Showing posts with label Roth. Show all posts
Showing posts with label Roth. Show all posts

Friday, March 2, 2018

401(k) Plan Survey 2018 from PSCA Summary


Nicholas Zaiko, CIMA
Senior Consultant
Bridgebay Financial, Inc.
www.bridgebay.com
The Plan Sponsor Council of America’s 60th Annual Survey of Profit Sharing and 401(k) Plans released on February 12, 2018 highlighted some interesting developments in the defined contribution market.  The survey consists of responses from 590 plan sponsors that offer defined contribution plans to their employees.    

Plan Fiduciary Advisors
The use of independent, fiduciary advisors has grown with 69.5% of plan sponsors stating that they retain independent advisors that are separate from their recordkeeper.  Nearly 36% use an ERISA 3(21) fiduciary advisor that has non-discretionary authority, providing advice to the plan sponsor with the employer making the final decision.  About 20% use an ERISA 3(38) fiduciary advisor that has full discretionary authority to select, monitor and make investment decisions.  The remaining respondents were not sure if their advisor was a co-fiduciary.

Investment Policy
Investment policy statements are in place for 87.6% of defined contribution plans.  Plan monitoring is conducted quarterly for 61.4% of plans with 19.6% of plans, mostly small plans, conducting annual reviews. 

Automatic Enrollment
Automatic enrollment is now offered by 59.7% of plan sponsors including large and small employers.  This plan feature is most common in plans with over 5,000 participants with 70% of those plans offering automatic enrollment.  Plan sponsors have been increasing the default deferral rates so that over 59.7% of plan sponsors now automatically enroll participants at over 3% of salary.  One-third of plan sponsors are defaulting participants at 3% of salary. Target date funds are used as the QDIA or default option by 63.7% of plan sponsors surveyed.

Deferral Rates
The most frequently used default deferral rate for automatic enrollment has been 3% of pay since the Pension Protection Act.  Plan sponsors are gradually transitioning to higher default deferral rates to improve savings.  More plans are now auto enrolling participants at rates more than 3% of pay with 35.2% of plans using a 6% default rate, and 40.2% using more than 6% default rate.

Auto Escalate Deferrals
Three-quarters of plans auto escalate by 1% each year, while 8.6% auto escalate by 2% and 5% auto escalate by 3%.  Plans that cap auto increases at 10% represent 41.8% of plans, while 19.4% cap it at more than 10%.

Automatic increase of default deferral rates has become widely accepted with 73.4% of plans increasing deferral rates over time.  About 33% of respondents increase the default deferral rate for all participants, 12% auto escalate deferral rates for participants that are “under contributing”. Another third of plans require the participant’s election to auto increase. 

Suggested Savings Rates
Plan sponsors that provide a suggested savings rate to participants represent 28.4% of sponsors surveyed.  The most often savings rate suggested was 6% of pay.  Some plan sponsors, 17.5% stated that they suggested savings rates higher than 10%.

Roth Contributions
The Roth contributions (after-tax) have become more readily offered as an option for participants with 63.1% of plans now offering the Roth 401(k) option in addition to the traditional 401(k) plan. 

Employer Contributions
Employer contributions have increased since the financial crisis to an average of 4.8% of participants’ pay. 

QDIA
After the Pension Protection Act most plans, nearly 70%, use a qualified default investment alternative (QDIA). The most popular QDIA is target date funds. 

The target date funds are offered by 73% of the plans surveyed of which 63.7% of plans use target dates as the QDIA or default investment option.  Plan assets in target date funds represent 22.2% of plan assets.  Of the plans using target date funds, 86.4% of the plans use off-the-shelf target date funds. Larger plans with 5,000+ participants often used customized target date funds. Actively managed target date funds represent 59.6% of the target date funds used while 40.4% use index or passively managed funds.

Investment Options and Allocations
Plans offer an average of 19 funds, a number that has remained steady since 2011. The funds most commonly offered are indexed domestic equity funds (87.3% of plans), actively managed domestic equity funds (85.3% of plans), actively managed international equity funds (83.7% of plans), and actively managed domestic bond funds (78.8% of plans). 

