Showing posts with label 403(b). Show all posts
Showing posts with label 403(b). Show all posts

Sunday, July 19, 2015

RFP Process for Bundled Service Provider


Nicholas Zaiko, CIMA®
Investment Consultant
Bridgebay Financial, Inc.

It is a good fiduciary practice to conduct a periodic review of the DC plan service provider to ensure that the participant assets are well-protected and tracked accurately.  This should include a review of financials and SSAE 16 (internal control audits) annually.  If the plan service provider has not been reviewed in a long period of time, or the plan has grown or changed dramatically in the number of participants, need for additional services and asset size, it is a good fiduciary practice to conduct a due diligence review which may best be performed through a request for proposal (RFP) for plan services. 

Define the Objectives of the RFP
The detail and customization of the RFP will be determined by the key objectives of the RFP.  Some typical reasons for sending out a RFP include:
  
1)   Benchmarking to compare the current provider's fees and services in response to ERISA 408(b)(2)
2)   Improving plan efficiency and delivery of services to the plan and its participants
3)   Streamlining the administration of the plan through improved technology and automation
4)   Expanding or enhancing the investment choices, advice, asset allocation solutions
5)   Improving participant communications, education and participation rates
6)   Seeking a change in provider's relationship team, response time and expertise

Establish Criteria
The plan sponsor should establish specific metrics to evaluate the providers to ensure that the key issues are addressed.  Any specific restrictions or contract stipulations that are non-starters should be identified at the onset.  When crafting the RFP, it is important for a plan sponsor to identify their organization's unique priorities, objectives and preferences.  Some criteria may include conversion timeline, minimum performance standards, fees, call center and on-line participant access, investment options and organizational flexibility.  A client service-oriented provider will be willing  and able to tailor its services to the plan sponsor's specific needs.

Plan Information
Make the responses specific and relevant to your plan by providing sufficient information and data about the plan features, asset mix, cash flows, employee demographics, and current investment line-up.  Include any new services desired and their importance to the overall decision.

Evaluate the RFP Responses
Quantitative criteria include sponsor and participant service measures, plan use data, fund performance, expenses and timing.  These tend to be easy to compare and understand, though they tell only a fraction of the provider’s full story.  Financial stability in the wake of the financial crisis is critical to continuously offering high quality plan services.  Financial strength ensures high quality personnel, up-to-date enhancements to systems and improvements in compliance and delivery of participant services.

The Committee should be clear on what aspects of the RFP are critical to the selection of a qualified service provider based on the criteria established prior to issuing the RFP.  Developing a scorecard is a helpful tool when evaluating RFP responses and will streamline the process.  The evaluation should be presented to the committee and finalists selected based on the results.

Education
Education should be accessible through multiple channels such as paper, webinar, in-person, on-demand information, and live representatives.  Call centers need qualified, expert representative that are responsive to participant requests.  There should be a broad menu of education media including user-friendly on-line tools, retirement calculators, retirement income education, publications, newsletters, investment information, on-demand educational tools and in-person seminars.  Beware of marketing material masquerading as investment education.

Compliance
Compliance expertise has taken a central role in this time of increased regulations. Providers should demonstrate specific cases where they provided solutions to plan sponsors to meet new regulatory requirements.  Strong providers will have updated technological tools, operational procedures and legal expertise that ensure the plan is compliant with the changing regulatory landscape.  Plan design recommendations from providers are also very useful in a rapidly evolving regulatory environment.  Plan sponsors should understand the provider's compliance resolution process and how proactive they are in ensuring the plan remains in compliance.

Finals Presentations
Once the finalists have been determined, they should be notified and sent an agenda for the presenters to follow.  The absence of a detailed agenda will allow the provider with the best showmanship, and not necessarily the best product, to win the business. The key client service and relationship personnel that will actually be handling the account on a day-to-day basis should be present at the finals presentation. The finalist in-person presentations should highlight the relationship services. Using a common agenda with each finalist will also make is easier to make truly apples-to-apples comparisons.  The way some firms answer certain questions may actually point out deficiencies in other firms.  A knowledgeable and experienced retirement plan consultant can highlight these differences and explain their implications on the plan sponsor's plan.

Sunday, May 17, 2015

Evaluating Plan Service Providers


Nicholas Zaiko, CIMA®
Investment Consultant
Bridgebay Financial, Inc.

Selecting a service provider for a 401(k), 403(b), or 457 retirement plan is one of the most crucial decisions that an employer and plan fiduciary can make in determining the retirement outcomes for its employees.  

