Listen To Your Participants: Don’t White Label 401k Investment Funds

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

Plan sponsors, if you would like to frustrate, annoy and confuse your 401k plan participants, then white label your 401k plan investment funds.

“White labeling” is the process of renaming the investment funds in a 401k plan using the asset class name they represent. Proponents of white labeling believe that attaching generic labels to investment funds helps participants make better investment decisions. They also believe it makes it easier to make changes to an investment fund lineup, I guess because it hides the fact that changes are being made from participants.

PLANADVISER recently published a well-written piece titled “Does White Labeling Conflict With Transparency Trends?” The answer is “Yes!” I don’t believe that white labeling makes sense, for the following reasons:

It lacks transparency

The process of white labeling obscures the identity of the fund(s) being used. Proponents of white labeling believe that if participants don’t focus on the name of the fund, the fund company and who is managing it, they will invest with more integrity based on their overall investment strategy. Unfortunately, white labeling flies in the face of the overall movement in 401k plans toward transparency. Don’t participants have a right to know what fund they are investing in, and shouldn’t that be a major consideration in determining whether they invest in it? Obscuring the identity of the fund, fund company and fund manager would seem to run counter to the trend of greater transparency.

It can cause participant frustration

I can tell you from more than 30 years of working with participants that anytime white labeling is discussed it leads to participant confusion and lack of trust. Participants often ask, “Why are they trying to hide the name of the fund?” If I answer with “It is to help you focus on the asset class rather than the fund when you invest”, they become confused. Many participants become annoyed and frustrated because they feel white labeling makes it more difficult to figure out what they are really investing in. In all my years of working with plan participants, I have never had a participant say to me, “Bob, I’m sure glad the company white labeled all of the investment funds in my 401k plan.”

Lack of understanding leads to a devalued plan

Making sure participants understand their 401k plans is of paramount importance. Greater understanding leads to greater utilization (e.g., making more contributions) and a higher level of comfort. Participants who understand their employee benefits value them to a much greater degree than participants who don’t. Anything that helps participants better understand their plans should be embraced. Without question, there are investment funds and mutual fund companies that participants quickly recognize, helping them become more comfortable with the investment offerings in their plans. Hiding the identity of funds and fund companies would seem to be a stumbling block to achieving better participant understanding.

It hides complex investment strategies

If you have adopted a white labeling strategy because you are using more than one fund in an asset class, or creating a unique asset class by combining funds, maybe that investment strategy is too complex. Plan sponsors should be creating 401k plans that participants understand, value and use. In other words, plans that are simple to explain and understand. Save all of those unique investment strategies for your corporate investment accounts.

White-labeled products are generally inferior

Most individuals who understand the white labeling concept associate it with generic or inferior branding. Why would you want to take a Vanguard or Fidelity fund and lower its value by white labeling it?

It obscures fund changes

Some practitioners believe white labeling facilitates an easier fund change process. Participants don’t have to be concerned about what is happening behind the curtain because the fund name hasn’t changed, just the actual investment. This is another activity that seems to lead to less transparency rather than more. Participants have a right to know and understand why a change is being made to a fund they are invested in.

It’s not a best practice

White labeling is generally not considered to be a 401k investment menu best practice because it is very hard to determine what benefits participants receive from a white labeling process.

It’s hard to obtain objective information

Using actual fund names makes it possible for participants to obtain objective, unbiased information about their investment funds from many sources. White labeling washes away this benefit, especially when more than one fund is used in an asset class since it is not possible to find publicly available information about white labeled funds from sources like Morningstar.

It hides the impact of superstar managers

Supporters of white labeling believe that participants can become distracted when a superstar manager leaves a fund they may be invested in. Since white labeling hides the names of the investment funds from participants, many may not be aware of management changes. Shouldn’t they be? The departure of a superstar manager can significantly impact a fund’s future investment performance. It may also alter the future path of that fund family. It would seem that a change like this should be shared with participants rather than hidden from them.