Managed accounts or professionally managed assets are offered by 40% of plans sponsors with the majority of plans with 5,000 participants.  In-plan annuities were offered to participants in 10% of the plans surveyed. 

The highest concentration of participants’ assets were actively managed domestic equity funds (22.9%), target date funds (22.2%), indexed domestic equity funds (13.5%), stable value funds (8.1%), and balance funds (4.3%) of plan assets.

Participant Education
The most frequent reasons given by plan sponsors for providing participant education are to:  

  • Increase participation (71.4%)
  • Improve appreciation for the plan (65.8%)
  • Increase savings and deferrals (62.7%)

Plan sponsors use a variety of approaches to educate their participants including the following:

  • Email (64.1%)
  • Seminars/workshops (55.3%)
  • Enrollment kits (46.4%)
  • Internet/intranet (42.7%)
  • Fund performance sheets (30.9%)

Participant Investment Advice
About 35% of plan sponsors offer their participants investment advice using third party advisors.  Approximately 25% of participants use the investment advice service when it is offered by plan sponsors. Of the advice providers, 30.8% are registered investment advisors (RIA), 28.8% are certified financial planners (CFP), and 20.2% are on-line or web-based providers. 

The most frequently used methods for providing advice are one-on-one counseling (68.5%), on-line advice (45.7%) and telephone representatives (48.7%).

Eligibility
Employers responded that over 90% of employees are eligible to participate in their defined contribution plans. About 65% of employers permit part-time employees to participate in the plan. Immediate eligibility is offered by 58.8% of employers surveyed. That means that employees can begin to participate in the plan as soon as they are hired.  Of employers that provide a matching contribution, 47% provide immediate eligibility to receive the match. Another 31.9% of plans that make non-matching contributions provide immediate eligibility to participants. 

The average percentage of eligible employees who have a balance in their plan is 88.7%. The average salary deferral for both 401(k) and Roth contributions for all eligible participants was 6.8%.

Loans
Most plans (88.9%) allow participants to borrow against their account balances.  Almost 25% of plan participants have loans against their balances. Plans that limit the number of loans outstanding to one loan at a time represent 55.1% of plans while two loans permitted are 36.3% of plans.  

Fees
The survey found that plan recordkeeping and investment fees are generally paid by the plan.  However, other plan expenses such as legal, audits, consulting, and education are paid by the company rather than the plan.  Asset-based fees for recordkeeping and administration are paid by 43% of plans while 34.4% of plans pay a per capita or flat fee per participant.  Over 50% of plan sponsors conduct an annual review of fees while 30.3% review fees more often.   





Saturday, December 20, 2014

Plan Design: In-Plan Roth Conversion


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

The In-Plan Roth Conversion provision is a plan feature introduced by the American Taxpayer Relief Act (ATRA) in January, 2013 that permits participants to convert pre-tax balances that are vested to after-tax Roth balances within the plan.  Expanding in-plan Roth contributions may prove to be a powerful tool for plan participants and a welcome enhancement to plan sponsors' retirement offerings.

IRS Notice 2013-74 dramatically increases participants' ability to convert pre-tax savings into after-tax Roth retirement savings by expanding the pool of eligible assets. 

Pre-Tax
Traditional DC plans such as 401(k), 403(b) and government 457(b) plans allow participants to make pre-tax deferrals to their plan.  These contributions reduce their current tax liability but ultimately, the withdrawals taken during retirement are taxed at regular income tax rates. 

After-Tax
With Roth versions of 401(k), 403(b) and 457(b) plans, participants contribute after-tax amounts that will be taxed in the year of their contribution, however,  withdrawals  will be tax-free.  In-Plan Roth rollovers enable participants to convert pre-tax retirement amounts into an after-tax account (Roth), paying taxes in the year of the conversion.

New IRS Guidance
On December 11, 2013 the IRS issued Notice 2013-74 which expands  the previously limited in-plan Roth conversion option to all vested amounts under eligible plans.  The new rule also allows amounts that are not yet eligible for distribution.

Plan sponsors are not required to offer in-plan Roth conversions to their participants.  Plan sponsors may limit the types of vested pre-tax contributions  to be converted (employer/employee), may  designate the frequency of elective conversions and may choose to discontinue the conversion program, as long as it is done in an equitable manner.

