Plan sponsors are faced with numerous challenges when managing a retirement program. Design, compliance, administration, and employee education are critical to the success of employer-sponsored programs.
Plan Design & Compliance
With over 14 years of experience in retirement plan design, we understand the competing priorities of providing employer-funded retirement benefits and protecting shareholder value. We are not only well versed in plan design (match, non-elective, integrated, cross-tested, Top-hat and SERP), but also in plan administration (eligibility, enrollment, grandfathering impact, loan and withdrawal features, distribution options, etc.) and investment structure (number and type of investments).
PFE first implemented automatic enrollment in 1996, two years before the IRS issued its favorable opinion of “negative-enrollment.” For the last 14 years, we have been staunch advocates for automatic enrollment, automatic increase and defaulting participants into equity-based investment portfolios. Many of our clients have benefited from auto-enrollment features for more than 10 years.
Our comprehensive review and follow-up analysis for 401(k) and non-qualified plans includes the following:
- Plan Design: rewards philosophy, retirement sufficiency analysis, assessment of employer costs, expected employee behaviors, benchmark to industry peers
- Plan Benefits: match (tiered or not), non-elective, combination, integrated, cross-tested, etc.
- Plan Features: eligibility, eligible pay, automatic enrollment and increase, pre-tax & Roth 401(k) contributions, distribution options, loans, and withdrawals
- Plan Administration: recordkeeper competency, services, service agreement and fees, confirm if any tasks should be in-sourced, out-sourced, or co-sourced
- Compliance: Document review, Summary Plan Description (SPD) development, error-evaluation and correction (self-correction, VCP, etc.)
- Investment Structure: compare current lineup to best practices
- Investment Manager Review and Selection
- Total Plan Expense Analysis: employer-paid vs. employee-paid; benchmark to peer group and PFE database
- Communication and Education: effectiveness of current approach/media
- Benchmark Findings: relative to appropriate peer group and industry best practices
We monitor current and pending retirement program legislation. Our recommendations enable you to stay informed of Department of Labor (DOL) and Internal Revenue Service (IRS) regulations and incorporate best practice procedures.
Our efforts include:
- Review Committee Structure and Operating Procedures (e.g., membership, number and relationship of named fiduciaries to the plan, meeting frequency, meeting agenda, meeting attendance, voting process, meeting minutes, implemented decisions)
- Review Retirement Plan Committee Charter and Plan Investment Policy
- Draft Charter and/or Investment Policy, if necessary
- Review how Committee oversees plan operations and investment performance, including QDIA selection, Notices (QDIA, auto-enrollment, etc.), investment manager monitoring, and process to remain current on plan compliance (DOL, IRS, SEC), participant behaviors, plan investments, service provider performance, etc.
- Review Fidelity Bond and Fiduciary Liability insurance coverage
- Review fiduciary compliance with ERISA §404(c), §406, and §408