There is no question that white labeling makes investment fund administration and communication easier for plan sponsors. However, 401k plans are not run for the benefit of plan sponsors. Rather, the Department of Labor requires them to be run for the benefit of plan participants.

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About the Author

Robert C. Lawton, AIF, CRPS is the founder and President of Lawton Retirement Plan Consultants, LLC. Mr. Lawton is an award-winning 401(k) investment adviser with over 30 years of experience. He has consulted with many Fortune 500 companies, including: Aon Hewitt, Apple, AT&T, First Interstate Bank, Florida Power & Light, General Dynamics, Houghton Mifflin Harcourt, IBM, John Deere, Mazda Motor Corporation, Northwestern Mutual, Northern Trust Company, Trek Bikes, Tribune Company, Underwriters Labs and many others. Mr. Lawton may be contacted at (414) 828-4015 or bob@lawtonrpc.com.

About Lawton Retirement Plan Consultants, LLC

Lawton Retirement Plan Consultants, LLC is a Milwaukee, Wisconsin-based independent, objective Registered Investment Adviser (RIA) providing investment advisory, fiduciary compliance, employee education, provider management and plan design services to 401(k) plan sponsors. The firm currently has contracts in place to provide consulting services on more than $400 million in plan assets. For more information, please contact Robert C. Lawton at (414) 828-4015 or bob@lawtonrpc.com or visit the firm’s website at: http://www.lawtonrpc.com. Lawton Retirement Plan Consultants, LLC is a Wisconsin Registered Investment Adviser.

Important Disclosures

This information was developed as a general guide to educate plan sponsors and is not intended as authoritative guidance, tax, legal or investment advice. Each plan has unique requirements and you should consult your attorney or tax adviser for guidance on your specific situation. In no way does Lawton Retirement Plan Consultants, LLC assure that, by using the information provided, plan sponsor will be in compliance with ERISA regulations. Investors should carefully consider investment objectives, risks, charges and expenses. The statements in this publication are the opinions and beliefs of the commentator expressed when the commentary was made and are not intended to represent that person’s opinions and beliefs at any other time. The commentary does not necessarily reflect the opinion of Lawton Retirement Plan Consultants, LLC and should not be construed as recommendations or investment advice. Lawton Retirement Plan Consultants, LLC offers no tax, legal or accounting advice, and any advice contained herein is not specific to any individual, entity or retirement plan, but rather general in nature and, therefore, should not be relied upon for specific investment situations. Lawton Retirement Plan Consultants, LLC is a Wisconsin Registered Investment Adviser and accepts clients outside of Wisconsin based upon applicable state registration regulations and the “de minimus” exception.

401k Loans: The Worst Possible Investment

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

Taking a 401k loan is such a bad investment choice that it should not be allowed in any 401k plan other than for hardship reasons. And yes, it is an investment because when plan participants take 401k loans, they become one of the investments in their accounts. Consider that:

Borrowers often lose the company match

Many participants who borrow from their 401k accounts end up stopping or lowering their 401k contributions while they are paying back their 401k loan. This often results in the loss of 401k matching contributions when a participant’s contribution rate falls below the maximum matched percentage.

Job changes can force defaults

Most participants considering a job change don’t realize that their outstanding 401k loan balance becomes due when they leave their current employer. In the case of involuntary job loss, an outstanding 401k loan can add significant pain to an already difficult situation. Regardless of whether a job change is voluntary or involuntary, nearly all participants don’t have the financial resources available to pay back their 401k loans when they separate from service. As a result, a large percentage of these participants are forced to default. The defaulted balance becomes subject to state and federal taxes and possibly state and federal early withdrawal penalty taxes. Plan balances that leave a 401k plan forever before retirement are referred to as leakage. “Leakage” from defaulted 401k loans makes it less likely that participants will build adequate retirement savings.