In-Plan Roth Conversion Process
A participant can make an in-plan Roth conversion by transferring assets from a non-Roth account into a designated Roth account within their retirement plan.   The amount transferred from pre-tax to after-tax becomes taxable in the year of the conversion. 

The participant is paying taxes up-front on its converted balances so that in the qualified distributions taken by the participant during retirement may not be taxed.   Essentially, the participant is paying taxes today to avoid paying taxes in the future.  According to the tax law, both the cumulative contributions and any accumulated earnings are both tax-free when withdrawn by the participant in a qualified distribution.  In order to qualify for tax-free status, among other criteria, the assets must be held in the Roth account for at least five years prior to distribution.

Eligible Pre-Tax Amounts
Prior to the new regulations, the only amounts in a pre-tax retirement plan that were eligible for Roth conversion were amounts that were otherwise distributable under tax law.  The new expansion of eligible amounts now covers all vested assets within a pre-tax plan including those that were previously excluded from conversion.

The Notice clarifies that plan sponsors may decide and restrict the types of vested contributions eligible for conversion within their own plan.  The frequency of conversions is also left to the discretion of the plan sponsor.  The plan sponsor must ensure, however, that any restrictions that are implemented do not  disproportionately favor highly compensated employee.

Tax Considerations
The guidance specifically identifies in-plan Roth conversion amounts as not being subject to income tax withholding.  This means that when a participant converts a pre-tax amount to an after-tax Roth amount, the income tax withholding for the year will be insufficient to cover their annual tax liability.  The conversion will trigger an increase in tax liability and the Notice warns that employees who choose to partake in the in-plan Roth conversion either increase their withholding rates or make estimated tax payments to cover the additional income tax liability

Administrative Considerations
Despite characterizing Roth conversions as in-plan "rollovers" from non-Roth to Roth accounts, the new law does not require plan administrators to provide Code section 402(f) notices regarding the tax implications of rollover distributions to participants who choose the make in-plan Roth conversions of non-distributable amounts.

Distribution Restrictions
Any amounts with specific distribution restrictions that are selected for conversion from pre-tax to after-tax Roth amounts will retain those same restrictions after the completion of the conversion.  The IRS suggests that for the simplicity of recordkeeping purposes, plan sponsors simply exclude those amounts with distribution restrictions from the amounts eligible for conversion.  Again, the Notice leaves the determination of eligible assets entirely up to the plan sponsor.  This would eliminate the need to track different converted amounts with different distribution restrictions, dramatically simplifying recordkeeping.

Qualified Roth Distributions
Several requirements must be met for Roth distributions to be considered qualified and therefore tax-free.  Primary among these criteria is the five-year period for qualification.  A qualified distribution must come from a Roth account made more than five taxable years after the first year the participant contributed to the Roth account.  In order to calculate the five-year period, the IRS has stated that if an in-plan Roth conversion is a participant’s first contribution to a Roth account in the plan, the five-taxable-year period begins on the first day of the taxable year in which the in-plan Roth conversion was made.

Converted Excess Contributions and Deferrals
In some cases, contributions and deferrals may later be determined to be in excess of limits.  Excess contributions may occur under the Internal Revenue Code (IRC) nondiscrimination rules.  Excess deferrals may occur under the IRC individual deferral limit.  If any converted amounts are  determined to be in excess, those amounts must be distributed from the Roth account.  This includes amounts that were previously designated non-distributable at the time of the in-plan Roth conversion.

Amending the Plan Document
In order to offer in-plan Roth conversions plan sponsors must amend their plan document before the end of the first calendar year in which they choose to add the feature.  For safe harbor plans with mid-calendar year-ends, the IRS allows for such plans to implement in-plan Roth conversions immediately. 

Conclusion
The Internal Revenue Service (IRS) recently issued guidance on the new legislation that could significantly expand the use of in-plan Roth rollovers in defined contribution (DC) plans.  Plan sponsors have the opportunity to offer expanded in-plan Roth conversions and should seriously evaluate the feature in light of their plan demographics, income levels and tax brackets before deciding to add this feature.