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Dan Solin

Dan Solin

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Your 401(k) Plan Could Be Illegal

Posted: 05/17/11 09:50 PM ET

401(k) plans are a great deal for employers. Their cost is subsidized by brokers and advisers, at the expense of the plan participants (employees), who are supposed to be the primary beneficiaries.

Let me give you a little primer on 401(k) plans. The plan sponsor (typically the employer) is a "fiduciary" to plan participants This means it is supposed to act in the best interest of those participants. Nice theory. The reality is quite different.

It is in the best interest of plan participants to have investment options in their plan that will generate the highest rates of return at the lowest cost. Based on reams of academic data, only index funds (including ETFs) meet this criteria. They are much lower cost than actively managed funds (where the fund manager attempts to beat the returns of a designated benchmark).

The majority of actively managed funds underperform their benchmark index over the long term. It is impossible to discern which of the outperforming actively managed funds will repeat their outperformance in the future. In fact, outperformance over most five year periods seems to be a positive indicator of underperformance in the ensuing period.

A 401(k) plan consisting only of a broad range of low management fee stock and bond index funds is in the best interest of plan participants. An even better option would be for the plan to offer broadly diversified portfolios of these funds for varying risk levels (from conservative to aggressive). Few employees have the ability to put together a risk adjusted portfolio in an appropriate asset allocation (the division of their portfolio between stocks bond and cash) on their own.

Few 401(k) plans offer these options. Indeed, as Ron Lieber discussed in a recent article in The New York Times, most 401(k) plans don't even offer a decent array of index funds. He notes that only 37 percent of plans offer index funds covering a broad domestic stock index, a broad international stock index and a broad domestic bond index. As I recommended in The Smartest Investment Book You'll Ever Read, with just these three funds, investors can put together a portfolio that has historically outperformed the returns of 95 percent of professionally managed money.

The reason for excluding index funds is simple. Index funds don't pay brokers, advisers or insurance companies a kickback (known as "revenue sharing payments") which are the price of admission to the plan's lineup of investment options. Lieber raises the issue of whether the absence of an array of index funds in 401(k) plans might violate the fiduciary duty of the plan sponsor. He concludes that no Court has directly addressed this issue, but encourages plan sponsors to take prompt remedial action before it is too late.

Lieber correctly notes that a Court is unlikely to conclude the absence of index funds is illegal. A combination of world class lawyers retained by the securities industry and recalcitrant judges, reluctant to roil a huge retirement plan system, is the perfect storm for plan participants.

Legalities aside, what about the moral and ethical issues? The present system subsidizes the cost for employers and eviscerates the savings of plan participants. Many forward thinking employers believe this is simply wrong. They are changing their plans and retaining advisers who fully disclose their fees, take no compensation from mutual fund families, and populate their plans with investment options that are really in the best interest of plan participants.

As Lieber notes, you are not powerless. Approach your plan administrator and insist your plan include a broad array of index funds. Even better, lobby for an all-indexed plan. When you approach retirement, you will reap the fruit of your efforts.


The views set forth in this blog are the opinions of the author alone and may not represent the views of any firm or entity with whom he is affiliated. The data, information, and content on this blog are for information, education, and non-commercial purposes only. Returns from index funds do not represent the performance of any investment advisory firm. The information on this blog does not involve the rendering of personalized investment advice and is limited to the dissemination of opinions on investing. No reader should construe these opinions as an offer of advisory services. Readers who require investment advice should retain the services of a competent investment professional. The information on this blog is not an offer to buy or sell, or a solicitation of any offer to buy or sell any securities or class of securities mentioned herein. Furthermore, the information on this blog should not be construed as an offer of advisory services. Please note that the author does not recommend specific securities nor is he responsible for comments made by persons posting on this blog.

 
 
 

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08:57 PM on 05/20/2011
One more point...while low expenses are important, it's probably the 3rd or 4th most important issue regarding getting the most from your 401k plan. In addition to maximizing the employee match if one is offered, the second is to maximize the tax savings by using the pre-tax option. This is like a "super IRA" Of course many plans offer a Roth option. This is another wonderful opportunity.

But maybe one of the most important issues is proper asset allocation. Too many folks just don't understand the risk and reward profiles of the various investment options and how to maximize your risk adjusted returns. I've seen particpants invest 100% of their contributions in company stock. Sometimes it works out, but other times it ends in tears. Others will only buy a "guaranteed" or fixed investment and often this will not return enough to build your assets over time.

