Fee lawsuits and Department of Labor fee disclosure requirements have made defined contribution (DC) plan sponsors laser focused on plan fees. One apparent result has been that such fees have declined overall: according to analysis by BrightScope and the Investment Company Institute (ICI), between 2009 and 2015, total plan costs across all 401(k) plans declined by 14 basis points.1 This has translated into potentially improved retirement prospects for workers. According to the EBRI Retirement Security Projection Model (RSPM), workers ages 35-39 who enjoy 14 basis points fewer plan expenses can expect close to a 4 percent bump in net retirement savings surplus (NRSS)2 when they retire.
While a 4 percent increase in retirement income adequacy is good, participants can experience significantly greater increases by simply benefiting from the economies of scale of large versus small plans. According to the Brightscope/ICI report, fees of small plans (those with $1 million to $10 million in assets) are 1.17 percent This compares to fees of midsized plans ($100 million to $250 million in assets) of 0.52 percent and fees of mega plans (more than $1 billion in assets) of 0.30 percent.
These differences in fees translate into substantial variations in projected savings at retirement. According to RSPM, if the youngest cohort (ages 35-39) of participants in small plans enjoyed the economies of scale of midsized plans, they could expect an increase in NRSS of 19.6 percent–merely due to lower fees. If such participants enjoyed the economies of scale of mega plans, they could expect an increase in NRSS of 26.8 percent due to lower fees.
Costs associated with small plans are a driving force in coverage as well: According to the Bureau of Labor Statistics Compensation Survey, while 83 percent of those working for private sector employers with 500 employees or more have access to a defined contribution plan, only 60 percent of those working for private sector employers with 50-99 employees have such access.
Statistics like these have prompted bipartisan support of initiatives intended to increase availability of open Multiple Employer Plans (MEPs). The thinking goes that open MEPs allow small employers to band together and gain economies of scale to overcome inefficiencies currently preventing them from making cost-effective DC plans available to workers.
In 2016, the Commission on Retirement Security and Personal Savings of the Bipartisan Policy Center (BPC) advocated the creation of a new type of open MEP that would be covered by ERISA3 for businesses with fewer than 500 employers.4 More recently, a provision in the Retirement Enhancement and Savings Act of 2018 (RESA) seeks to facilitate the availability of open MEPs by modifying regulatory provisions such as the “one bad apple” rule that might otherwise hinder open MEP availability.
Critics of open MEPs point to the daunting challenges associated with supporting large numbers of low balance accounts and other administrative considerations, which suggest that economies of scale will be very difficult to achieve. They further point to the potential for abuses if implementation and oversight aren’t well thought out.
However, EBRI’s projection analysis shows that there are potentially gains to be made if open MEPs can achieve even some of the economies of scale of larger plans for small businesses.
1The BrightScope/ICI Defined Contribution Plan Profile: A Close Look at 401(k) Plans, 2015. March 2018
2The net retirement savings surplus is equal to the
present value (in 2018 dollars) at the end of each household’s simulated
lifespan of the surplus wealth in retirement (for those who are not
simulated to run short of money in retirement) less the savings
shortfalls (for those who are simulated to run short of money in
retirement). For additional information, see VanDerhei, Jack.
“Retirement Savings Shortfalls: Evidence from EBRI’s Retirement Security
Projection Model.®” EBRI Issue Brief No. 410 (Employee Benefit Research
Institute, February 2015) http://bit.ly/ebri-2015-february-ib-pdf
3Employee Retirement Income Security Act of 1974
4The BPC was chaired by Kent Conrad (former Senator of
North Dakota) and James B. Lockhart III (former Executive Director of
the Pension Benefit Guarantee Corporation (PBGC)). The name of the
report is: Securing Our Financial Future. http://bipartisanpolicy.org/wp-content/uploads/2016/06/BPC-Retirement-Security-Report.pdf