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.

Friday, January 16, 2015

Best Practices: Annual Plan Reviews



Barbara Williams, CFA 
Managing Director 
Bridgebay Financial, Inc. 
www.bridgebay.com  

As a plan sponsor, a key component of your fiduciary best practices should include an annual overall plan review.  The review should include metrics used to measure the plan's success.  It is critical to have an accurate understanding how well your plan is meeting the retirement needs of your participants.

There are general functions within your plan that your annual plan review should include:  

  • Plan Design
  • Recordkeeping and Plan Administration
  • Investments
  • Updated plan documents
  • Plan compliance with IRS, DOL, ERISA
  • Participant Communication and Education
  • Service Provider Fees

Purpose of Annual Plan Review
The annual plan review should occur at the end of your plan year or early into the new plan year.  The role of an annual plan review is to enable you as a fiduciary to effectively oversee each aspect of the plan's operations.  This includes the plan's design, the participant statistics, quality of investments and their performance, regulatory and legislative changes, compliance and participant communications.  It is also important to conduct an annual review for financial stability of your plan's critical service providers that track safeguard your participants assets such as the trustee/custodian and administrator / recordkeeper. 

The results of the plan review provides documentation of the plan, an opportunity to correct plan errors, and improve participant services.  The review can include establishing enhancements and goals for the plan in the upcoming plan year.  The review can identify operational improvements and participant education/communications programs.  The review should include Section 404(c) compliance or areas for improvement.  Nondiscrimination test results, participations rates are best documented in the annual review.  A review should include the plan statistics, comparative industry statistics and surveys, comparison to peer employer plans, and participation rates.

A plan review can document and recognize milestones achieved in the goals set for that year as well as identify areas for improvement or deficiencies that can expose to fiduciary risk.

Best practices for promoting plan success:

  • Monitor trends in participation rates
  • Seek to improve contribution rates
  • Prudently offer a menu of investments that promote asset allocation and diversification
  • Educate participants with the goal of achieving financial literacy
  • Promote retirement readiness
  • Monitor trends
  • Plan Design
  • Benchmarking

Plan Design
Changes to plan design may be triggered periodically by regulatory and legislative changes such as the PPA 2006 that provided new fiduciary protections for plan sponsors. 

Changes in the age, participation levels and other employee demographic may trigger plan design changes.  As your plan evolves and the workforce changes there will be opportunities to revamp the plan’s design.

Specific changing demographics may have a significant effect on your plan's structure and participants' retirement outcomes.  For example, changes in employee demographics with rapid hiring and younger new hires tends to affect the plan's QDIA, choice of investments and participant communication and educational programs.  Conversely, an employer evolving with more experienced employees with higher balances and approaching retirement may consider managed accounts, investment advice and risk-based asset allocation funds.  As participant demographics change, the plan design should evolve to meet the participants' retirement goals.

Some plan sponsors may accelerate new hiring which causes significant changes in employee age groups, compensation and turnover. 

As the employer’s participants change over time, the plan should revisit the peer benchmarking that it is using based on the changing profile of its participants. As the profile of employees changes or evolves, there may be other plan features that are more relevant to the needs of the population.  In some cases, target date funds for new hires may also be supplemented with managed accounts as balances grow. 

Plan sponsors are challenged to follow changing trends in retirement plans as the demographics of participants change over time. 

Plan Documents
Fiduciary files should document any changes made to the plan document, amendments, administrative processes, plan design, compliance, eligibility or recordkeeping should be written, signed, dated and maintained as a part of the fiduciary files.  Often changes require amendments to the plan document which should be reflected in the plan’s Summary Plan Description (SPD) given to the participants.  In the case of major changes to the plan document, the updates and supplements should be reflected in the Summary of Material Modifications (SMM) which is also given to the plan’s participants.

Participant Disclosures
Under ERISA 404(a)(5) participant disclosures participants receive annual fund and fee disclosures.  Annually participants should receive QDIA disclosures that provide fee information and fund performance against standard benchmarks.   Any fund changes to the plan and the transfer of participant balances to a new fund require specific participant notices.  The annual review should check that these disclosures and notices are being sent to participants on a timely basis and are correct.