The Department of Labor (DOL) has indicated that a plan sponsor has a fiduciary duty to establish and follow a formal review process at reasonable intervals, generally 3-5 years, to ensure the caliber of the selected provider. A client service focused organization will tailor its services to the plan sponsor's needs and have an understanding of the key requirements of the plan sponsor.

The process starts with the Request For Proposal (RFP) which should address the provider’s services, expertise, client commitment and compliance experience at a reasonable cost.  The RFP provides a strong foundation for selection but is not the only factor.  The in-person finalist presentations should highlight the relationship services.

Provider Selection Sub-Committee
It is good practice, in order to facilitate the service provider search, for the plan sponsor to establish a Selection Committee with a range of members with different areas of expertise such as payroll, employee benefits, legal, compliance, investments/finance and technology/systems.  Each member should be responsible for evaluating the provider’s abilities in their respective key areas. 

Use of an Outside Retirement Plan Expert
Many plan sponsors engage an outside consultant to guide and advise them through a methodical process that is well-documented and clearly illustrates the reasons for the decisions made.  The consultant's role is to guide the plan sponsor in establishing goals and objectives, success metrics, and targeting performance standards. The plan consultant can screen candidates, customize the RFP to the plan sponsors needs, conduct the provider search, analyze or score the results and lead the finalists’ presentations.

The RFP consultant will pre-screen candidates based on specific plan sponsor requirements or a set of minimal capabilities.  A retirement plan consultant may expedite the selection process by searching its database of service providers to identify those candidates that offer services that best fit the particular plan's needs.  

The consultant can guide plan sponsors through a large universe of competent service providers and qualify a few candidates that are a strong match for the plan sponsor and the participants.  Service providers have different target markets, service levels and areas of expertise.  The RFP consultant can differentiate among providers and permit the plan sponsor to select the service provider that best meets their specific requirements.

Preparation of the RFP questions is critical for efficiency and thoroughness to prevent receiving vague responses.  Certain questions may serve as differentiators.  The consultant's expertise in understanding the nuances of different levels of service, identifying potential conflicts of interest and understanding the benefits or limitations of certain providers can be extremely valuable to a plan sponsor.  A key benefit in using an expert is that the consultant can provide invaluable insights from having worked directly with the numerous providers under consideration.

One of the best ways for a consultant to present the results of their evaluations is to provide side-by-side analysis and a scoring system to enable the plan sponsor to identify and understand the finalists they would want to interview.  

Sunday, April 19, 2015

Service Provider Due Diligence


Nicholas Zaiko, CIMA®
Investment Consultant
Bridgebay Financial, Inc.

Selecting and effectively monitoring defined contribution plan service providers is an essential fiduciary duty of the plan sponsor which influences retirement outcomes for its employees.  The plan sponsor or Committee overseeing the defined contribution plan shares this responsibility for the prudent management of the plan for the benefit of the participants.

Fiduciary Reasons for Conducting a Provider RFP
In the ERISA Section 408(b)(2) fee disclosure rules, the Department of Labor (DOL) assumes that a prudent plan sponsor has a fiduciary duty to establish and follow a formal review process at reasonable intervals, generally three to five years, to ensure the caliber of the selected DC provider and that the services are being delivered at a "reasonable" cost.  Typically, a plan sponsor can conduct this due diligence review by issuing a service provider RFP.

Types of Service Providers
There are a full range of DC plan service providers that are either independent or affiliated with different types of institutions that include:  TPAs (third party administrators) or independent recordkeepers, mutual fund companies, insurance companies, banks, and brokerage firms.

Bundled or Open Architecture 
In order to properly operate a qualified DC plan, an array of services are necessary.  Those services include recordkeeping administration, trustee/custodian services, compliance testing, investments, legal update of plan documents, government reporting and participant education.  Bundled service providers offer the full spectrum of services necessary to operate a qualified plan under one contractual arrangement.  A bundled provider includes plan administration, recordkeeping, trustee, legal, investments, participant communication and education. Defined contribution plans, such as 401(k), 403(b) and 457, that are open architecture may use multiple service providers that perform each role.  In such a situation, the plan sponsor would issue RFPs for each of the various services.

Multi-Purpose RFP
A well-documented due diligence review enables plan sponsors to fulfill their fiduciary duty to prudently monitor their service plan providers.  A multi-purpose RFP covers the services of key providers necessary to operate a 401(k) or 403(b) retirement plan.  The design of the questionnaire is the first step in the evaluation process when benchmarking providers.

The process starts with the Request For Proposal (RFP) and should elicit information about the provider’s services, expertise, client commitment and compliance experience with clearly detailed costs.