One more issue is the lack of true diversification options. I've seen many plans that offer 3 or 4 different funds buying the same stocks. This isn't diversification! Rarely do 401k's offer an option of commodities like energy, precious metals and agricultural products. These have been important diversifiers during the current commodity inflation cycle.
08:45 PM on 05/20/2011
Your 401(k) Plan Could Be Illegal ? What does the article have to do with legality of a 401k?

I agree that 401k participants should be given the choice of low cost index funds, but there are larger issues with most plans, and how participants manage their funds.

The 401k is the most powerful savings tool offered to many employees. In the instance where the company matches a part of your contributions, it's a home run.

When I first started working after college, I made it my business to put the maximum 8% pre-tax and 8% after tax into my plan. My employer put in 4% which was the maximum, their formula was a 100% match for your first 4% pre-tax contribution.

Believe it or not, some employees didn't participate to get the 4% match. I made it my mission to make sure all my colleagues would at least put in 4% so they got their 4% "bonus." One staffer said she couldn't afford it, so I encouraged her to put in 1%. After a couple of pay periods she admitted she didn't even miss the money. A couple of month later, I convinced her to move it to 2% of pay. Then I told her to bump it each time she got a salary increase so you wouldn't miss it.

A year later she ran up to me and was so excited she had accumulated nearly $5,000 in her plan. She exclaimed she never had any savings.
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Mamma Roma
Contrarian and proud of it
09:51 PM on 05/19/2011
A couple of years ago. PBS did an expose called "Credit Card Nation", in addition, it featured the genleman who figured out that by using the IRS CODE 401k, ( that's the only government connection) it could generate a new class of investors, while shifting the pension burden.

Trouble was, employers started raiding these accounts and this man (his name escapes me) did a complete turn around on his view and condemned them.

We refused to participate, and are glad we didn't when we discovered my husbands employer had no intention of matching funds.

I will dig up the information and link it.
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Alicia Westberry
college student & blogger
06:03 PM on 05/19/2011
Nothing in this blog indicates any illegalities. Morally & ethically wrong doesn't equate illegal.
10:28 AM on 05/20/2011
With the New Department of Labor 408(b)2 regulations becoming effective on January 1, 2012, it will come to the point of being illegal. To knowingly ignore excessive fees, revenue sharing, and kickbacks will soon be a thing of the past and if you are a plan sponsor who doesn't take the initiative to ensure your plan is paying"reasonable fees for reasonable services" you will be held accountable. ING has a lawsuits against them for not disclosing kickbacks and revenue sharing to one of their 401k plans. Many other firms have suits pending as well. This is just the beginning.
05:28 PM on 05/19/2011
I wanted to share our firm's experience over the past several years converting our 401(k) clients to all passively managed funds. We construct seven diversified portfolios having different risk and return characteristics, using funds from DFA and Vanguard.

We lost roughly 1/4 of our client base, most of whom could not believe that low cost passive funds have and will outperform most active managers. The remaining clients who stayed with us were all a bit cautious at first, but now they are completely happy. We even had one of our clients forward the Ron Lieber article to us, I had missed it.

