3 (More) Pervasive Retirement Myths - an Academic Perspective

Last week I highlighted three “myths” about the retirement system that will not die — all the more distressing because they are perpetuated by retirement industry pundits. Here are three more that (mostly) aren’t perpetuated by those who actually work with retirement plans, but by academics.  Academics who, sadly, are often listened to, and cited by those who regulate and legislate these programs.

The Match Doesn’t Matter

This doubtless comes as a surprise to those of us who work with retirement plans and retirement plan participants. More precisely, there are a few studies out there that suggest that a matching contribution doesn’t have a very strong impact on participation. The study that is cited most often in support of this one is one conducted several years ago in conjunction with H&R Block, where individuals were offered a financial incentive to take their tax refund and deposit it in an IRA. Most didn’t — and thus the notion that the promise of the match doesn’t produce (much) in the way of participation.

Now, if you find yourself saying, “But that’s not really an analogous situation to 401(k) saving” — well, you wouldn’t be the only one to think so.

But even if it has only a modest impact on the decision to participate, the data clearly suggests that it has a big impact on the rate of savings — and on the savings accumulations itself.

You Can Plug the Leakage Problem by Limiting Loans

Preventing “leakage” has become a constant drumbeat of many in our industry, their passion fueled by estimates of the enormity of the problem that seem limited only by the imaginations of those clamoring to solve it. As recently as a week ago, I was at a conference where a respected researcher went so far as to suggest that we are losing as much as $1 in leakage for every $2 contributed into the system. I kid you not.

Now, the “out” for these wild exaggerations is that nobody knows for sure, and so — if you’re looking for them — you see those estimates footnoted with disclaimers like “author’s calculations.” Or sometimes they come right out and admit that it’s based on a “host of simplifying assumptions.”

Don’t get me wrong — “leakage” can be a threat to an individual’s retirement security. But when the nonpartisan Employee Benefit Research Institute (EBRI) looked into the matter in testimony provided to the ERISA Advisory Council last year, it was cashouts — not loans or hardship withdrawals (even including the impact of a six-month suspension of contributions) — that turned out to be approximately two-thirds of the leakage impact.

So, if you want to solve the real leakage problem, you might want to start by accurately assessing the size of the problem, rather than just making numbers up. And then you might look for ways to make it easier for folks to keep their savings in the system at job change.

And let’s not forget — locking people’s money up with no access until retirement may solve the leakage problem. But it could also lead to a reduction in the amount of money people save in the first place.

The 401(k)’s Tax Incentives Are ‘Upside Down’

One of the comments you hear from time to time is that the tax incentives for 401(k)s are “upside down” (or as it has been more colorfully described, “out of whack”) — that is, they go primarily to those at higher income levels, who perhaps don’t need the encouragement to save. And from a pure financial economics perspective, those who pay taxes at higher rates might reasonably be seen as receiving a greater benefit from the deferral of those taxes.

Indeed, if those “upside-down incentives” were the only forces at work, one might reasonably expect to find that the higher the individual’s salary, the higher the overall account balance would be, as a multiple of salary. However, drawing on the actual administrative data from the massive EBRI/ICI 401(k) database, and specifically focusing on workers in their 60s (broken down by tenure and salary), EBRI Research Director Jack VanDerhei has found that those ratios hold relatively steady. In fact, those ratios are relatively flat for salaries between $30,000 and $100,000, before dropping substantially for those with salaries in excess of $100,000.

In other words, while higher-income individuals have higher account balances, those balances are in rough proportion to their incomes. They are not “upside down.” Now this is the outcome — the balances — not just focused on the contributions, the amount(s) going in, which is what most of the criticism focuses on.

As retirement plan advisors are well aware, these programs are subject to a series of limits and nondiscrimination test requirements: the boundaries established by Code Sections 402(g) and 415(c), combined with the ADP and ACP nondiscrimination tests. Those plan constraints were, of course, specifically designed (and refined) over time to maintain a certain parity between highly compensated and non-highly compensated workers in the benefits available from these programs. The data suggest they are having exactly that impact.

More recently, the “fairness” of these incentives has been questioned since they “only” go to workers who are covered by workplace retirement plans (though, as I pointed out last week, those numbers are often distorted as well). A better solution might be to expand those covered by such plans, rather than to undermine the diligence of those who are saving.

You’re less likely to hear these statements in your earshot — they tend to show up in academic forums, and sometimes in legislative hearings — forums where “decorum” might suggest avoiding confrontation.

But this is not just an academic exercise. And no one is well served — even the often well meaning academics who are trying to help improve the current system — by perpetuating misunderstandings.

- Nevin E. Adams, JD

How Much Would You Pay?