Independent Benchmarking
The RFP process can be a benchmarking tool to assess the quality of the plan’s services, potential upgrades to the plan and serve as a resource to evaluate the reasonableness of plan fees.  Periodic, unbiased benchmarking documents the plan sponsor's fiduciary process to monitor the quality of plan services and fees.

Saturday, March 14, 2015

Education Policy Statement

Nicholas Zaiko, CIMA®
Investment Consultant
Bridgebay Financial, Inc.

Plan sponsors understand the importance of managing a well-designed retirement plan for their employees.  As deferral rates increase and automatic plan features help encourage savings in defined contribution plans it becomes increasingly important to have a financially literate workforce.  Education is a critical element in ensuring that employees have a good understanding of their benefits.  Employees place their trust in their employer to provide for their best interests.  Education designed to help the employer’s workforce achieve financial stability through retirement savings and sound financial practices is universally well received and appreciated by employees. 

As a plan sponsor, the decision to implement and maintain an education program for employees is integral to pursuing a prudent process and is just as important as selecting the investment options for the defined contribution plan.  Effective employee communication enhances the participants’ awareness of the retirement plan’s features and guides participants to create their own retirement savings portfolios and implement appropriate savings strategies.

Once a formalized education program has been established, participants tend to express greater confidence in their ability to save for their future.  A transparent and well-communicated retirement plan strategy engages participants and forges a partnership in the savings process. 

Education should be targeted to the level of understanding of the employees and participants in the plan.  There may be different levels of understanding, personal circumstances, savings rates and stages in life.  All of these differences may require multi-pronged education programs that address the participants’ unique needs.  Employee surveys and targeted communications are instrumental in optimizing the educational process to achieve positive results.

Education Policy Statement
Most plan sponsors provide a basic level of education for their participants.  Developing an Education Policy Statement documents the employer’s commitment to provide financial education to participants by establishing a framework for a well-structured and communicated program.    Crafting this document provides direction and procedural guidelines for key members of the plan sponsor staff to make decisions regarding the content and implementation of the education program.

The plan sponsor’s approach can be very paternalistic and highly protective of the employees’ best interest in providing for financial literacy and personal finance beyond the requirements of the retirement plan.  Some plan sponsors may play a more limited role that is specific to communicating the elements of the retirement plan to its participants. 

The objectives of the education plan may be to enhance employee engagement, encourage better savings, promote financial wellness and improve employee retention and loyalty.

Benefits of an Education Policy Statement
An Education Policy codifies the plan sponsor’s educational aspirations and documents their commitment to employee education by establishing goals and objectives that can be implemented and measured.  Feedback is typically very positive after the implementation of a well-directed, focused educational program for employees.  Many participants claim to feel more confident in making sound and informed decisions. 

A clearly articulated strategic education plan focuses important resources to optimize budgets and time. Policy statements help plan sponsors and fiduciaries define and document their ongoing efforts in designating resources to help participants understand their choices.  An added benefit for plan sponsors and fiduciaries is that the policy helps document a prudent process.

A well-developed policy identifies goals and highlights responsibilities for implementing, deploying, and measuring results.  Accountability increases the co-operation among different groups involved in providing education to meet the established goals.   

Features of an Education Policy Statement
A policy sets the overall direction of the program and establishes procedures for ongoing education, feedback and communications.  It addresses the overall objectives of the education program, establishes the plan sponsor’s philosophical approach and mission statement.  The purpose of the Education Policy should be to retain employees and enhance their loyalty by offering ongoing investment education.

The policy should define roles, responsibilities, and accountability for the program’s success.  Often this includes the plan sponsor, plan fiduciary advisor, recordkeeper, and education service provider. The roles and responsibilities throughout the planning process, implementation and monitoring the effectiveness of the education program should be outlined.

The due diligence process for the selection of third-party service providers can be identified as well as criteria for the selection of education service providers, potential conflicts of interest, and monitoring their effectiveness.  Criteria for education service providers should be set for the selection, evaluation and ongoing monitoring of educational results.

Setting metrics and milestones provide prudent guidance. The use of participant data and plan metrics can be used to monitor and evaluate success.  Timelines for measuring results, frequency and other general types of metrics can be valuable tools.

Conclusion
A financially educated workforce is another tool plan sponsors can use to encourage and cultivate success for both their retirement plan and their plan participants.  A structured and well-articulated education plan, documented by an Education Policy Statement, can serve to provide fiduciary protection, improve participant loyalty and foster successful savings habits.