By Fred Reish, Partner/Chair, Fiduciary Services, ERISA Team at Drinker Biddle & Reath LLP
As I review investment policy statements for participant-directed plans, I see a number of common deficiencies. This article is about one of those—the selection and monitoring of target date funds ("TDFs”).
In my experience, most IPS’ say little or nothing about the criteria to be applied to TDFs. For example, an IPS might be completely silent on the issue or may simply say that they will be selected and monitored. But, in neither case is there a robust set of criteria. That is problematic.
One reason is that TDFs are capturing an increasingly large percentage of 401(k) assets. As more plans automatically enroll, that percentage will continue to grow. I can imagine a day, in the not-so-distant future, where over half of the assets in 401(k) plans will be in TDFs. That leads to the unfortunate conclusion that, based on the current practices of many advisers and committees, over one-half of the assets in the plan will be in a suite of investments that has not been subjected to close scrutiny, while the other investments – that hold less than half of the assets -- will be subject to a rigorous evaluation process. That just doesn’t make sense. And, where a situation doesn’t make sense, it can lead to problems.
With that in mind, I recommend that you take a look at the evaluation criteria in DOL comments filed by the Investment Company Institute and the American Benefits Council. It is the most robust set of TDF criteria that I have seen. Click here to view the ABC/ICI comments.
The criteria in those comments set a much higher standard than the common practices of advisers and plan committees. However, I think those comments may suggest the future -- rather than reflecting the past.
For example, the comments suggest considering, among other things:
- The performance of each of the mutual funds inside the TDF,
- Appropriate benchmarks to evaluate TDF performance,
- Participant demographics, and
- Whether the plan sponsor also offers a pension plan.