The True ‘Cost’ of ‘The True Cost of Forgotten 401(k) Accounts’

An update of a so-called “study” has been making the rounds—again—and its authors have doubled-down (and then some) on the assumptions in an updated version.

I’m referring to something called “The True Cost of Forgotten 401(k) Accounts (2023)”—an update to a report circulated about a year ago of the same title (sans the “2023” qualifier) by a firm called Capitalize. The first report claimed that there was $1.35 trillion in “forgotten” 401(k) accounts—the latest iteration has upped that number to $1.65 trillion.

That’s right, $1.65 TRILLION.

Not that the report’s authors make it hard to be incredulous about their results. Their executive summary claims that a full 25%—that’s a full QUARTER—of all 401(k) plan assets are, by their definition, “forgotten.” And if you’ve ever “left behind” a 401(k) account at a previous employer—well, apparently you’ve “forgotten” that account by their definition.  

Now if that definition of “forgotten” winds up being more credible than the one hinted at a year ago—the notion that these balances were truly lost, a.k.a. the “orphan” accounts that individuals truly have lost track of—a category that the Employee Benefit Research Institute (EBRI) has estimated[i] at $1.5 trillion OVER A 40-YEAR TIME PERIOD—well, the underlying assumptions—not to mention the mathematical extrapolations based on those underlying assumptions—are not. 

The authors mostly took the baseline they conjured up a year ago (see “Compounding the Problem(s))—this includes some assumptions not only about the rationale for the decision[ii] to leave the account where it is, but an alleged fee differential between IRAs and 401(k)s (they claim IRAs are less expensive), make a swag assumption about the average size of those accounts, and cut that alchemy in half (to be “conservative”). The new version builds on that shaky foundation by applying some assumptions about job turnover from the Great Resignation—and, no surprise, job turnover (apparently) means (even) more 401(k) accounts “left behind.”

The Assumptions

At a high level, they assume: 40% of workers cash out[iii] their 401(k) (with no apparent allowance for account balance), say they used IRS data on rollovers to determine rollovers, assume 2-3 million workers rollover their 401(k) (based on GAO data that said 401(k) to 401(k) rollovers account for 10-15% of total rollovers, and “impute” (their word) the number of “newly forgotten 401(k)s based on the difference between the total number of 401(k) accounts tied to job-changers and those who cash out, roll over to IRAs, or roll over into 401(k)s.” Bearing in mind that they will then take the number of accounts, and multiply THAT by the average account balances they derived earlier. 

Now, that might explain why they wind up with a number that represents a jaw-dropping quarter of 401(k) balances allegedly “forgotten”—but fails to explain why any credence should be put on that derivation. It is, quite simply, math that takes questionable assumptions, pulls a number out of the middle of those, and multiplies it by other questionable assumptions, producing a large number that is then said to be drawn from credible sources. But even credible sources are quickly waylaid by bad assumptions concocted from some kind of unarticulated triangulation.

Yet another example is the $115 BILLION they say is the “potential collective opportunity cost” from these accounts left behind—the result, they claim, “as a result of poor allocation and above average fees these accounts could experience.” To get to that number, they take the number of accounts they’ve conjectured (29.2 million in 2023) and then multiplied THAT “by the foregone savings one of these accounts would experience in a single year based on our scenario analysis (~$3,900).” “One of those accounts” being that $55,000 average they started with. I kid you not.   

The Motivation?

That said, this time around, the motivations behind the report from Capitalize are to my eye more obvious than they were a year ago. Their assertions are primarily that these balances left behind are paying fees in excess of what they might—presumably in the warm embrace of firms such as firms like Capitalize that offer a rollover solution. This time the report wastes no time highlighting the potential issues with leaving your 401(k) balances “behind”; that it becomes harder to track fees, allocate funds, and that your fees may be larger if you leave it with the plan of a smaller employer. They even invoke the notion that “unlike retail accounts” you may have limited choice with regard to fees “or other preferences.”

Honestly, I have tried to ignore this aberration. The number is nonsensical on its face, even with the most liberal definition of “forgotten.” But, it’s August—a slow news month—and journalists scrambling for a catchy lead apparently just can’t resist the opportunity. More distressing (at least to me) is the number of ostensibly well-meaning industry professionals who (continue to) share links to the uncritical coverage of this report.   

Interestingly enough, the dictionary defines “capitalize” as “to take the chance to gain advantage from.” 

Hmmmm….

- Nevin E. Adams, JD

 

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[i] As a stand-alone policy initiative, EBRI has projected that the present value of additional accumulations over 40 years resulting from “partial” auto portability (participant balances less than $5,000 adjusted for inflation) would be $1.50 trillion, and the value would be $1.99 trillion under “full” auto portability (all participant balances). Under partial auto portability, those currently age 25–34 are projected to have an additional $659 billion, increasing to $847 billion for full auto portability. But that picks up all potential rollovers, and they certainly aren’t “forgotten.”

[ii] Full disclosure—the author CONSCIOUSLY left behind every single one of his 401(k) accounts until recently. For account balances above $5,000 it was the easiest thing to do (e.g., “nothing”), for some of them it was a matter of appreciating the institutional pricing and/or options available there versus the new 401(k), and for at least one it was simply the aggravation involved in trying to get the funds from the old 401(k) mailed to me in a check. I’m happy to say that the process has improved somewhat over the years, though all three prior providers insisted on mailing me a hardcopy check (two, where Roth balances were involved). Oh, and I never “forgot” a single one.  