Growing up, I remember late night television being broken up by commercials touting a series of interesting products, everything from a rod-and-reel contraption that would fit in your pocket to a special set of knives that would, apparently, slice through any substance in the known universe without ever being sharpened. But unlike the commercials that ran during prime time, having made the pitch, the announcer lead viewers through a series of additional product extensions, generally with the admonition, “but wait, there’s more…”

Even with all that buildup, as the commercial closed viewers were reminded of the features of the product, and then asked, “Now, how much would you pay?” as several possible prices were suggested, then crossed off before being informed of the actual price (“plus shipping and handling”). And then, to close the deal, viewers were frequently told that they could have a SECOND version of the product for the same price (“just pay shipping and handling”).

I’m happy to say that I considered buying more of those offerings than I actually bought (albeit somewhat embarrassed to admit to how many I HAVE purchased over the years). The lessons I learned early on were that the product never worked nearly as well at home as it did on television, that you almost never had a good use for the second “at no additional charge” copy, and that when you added up ALL the costs, you frequently found out a sizeable gap between what you thought you were paying, and the actual bill.

Earlier this year, as part of its 2014 budget proposal, the Obama administration included a cap on tax-deferred retirement savings that would limit the amounts that could be accumulated in specified retirement accounts―which covers most of the ERISA-qualified plan universe (401(a), 401(k), 403(b), certain 457(b), as well as individual retirement accounts (IRAs), and―to the surprise of many―defined benefit pension plan accruals, as well.

The proposal would limit the amount(s) accumulated in these accounts to that necessary to provide the maximum annuity permitted for a tax-qualified defined benefit plan under current law, currently an annual benefit of $205,000 payable in the form of a joint and 100 percent survivor benefit commencing at age 62. This, in turn, translates into a maximum permitted accumulation for an individual age 62 of approximately $3.4 million (a number that many of the initial media reports carried) at the interest rates prevailing when the proposal was released. And, certainly initially, most of the analysis of the proposal’s impact―including that from EBRI’s own unique and extensive databases―was focused on how many individuals had accumulated account balances in excess of that $3.4 million today.

But, taking a longer view, and using our proprietary Retirement Security Projection Model,® EBRI’s simulation results for 401(k) participants (assuming no defined benefit accruals and no job turnover) show that more than 1 in 10 current 401(k) participants are likely to hit the proposed cap sometime prior to age 65―even at today’s historically low discount rates. If you assume discount rates closer to historical averages, the percentage likely to be affected increases substantially.

As part of the analysis published in the August 2013 Issue Brief,¹ EBRI Research Director Jack VanDerhei also looked at the potential impact of the proposed cap based on two stylized, final-average defined benefit plans and a stylized cash balance plan, along with a number of different discount rate assumptions. As an example, assuming coverage by a defined benefit plan providing 2 percent, three-year, final-average pay benefits, with a subsidized early retirement at 62, and assuming an 8 percent discount rate, nearly a third are projected to be affected by the proposed limit.

VanDerhei also looked at the potential response of plan sponsors, specifically smaller 401(k) plans (those with less than 100 participants), whose owners might reconsider the relative advantages of continuing the plans, particularly in situations where that owner of the firm believes that the relative cost/value of offering the plan is significantly altered such that the benefit to the owner is reduced. Since these owners (and their personal circumstances) can’t be gleaned directly from the data, some assumptions had to be made. But, depending on plan size, the EBRI analysis indicates this could involve as few as 18 percent of the small firms (at a 4 percent discount rate) or as many as 75 percent of the small firms (at an 8 percent discount rate).

The administration’s budget proposal estimated that the retirement savings cap would generate an additional $9 billion in revenue. But the question―and one that the EBRI analysis helps policy makers answer, and for a wide range of possible outcomes―is “how much would it cost?”

Nevin E. Adams, JD

¹ See “The Impact of a Retirement Savings Account Cap,” online here.

“Upside” Potential

I once spent a very uncomfortable period of time stuck in one of those carnival rides that, for brief periods of time, spins riders in a circle as the cab you are in also twirls. As uncomfortable as the ride was, the “stuck” part came while my cab was high in the air—and turned upside down. In no time at all, it was obvious that this extended “upside down” state wasn’t contemplated by those who designed the seating compartment (nor, apparently, had they considered that my compartment “mate” would find it exciting to rock our stuck cab during our brief “internment”).

One of the comments you hear from time to time is that the tax incentives for 401(k)s are “upside down,” that they go primarily to those at higher income levels, those who perhaps don’t need the encouragement to save. And from a pure financial economics perspective, those who pay taxes at higher rates might reasonably be seen as receiving a greater benefit from the deferral of those taxes.
Indeed, if those “upside-down incentives” were the only forces at work, one might reasonably expect to find that the higher the individual’s salary, the higher the overall account balance would be, as a multiple of salary. However, drawing on the actual administrative data from the massive EBRI/ICI 401(k) database, and specifically focusing on workers in their 60s (broken down by tenure and salary), those ratios hold relatively steady. In fact, those ratios are relatively flat for salaries between $30,000 and $100,000, before dropping substantially for those with salaries in excess of $100,000.

In other words, while higher-income individuals have higher account balances, those balances are in rough proportion to their incomes—and not “upside down.”

