or, for those who are already enrolled, to increase the default contribution rate, or to reenroll those who have opted out of participation in the past? What if that focus prompted those who are already participating to increase their deferral rate (on their own), or to boost that rate so that they got the full benefit of the employer match? And what if that period of focus—or the actions above—led workers to stop and actually figure out how much they might need to save to sustain their retirement?

What if, indeed? 

- Nevin E. Adams, JD

Failure(s) to Communicate

There’s an oft-repeated line from that 1967 classic movie “Cool Hand Luke” about a “failure to communicate.”

Now, most of us aren’t trying to convey the consequences of violating prison rules, but there are messages where mere words sometimes fall short of their purpose. There are literal barriers in terms of language, of course—but all too often also barriers built of different life experiences, of cultural references, and certainly of age. Indeed, we frequently use words, or employ metaphors to enhance, or at least provide some flavor to our explanations/instructions—only to have it fall on ears that may hear the words, but lack—or in some cases, confuse—the necessary context (I’m routinely forced to reference the Urban Dictionary to make sure certain words haven’t taken on an unintended meaning).   

Mind ‘Set’

In that spirit, several years back I stumbled across something called the Beloit College Mindset List (a couple of years back it “moved” and was rebranded as the Marist Mindset List). It was a list developed to help college faculty be aware of dated references—to help assure better communications with the incoming class of college freshman. In fact, the focus of the list (and it dates back to 1998) was to provide some perspective on the shifting generational perspectives—the mindset, if you will—of individuals just entering college.

I remember fondly the “can you believe it?” water cooler chats about some of the items on previous lists—kids entering college that had never actually seen a floppy disk (which, ironically, lives on in that “save” icon in Microsoft applications), who might have wondered what “cc” actually stands for in their email (because they have never actually had to deal with a “carbon copy”), who never had to dial a rotary phone, who might never have seen (much less used) a payphone, who never knew a world without the “world wide web” (much less a world in which you could connect to it—wirelessly)—and perhaps most notably of late, weren’t even alive on 9/11. Yes, we’re talking about a generation who can’t fully appreciate just how weird it seems to see people having video calls on their wristwatches—just like Dick Tracy did in comics of old (talk about your dated references!).  

Class of 2027

But, according to this year’s Marist Mindset List,[1] the Class of 2027:

• Are just as likely to be listening to Led Zeppelin as Lana del Rey or Lil’ Baby on their phones (with access to music services like Pandora launched in 2005, the year many of these future graduates were born).
• Will get their news primarily from social media sites like YouTube, Instagram and TikTok (Dan Rather & Ted Koppel both retired in 2005, “effectively ending the reign of network news programs as the primary way younger Americans get their news”).
• Have always lived in a world visibly affected by climate change (harkening back to Hurricane Katrina and Rita—though they wouldn’t be old enough to remember either).
• Will almost exclusively watch their video content on YouTube (which launched in 2005) and similar sites online.
• Will be the first to fully integrate ChatGPT or “Generative Pre-trained Transformer” into their college learning experience (one can’t help but see “fully integrate” as a disarming euphemism for more insidious applications).
• Often quote the TV show “The Office,” although the program ended its run in 2013. The characters are omnipresent in today's college culture and the show is now a cultural phenomenon thanks to its rebirth via Netflix and short-form streaming services (OK—I don’t get the fixation on The Office, either. But who am I to question generational fixations?)
  

Retirement (Re)Set

That said, for those of us who will be working (or living) with the Class of 2027 (once they graduate, if not sooner), well, for them (and those working with them), it might be good to keep in mind:

• There have always been 401(k)s (even if everyone hasn’t had access to them at work).
• They may never have to actually sign up for their 401(k) (thanks to automatic enrollment).
• They may never have had to think about the investments in their 401(k) (due to QDIA/target-date fund defaults).
• There has always been a Roth option available to them, whether 401(k), 403(b) or IRA (and, considering what future tax rates are likely to be, they should take advantage).
• They’ve always been able to view and transfer their balances online and on a daily basis (and so, of course, they mostly won’t).
• They’ve always worried that Social Security wouldn’t be available to pay benefits. (In that, they’re much like their parents at their age…even today).

But perhaps most importantly, they’ll have the advantage of time, a full career to save and build, to save at higher rates, and to invest more efficiently and effectively—and, with luck, access to a trusted advisor to answer their questions along the way...

  - Nevin E. Adams, JD

---

[1] Sadly, this year’s list isn’t quite as much “fun” as previous lists have been (at least not to this Boomer)—and this year it comes with some political “commentary” that seems unnecessary (at least to this Boomer). The Marist crowd appears to take themselves more seriously than the Beloit College founders did (or perhaps it’s just the times we’re in).