[iii] Don’t get me wrong; “leakage” is a real concern, and rollovers, for the most part, remain a tedious process for your average participant. Too many smaller (and perhaps some larger) balances do, in fact, get lost or overlooked, and “attribution” via escheatment or force outs does occur.

Could Employer Contributions Actually Lead to Leakage?

I recently stumbled across an academic study that claimed to find a correlation between higher employer contribution rates and leakage.

I will confess to a certain skepticism at that finding. There are, after all, a well-established series of things that contribute to leakage, broadly defined as distribution of retirement savings prior to retirement – but employer matching contributions – and certainly more generous matching contributions – have never been on that list.

The study – innocuously titled “Cashing Out Retirement Savings at Job Separation” – spends most of its 20-odd pages talking about leakage, its impacts on retirement security, and some possible solutions.  That said, one needs read no further than the abstract of this paper to find its surprising conclusion regarding one such underlying cause; its authors “estimate that a 50% increase in employer/employee match rate increases leakage probability by 6.3% at job termination.” More specifically, “The higher the proportion of one’s 401(k) balance contributed by the employer, the more likely employees are to cash out, holding constant balance and covariates.”

Proportion ‘Ate?’

That latter part is significant, since we know that participants with lower balances are more likely to have their balances distributed at job separation (so-called “force-outs” being typical at $1,000 or less). In fact, the paper acknowledges that “A higher balance discourages leakage holding all else constant.” Even so, a 6.3% increased probability might be “statistically significant,” but it most assuredly isn’t significant in economic terms. But to see any kind of connection between a more generous employer match and leakage just seemed – unusual. Particularly since – and as the study’s authors acknowledge – “Employers with more generous matches care about their employees’ well-being in retirement, but unintentionally nudge employees to cash out when they change jobs.”

The research cites a relatively robust sample (162,360 employees terminating from 28 retirement plans form 2014-2016 from a recordkeeper “that covers 15% of the U.S. workforce”), from a variety of industries. They acknowledge that the cash-out percentage (41.4% of employees cashing out at job separation) in this sampling is “strikingly high,” although in this group[i] – though interestingly “only 27.4% of terminating employees ever carried a loan, and only 3% of those defaulted.” The latter data point stands out because previous studies have found that outstanding loans defaulted at job separation are a significant cause of leakage. And – while averages are notoriously unreliable datapoints, the terminating participants in this sample had an average account balance of $46,556.[ii]

Reasons Able?

Of course, these researchers were looking for a connection between employer contributions and leakage – and, having found one – held out four possible rationales for that connection. First, they considered a scenario where workers, cognizant of the higher match actively planned to “leak” – basically “over-saving” to obtain the match, cutting into the income they actually needed for current expenses, and then needing the leakage to fill that hole. Secondly, they opined that a higher employer contribution rate during employment might engender a higher level of job security, and a correspondingly higher spending rate by the worker – that, upon termination, might then need to be funded by higher rate of withdrawal/leakage. Thirdly, they thought that workers might retain a sense of mental accounting that compartmentalized the employer match as “free” money, rather than sums set aside specifically for retirement (though the leakage impacted more than that account). Finally – and this is the rationale they landed upon to explain this “account composition” effect – that individuals who contributed a smaller proportion of their 401(k) balance (relative to the match) may be prone to think of their accounts at job separation as a readily spendable pile of cash (less so if one contributed more).

All of this felt to me like they were trying (too hard?) to rationalize behavior that wasn’t “rational.” That said, the researchers nonetheless conclude that “exiting one’s firm and being told that a sum is available can transform a perceptually illiquid source of long-term retirement security into a psychologically liquid pile of cash. Terminating employees spend the money when, arguably even for the minority of employees involuntarily terminated, there are good options of reducing household spending, adding gig forms of employment, or leveraging home equity lines of credit to supplement unemployment benefits until back in the workforce.”

Ultimately, it was impossible to really get inside the numbers and assumptions presented to ascertain how much of this conclusion was data-based versus “extrapolation.” The contributions labeled as matching looked to be more than just standard matching, perhaps including QNECs or safe harbor contributions as well, but there wasn’t enough detail in the paper’s tables to confirm that. As noted above, the withdrawal rates were high, and the “average” account balance presented clearly covered a wide variety of possibilities. And let’s not forget that, even with those considerations, the additional rate of leakage attributed to these generous employer contributions was pretty small.

There is, however, at least one conclusion worth drawing from this – and that’s that if the worker considers these accounts “free” money – and goodness knows, the employer match has long been positioned as such – they might well not realize the price they will pay, both at the point of distribution (taxes and penalties) – and ultimately at retirement – for spending those retirement savings…now.

- Nevin E. Adams, JD  

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[i] Another aspect of this group that struck me as odd – only about two-thirds of this group took a one-time total cashout, whereas another 21% depleted their 401(k)balances in two or more withdrawals within eight months.  One would normally expect traditional leakage patterns to be tied to a single withdrawal, rather than a series.

[ii] With an understandably large standard deviation of more than $97,000 – I say understandably because individuals with that size account balance tend to stay with the plan (an easy default) or rollover to an IRA or other plan). As the authors acknowledge, “A higher balance discourages leakage holding all else constant.”