(click to enlarge)

As those who work with these programs know, what keeps these potential disparities in check is the series of limits and nondiscrimination test requirements: the boundaries established by Internal Revenue Code Secs. 402(g) and 415(c), combined with ADP and ACP nondiscrimination tests. Those plan constraints were, of course, specifically designed (and refined) over time to do just that—to maintain a certain parity between highly compensated and non-highly compensated workers in the benefits available from these programs. The data suggest they are having exactly that impact.

And that’s why focusing only on the incentives—and not also on the limits—can leave you “stuck” with only part of the answer.

Nevin E. Adams, JD

"Missed" Behavior

As the nation continues to grapple with fiscal challenges, the subject of so-called “tax expenditures,” (the amount of tax breaks accorded various programs) has attracted a great deal of attention. Critics of the current tax preferences structure for work place retirement plans have questioned the efficacy of those preferences relative to the savings produced.

In that vein, a recent study¹ examined the experience of the Danish pension system to consider the relative impact of government retirement-savings tax preferences on savings behaviors, as well as the impacts on savings patterns of a mandate that required all Danish citizens to contribute 1 percent of their earnings to a retirement savings account from 1998 until 2003.

In explaining their rationale for drawing on the Danish pension experience, the study’s authors described that nation’s pension system as “broadly similar in structure” to that in the United States and other developed countries, in that it has individual accounts, employer-provided pensions, and a government-supported defined benefit (DB) retirement plan. However, while the components are similar, as a recent EBRI Notes article² points out, the Danish retirement system functions differently in several critical aspects.

The Danish Experience

Not surprisingly, the research on Danish workers noted a “sharp increase” in savings rates in 1998 (when the mandate took hold), and sharp reductions in total savings in 2004 (when the mandate lapsed). They also considered worker savings responses when, in 1999, the Danish government reduced the subsidy for contributing to capital pension accounts for individuals in the top income tax bracket, noting that while contributions fell sharply for individuals in the top bracket, they “remained virtually unchanged for individuals just below that bracket.” In other words, the individuals directly affected by changes in the incentives reacted, while those for whom the tax subsidy was unchanged did not.

They also found that the reduction in incentives also had a larger effect on Danish workers who make frequent changes to their pension contributions. In essence, Danish savers who were actively making decisions about their pension contributions were more likely to respond to the change in incentives than other individuals. This group the study authors classified as “active savers,” who, as it turns out, also have significantly higher wealth/income ratios and were more likely to be older than other Danish workers in the study.

Combining all these results, the authors arrive at two top-line conclusions about the saving behavior of Danish workers. First, that only 15 percent of those individuals are “active” savers, that only those active savers respond to tax incentive changes, and then largely only by reallocating savings between their tax-deferred pension accounts and taxable savings accounts. Second, for these active savers, a $1 of tax expenditure by the government on subsidies for retirement savings raises total savings by only about 1 cent, on average. Not surprisingly, these conclusions have drawn the attention of those who question the efficacy of the current retirement savings tax incentives in the U.S. But is this Danish experience relevant to the United States?

For the most part, the U.S. private sector relies on a voluntary retirement system—both on the part of workers to participate and save, and, significantly, on the part of employers to not only sponsor but also encourage participation with education, payroll deduction, and matching contributions. Furthermore, while U.S. employers sponsor these programs to attract and retain workers, they are encouraged to do so by certain tax preferences, conditional on administering the plan in accordance with various “nondiscrimination” standards. However, if the tax-deferred status of pension savings accounts were altered, previous surveys have shown these ties would almost certainly be weakened, if not entirely broken.³

Ultimately, the study of Danish worker savings behaviors was just that, and—as a study of individual savings behaviors in that environment—it has merit. It did not, however, consider the reaction of employers to these kind of changes. Those who would draw lessons from that experience should consider that the “success” of defined contribution work place retirement plans in the United States currently depends on the behavior of TWO parties: workers who voluntarily elect to defer compensation, and employers that choose to sponsor and, in many cases, contribute to them.

Nevin E. Adams, JD

¹ See Chetty, Raj, John N. Friedman, Soren Leth-Petersen, Torben Heien Nielsen, and Tore Olsen, “Active vs. Passive Decisions and Crowd-Out in Retirement Savings Accounts: Evidence from Denmark,” NBER Working Paper # 18565, November 2012, online here.

² See “Tax Preferences and Mandates: Is the Danish Savings Experience Applicable to the United States?”

³ A survey conducted on behalf of The Principal Financial Group in 2011 determined that if workers’ ability to deduct any amount of the 401(k) contribution from taxable income was eliminated, 65 percent of the plan sponsor respondents would have less desire to continue offering their 401(k) plan. A separate survey of plan sponsors by AllianceBernstein that same year found that small plan sponsors were more likely to respond negatively to a proposed change in the deductibility of contributions by employees than larger employers—the impact of the loss of access to plans, and to the matching contributions often associated with those plans, was documented in previous EBRI research. See “Modifying the Federal Tax Treatment of 401(k) Plan Contributions: Projected Impact on Participant Account Balances,” online here.