We believe that it is legally indefensible to not offer passively managed funds. At some point in time, aggrieved participants will be looking for restitution.
10:43 AM on 05/20/2011
My firm uses DFA funds as well. I'm sure the 1/4 that you lost, truly didn't realize what it was you were accomplishing for them. Out of 300,000 advisors nationwide, only about one half of one percent can offer DFA funds to their individual clients; an elite group indeed considering DFA’s international presence. Active manager generates higher turnover, transaction costs and taxes due to speculative trading. Index managers actually accept high transaction costs and turnover in favor of tracking. Alternatively, Dimensional Funds minimize costs and enhance returns through portfolio design and trading. I also think you are correct in mentioning that participants who are displeased will take action. It's already starting just based on the number of lawsuits that have been in the news recently regarding 401k plans.
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CPAwADD
My super power is sarcasm!
02:58 PM on 05/19/2011
The requirements to actually act as a fiduciary are fairly stringent. The point that they are not being seriously followed is a valid one. Unless this requirements are enforced nothing will change.
09:36 AM on 05/19/2011
I completely agree with this article. It's no wonder that 401k lawsuits have increased 23% year over year for the past 3 years. Just look at firms such as Caterpillar, Edison International, and more recently Kraft Foods and Bechtel Corp that have had plan participants bring lawsuits against them for excessive fees and breach of fiduciary duties. Many business owners and plan sponsors choose to do nothing because they trust their existing service providers, they don't realize the ramifications of new DOL regulations, and unfortunately they don't want to put in the effort. Hidden fees caused by a lackluster investment menu can cut into a plan participants retirement balance by up to 50%. Plan sponsors, business owners, trustees, etc have to be more proactive in ensuring they are providing the best possible plan with reasonable fees. Get a second opinion on your plan through an independent, unbiased third party; my firm, CJM Fiscal Management, does this for free. Also, see how your plan is benchmarked and compares to your peers and begin to question your existing service providers. The answers to your questions may shock you!
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mansterEZ
searching for secular humanist fact-based truth
06:56 PM on 05/18/2011
Most employees see ANY retirement plan as an employer giveaway benefit so it's a win win. Your post is absolutely correct and requires the employee to do absolutely nothing except stay employed in order to benefit. Knowing all the fine points probably will not change most minds because employees want to trust their employers are actually looking out for their best interests. Employers depend on their workers to remain purposefully ignorant so that the company can remain profitable and employees just want the business to thrive so they can have a job. If the owners or board members get rich in the process is okay as long as employees receive reasonable compensation and are able to live comfortably. Just because it might be illegal doesn't mean much if no one ever goes to jail over the practice. Such is the existent sad state of today's America.
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OSCPJ
Want it? Work 4 it. No 1 has ever drown in sweat.
05:33 PM on 05/18/2011
The author forgot one little thing to mention.

THEY ARE OPTIONAL.  IF YOU CHOOSE TO PARTICIPATE YOU FOLLOW THE RULES.  YOU ARE NOT FORCED TO DO THIS.
05:58 PM on 05/18/2011
It doesn't matter if 401ks are optional or not.

http://www.law.upenn.edu/bll/archives/ulc/fnact99/1990s/upia94.pdf
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OSCPJ
Want it? Work 4 it. No 1 has ever drown in sweat.
06:14 PM on 05/18/2011
I read your article.  Did you?  The National Conf of Commisioners, 4 unelected officials with no power. 

Here's a good summary.

http://en.wikipedia.org/wiki/Uniform_Prudent_Investor_Act

Not one mention of what is illegal?

BLUF, what exactly is your claim that 401k are illegal?
06:20 PM on 05/18/2011
There is plenty of case law on the prudent investor laws. But this is from the link....

'SECTION 7. INVESTMENT COSTS. In investing and managing trust
assets, a trustee may only incur costs that are appropriate and reasonable in relation
to the assets, the purposes of the trust, and the skills of the trustee.'
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OSCPJ
Want it? Work 4 it. No 1 has ever drown in sweat.
07:50 PM on 05/18/2011
This was approved by the states.  Not the same in all states. 

Most Investment companies are located in NY, some in DE.  Most workers work in one of the 50 states.  The HQ of the companies, one of the fifty. 

It doesn't matter what the states want.  Its a Federal matter.  And their is no precedent to speek of.
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Trublulu
03:58 PM on 05/18/2011
Soon public sector employees will only have the option of purchasing retirement funds similar to the 401k. Instead of a defined pension (that private sector employees once enjoyed), they will have to contribute to the Wall Street ponzie scheme but the public sector will not have any contributions from their employer. So, they will lose all the way around: low pay, reduced benefits, and a non-existent pension plan). This should make Wall Street/Republicans very happy. But, my question is, when pensions, pay, benefits, etc. are reduced or eliminated for everyone except the super rich, who is going to be able to pay for all the cheap goods from Asia?
QuantProgrammer
Cap welfare benefits at two kids.
12:18 PM on 05/18/2011
These are all good points, but the fact is that if you are gettting a vested employer match, it makes a great deal of sense to still take advantage of that. If your 401(k) plan has an extra 2% in expenses, it would take 50 years to wipe out a 100% employer match.

One thing that went practically unmentioned in this article is a simple and obvious solution for 401K plan participants- pick up the phone and call HR. Get your coworkers to lobby them. They normally want to help the employees out on this stuff, and they are usually the folks in charge of deciding which company you go with and which funds you have available. Fidelity is pretty darned cost-effective as a servicer, and if you go with their index mutual funds, you can get the costs down to less than 1%/year.