Opportunity costs can be substantial

Assume that a participant takes a $10,000 loan for five years at 6%. The investment experience on that portion of the participant’s balance will be a 6% return for five years. Had the loan balance been invested in the investment options in the plan for the same period, the participant may have earned a lot more. For example, the five-year return on the Vanguard 500 Index Fund through March 31, 2017, was more than 13%.

Interest on a 401k loan is not tax-deductible

Anyone needing a loan should investigate the possibility of taking a home equity loan first since interest on these loans is tax-deductible.

Paying interest to yourself is not such a good idea

I have heard many participants say that they believe 401k loans make sense because they are paying interest to themselves. They often add that the higher the interest rate, the better! First, it is normally not a desirable financial strategy to pay interest of any kind. Second, why would you want to pay a higher interest rate on a loan just because you are paying interest to yourself? That just means you have less of a paycheck to live on. Finally, it appears that the interest on 401k loans is double taxed. Since loan payments are made on an after-tax basis, interest on each payroll loan payment is first taxed then and taxed for a second time when paid out as a distribution at retirement.

Bad loans end up being made

Unless the plan uses hardship provisions to qualify for a loan, a plan sponsor cannot deny a participant loan request. This makes the 401k plan the lender of last resort and results in many bad loans being made to participants who are not creditworthy. Easy access to 401k loans can often make a participant’s bad financial situation worse.

Many participants have said, “Bob, if taking a 401k loan is so bad, why would the company let me do it?” Good question! It is clear that participant loans can drastically reduce an employee’s chances of achieving retirement readiness. As a result, plan sponsors should seriously consider limiting loan availability to hardship criteria or eliminating loans entirely from their plans.

________________

About the Author

Robert C. Lawton, AIF, CRPS is the founder and President of Lawton Retirement Plan Consultants, LLC. Mr. Lawton is an award-winning 401(k) investment adviser with over 30 years of experience. He has consulted with many Fortune 500 companies, including: Aon Hewitt, Apple, AT&T, First Interstate Bank, Florida Power & Light, General Dynamics, Houghton Mifflin Harcourt, IBM, John Deere, Mazda Motor Corporation, Northwestern Mutual, Northern Trust Company, Trek Bikes, Tribune Company, Underwriters Labs and many others. Mr. Lawton may be contacted at (414) 828-4015 or bob@lawtonrpc.com.

About Lawton Retirement Plan Consultants, LLC

Lawton Retirement Plan Consultants, LLC is a Milwaukee, Wisconsin-based independent, objective Registered Investment Adviser (RIA) providing investment advisory, fiduciary compliance, employee education, provider management and plan design services to 401(k) plan sponsors. The firm currently has contracts in place to provide consulting services on more than $400 million in plan assets. For more information, please contact Robert C. Lawton at (414) 828-4015 or bob@lawtonrpc.com or visit the firm’s website at: http://www.lawtonrpc.com. Lawton Retirement Plan Consultants, LLC is a Wisconsin Registered Investment Adviser.

Important Disclosures

This information was developed as a general guide to educate plan sponsors and is not intended as authoritative guidance, tax, legal or investment advice. Each plan has unique requirements and you should consult your attorney or tax adviser for guidance on your specific situation. In no way does Lawton Retirement Plan Consultants, LLC assure that, by using the information provided, plan sponsor will be in compliance with ERISA regulations. Investors should carefully consider investment objectives, risks, charges and expenses. The statements in this publication are the opinions and beliefs of the commentator expressed when the commentary was made and are not intended to represent that person’s opinions and beliefs at any other time. The commentary does not necessarily reflect the opinion of Lawton Retirement Plan Consultants, LLC and should not be construed as recommendations or investment advice. Lawton Retirement Plan Consultants, LLC offers no tax, legal or accounting advice, and any advice contained herein is not specific to any individual, entity or retirement plan, but rather general in nature and, therefore, should not be relied upon for specific investment situations. Lawton Retirement Plan Consultants, LLC is a Wisconsin Registered Investment Adviser and accepts clients outside of Wisconsin based upon applicable state registration regulations and the “de minimus” exception.