But Mr. Solin is right in that if you do not get a company match and intend to stay with your employer for a long time, at the very least, make your Roth contribution in your own IRA first.
01:02 PM on 05/18/2011
Agree. The only thing that makes 401ks valuable is the company match. Beyond that go IRA.
01:53 PM on 05/18/2011
While I agree with the match aprt...I've actually done pretty well (IMO) with what my company offers...+17% last year/+12% previous year/-16%-2008/~+10% before.

I'm not complaining considering I don't know "jack" about it. But I do work for a larger multi-national company and I do readjust my picks at the start of each year.
01:16 PM on 05/19/2011
a second thing that makes them valuable is that an employee can usually also contribute more to a 401K on a pre-tax level than they can to an IRA..
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spriddler
01:12 PM on 05/18/2011
Great advice
12:05 PM on 05/18/2011
Why do we have 401ks anyway? Another convoluted government program, which will gyrate with controversy from now on.

Let people keep what they've earned ... and not tax them to their last cent. Even the "evil" employer (gasp!). Get the government out of "managing" peoples' money. Government's in charge of the military, court system, stuff like that.
01:03 PM on 05/18/2011
401k is just more social engineering by the nanny staters in government. If the benefit is there you might as well take it. But we would be much better off if the government left us alone in our personal lives.
04:03 PM on 05/18/2011
Right, kinda like it was in the good old days. Check in with us when you're 75.
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BBackSoon
Hello, I must be going.
06:04 PM on 05/18/2011
You sure about that? I thought it was a cheaper way for employers to offer a retirement package. No more Pension funds.
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IndyStacey
When I do good, I feel good.
01:31 PM on 05/18/2011
401ks are not a government program. They are offered by employers and employees can choose to participate or not.
Linda from Deerfield
Paying attention
10:59 AM on 05/18/2011
I can't help but notice how many people speak of the 401k as if it is by definition a scheme to force investment in the stock market, be it via index funds or otherwise, without any realization that it doesn't have to be that way.

In my own experience, it was only a couple of decades or less ago that employees approached our Fortune 500 employer's plan administrator to complain that the 401k offered no alternative to stock and bond funds -- like a money market or simply cash -- that could even be used as a holding area from selling in anticipation of moving the 401k or retiring with a reduced risk profile, not to mention to minimize losses. It was unconscionable, really, and randomly punished those whose life events happened to coincide with a down market. Fortunately the administrator did add a safe cash-like alternative to the mix. It is definitely worth it to get these situations addressed.
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CTDFalconer
Think twice, post once.
03:01 PM on 05/18/2011
You're quite right in that employee-investors should be able to have the flexibility they need. One's retirement timing shouldn't have to based on the swings of the market.
HUFFPOST SUPER USER
live by the golden rule
10:59 AM on 05/18/2011
I have a different problem with 401Ks.

I worked for a good company, which treated employees and the environment well. I repeatedly lobbied for them to include socially responsible funds in the 401K options, explaining that by not doing so they were forcing their employees to invest in companies that failed to meet their own high standards. They kept saying that "Fidelity doesn't offer socially screened funds" and so they did not include them in our choices. Even when socially screened funds are offered, they usually are limited to one or two offerings. My own feeling is that the responsible funds should be the default options. One or two funds could be available for people who say, well, I don't care how much land I destroy or people I hurt, I just want the highest return possible, but for the rest of us there should be a wide range of responsible choices.
01:07 PM on 05/18/2011
'My own feeling is that the responsibl­e funds should be the default options.'

The plan providers would be breaking their fiduciary responsibilities with respect to diversification.
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humanbeing-rick
Born in the USA 1947
10:27 AM on 05/18/2011
I am an early baby boomer facing retirement after 4 decades as a engineering professional for major American corporations, and I contributed as I was advised to the 401K plans that replaced their pension plans. I got screwed as a faithful participant, and have lost more than half of it's value over recent years - and it is infuriating that it went into the pockets of unscrupulous young upstarts on Wall Street. My Dad had a great retirement, full retirement covered everything. I got a small fraction in comparison to what my Dad received, for similar careers and positions.
This proves that our American way of life has been hijacked by the wealthy and the white collar criminals the enable them!!!
10:41 AM on 05/18/2011
The Gov't has their hand in this too. They have designed a retirement system that puts people at risk and they reap the rewards. You get a little tax delayment benefit today so you can pay more taxes in the future. They dictate the amount you can save for retirement and the terms on which you withdrawal your money.
11:28 AM on 05/18/2011
Because there is no risk in Defined Benefit plans.
04:06 PM on 05/18/2011
You won't have to look far to find Republicans.