Are 401k Plan Loans Double Taxed?

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

Are 401k plan loans double taxed? As outlined in the example below, it appears that the principal amounts of 401k loans that are distributed at retirement are taxed at a rate that is more than double that of a participant’s incremental tax rate. [Read more…]

The 10 Biggest 401k Plan Misperceptions

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

Your 401k plan participants really believe some of the things outlined below!

Having worked as a 401k plan consultant for more than 30 years with some of the most prestigious companies in the world (e.g.; Apple, AT&T, IBM, John Deere, Northern Trust, Northwestern Mutual), I am always surprised by the simple but significant 401k misperceptions many plan participants have. Following are the most common and noteworthy 401k misperceptions: [Read more…]

Should 401k Plans Offer Only Index Funds?

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By Robert C. Lawton, President, Lawton Retirement Plan Consultants, LLC

A number of retirement plan experts believe that 401k plan participants should only be allowed to invest in index funds. They say the additional cost that participants pay for actively managed mutual funds is not justified by better performance. Some 401k plan sponsors have agreed, offering only index funds in their fund lineups. Is that a good idea?

Arguments For Using Only Index Funds

[Read more…]

What Your 401k Investment Committee Should Discuss

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

If you are like most 401k plan sponsors, you worry about whether your 401k plan investment committee is focused on the right stuff. Is the investment committee using its time wisely talking about what is important? Or do you spend way too much time agonizing about investment performance? I believe that your 401k plan investment committee should focus on reviewing the following at their meetings: [Read more…]

Fiduciary Confusion: What’s A 401k Plan Sponsor To Do?

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

On February 3, President Trump signed a memorandum asking the Department of Labor to review the new fiduciary rules that apply to retirement accounts. The next week, on February 9, the Department of Labor (DoL) filed documents that will likely result in a six-month delay of the scheduled April implementation of the rules. There have been a lot of comments circulated on the impact of a delay or any changes. And of course, debate has once again been revived on the value of these new rules. Most important, though, is what this means for your 401k plan and participants and what your 401k fiduciary responsibility is. [Read more…]

How To Avoid A DoL 401k Audit

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

There are many reasons for plan sponsors to do everything possible to avoid a Department of Labor (DoL) 401k audit. They can be costly, time-consuming and generally unpleasant.

The DoL in its Fact Sheet for fiscal year 2016 indicates that the Employee Benefits Security Administration (EBSA) closed 2,002 civil investigations with 1,356 of those cases (67.7%) resulting in monetary penalties/additional contributions. The total amount EBSA recovered for Employee Retirement Income Security Act (ERISA) plan participants last year was $777.5 million.

In my experience, if you receive notification from the DoL that it has an interest in looking over your 401k plan, you need to be concerned. Not only do the statistics above support the fact that DoL auditors do a good job of uncovering problems but in my opinion, they are not an easy group to negotiate with to fix deficiencies.

As a result, I believe the best policy to follow to ensure you don’t receive a visit from a DoL representative is to do everything possible to avoid encouraging such a visit. Here are some suggestions that may help you avoid a DoL 401k audit: [Read more…]

What’s The Right 401k Contribution Rate?

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

The most frequent question I receive from 401k participants is, “How much should I contribute?” My answer is always the same, “As much as you possibly can.” That never seems to satisfy anyone, so I typically go on to explain the following.

The correct 401k contribution rate

[Read more…]

Six New Year’s Resolutions 401k Plan Sponsors Should Make

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By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC

I hope that 2016 was a great year for you and that 2017 will be even better!

A few changes can make your good 401k plan into a great one. To help your 401k plan achieve greatness, consider making the following 401k plan improvements by year-end: [Read more…]