Pension data cleanup can reduces costs

Data cleanup can help defined benefit (DB) plan sponsors avoid incorrect participant payments and the cost associated with correcting mistakes. Milliman’s Audrey Palmer discusses the potential mishaps that may result from inadequate pension data and the benefits of data cleanup in the DB digest article “Why good data matters.”

Here is an excerpt:

Each year, your plan’s compliance with Internal Revenue Service and Department of Labor regulations also depends on the integrity of the plan’s data. Incomplete or incorrect data can potentially cause noncompliance with many plan-disqualifying regulations, including disclosure requirements, minimum funding requirements, and minimum coverage, participation, and vesting requirements. It can also cause a serious financial burden to participants when excise taxes are imposed that are due to late payment of required minimum distributions. …

… A data cleanup project can make a significant impact to the ongoing administration of your plan by enhancing the individual participant experience, helping to ensure compliance with regulatory requirements, and keeping the plan agile and able to respond to an ever-changing financial and regulatory landscape.

The up-front cost of a data cleanup project is justified when care has been taken to identify the gaps that are easiest to close and will make the most impact. Milliman consultants have experience with this prudent analysis and can help determine which cleanup projects will produce the best return on investment.

An essential part of any data cleanup project is an evaluation of the ongoing periodic data files that provide the participants’ statuses, compensation, hours, and any indicative data to the recordkeeper. Each payroll should undergo a validation check to make certain the expected population, expected totals, and expected statuses are loaded with each file. These checks, combined with a comprehensive analysis of the file produced by the plan sponsor, will catch most errors that could cause ongoing data issues.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

New process for DB plan determination letter applications
The IRS published a post on its website highlighting the new process for defined benefit plan determination letter applications.

To read the entire post, click here.

IRS releases draft Form 5300
The IRS issued a draft of the revision for Form 5300, Application for Determination for Employee Benefit Plan. Form 5300 is used to request a favorable determination letter (DL) from the IRS on the qualified status of these plans and the exempt status of any related trust.

Form 5300 has undergone major revisions in format and information required. Many of the revisions reflect the changes affecting individually designed plans described in Announcement 2015-19, and Revenue Procedure 2016-37. The revised form significantly simplifies the information plan sponsors must provide and is expected to reduce the taxpayer burden in filling out the form.

The IRS expects the final version of Form 5300 to be available by December 2016. If you wish, you can submit comments about the draft Form 5300.

Federal agencies release proposed revisions to improve Form 5500
The Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA), the IRS, and the Pension Benefit Guaranty Corporation (PBGC) are seeking public comments on proposed revisions to modernize and improve the Form 5500 Annual Return/Report filed by private-sector employee benefit plans. The EBSA also published a related notice of proposed changes to its annual reporting regulations under Title I of the Employee Retirement Income Security Act.

The Form 5500 is the primary source of information about the operations, funding, and investments of private-sector, employment-based pension and welfare benefit plans in the United States.

To read the proposed rule, click here.

 

Avoiding poverty in a DC-only world

Bradley_JeffIn a defined contribution (DC) world, retirees are forced to make critical decisions, often with little or no assistance. Most of these individuals choose to take a single sum distribution either immediately or soon after they terminate employment.

This paper from the Center for Retirement Research at Boston College asserts that distribution provisions in DC plans are critical factors in evaluating the risk of falling into poverty in old age.

Specifically, the paper states that reliance on non-annuitized DC benefits with fairly easy access to lump-sum distributions puts elderly households at risk of not having sufficient income (or assets) to sustain themselves or, if they are not already in poverty at retirement, falling into poverty as the household members age or die off.

As workers continue to age, this will become a greater problem as those covered by defined benefit plans retire from the workforce and are replaced by those covered only by DC plans. So what can plan sponsors do to minimize the probability of their retirees falling into poverty?

Extrapolating from thoughts in the paper, the conclusion is that plan sponsors should encourage the following behaviors:

• Not taking lump-sum distributions before retirement
• Annuitizing some or all DC benefits when possible
• Choosing joint-and-survivor options when available

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Milliman launches enhanced defined contribution participant website

Milliman today announced the launch of its latest in a series of website enhancements for its defined contribution clients and their plan participants.

New features on MillimanBenefits.com include an interactive “It’s Your Move” dashboard with tools that support successful retirement behaviors, such as saving enough to get the company match, diversifying investments, and utilizing automatic increase and automatic rebalance features – all with a refreshed look and feel. The site enhancements build on Milliman’s robust PlanAhead for Retirement® projection tool, educational Financial Resources Center, and award-winning mobile application.

“Our consultants are excited to offer these new features to our clients. More than ever, our clients understand that it’s important to encourage constructive behavior in this age when too many people are not saving enough for retirement,” says Jeff Budin, Milliman’s global employee benefits practice leader. “From a behavioral finance perspective, it’s helpful to participants to see a list of items they are doing well next to some additional actions they could take to strengthen their account with the simple click of a mouse.”

To learn more about Milliman’s independent, conflict-free approach to recordkeeping in the defined contribution industry, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

Technical corrections to best of interest rule; class exemption for principal transaction in certain assets
The Department of Labor (DOL) filed technical corrections to the Best Interest Contract Exemption, which was published on April 8, 2016. The Best Interest Contract Exemption allows certain persons that are fiduciaries under the Employee Retirement Income Security Act of 1974 (ERISA) or the Internal Revenue Code (the Code), or both, by reason of providing investment advice, to receive compensation that may otherwise be prohibited.

The corrections in this document fix typographical errors, make minor clarifications to provisions that might otherwise be confusing, and confirm insurers’ broad eligibility to rely on the exemption, consistent with the exemption’s clearly intended scope and the analysis and data relied upon in the DOL’s final regulatory impact analysis (RIA).

For more information, click here.

Office of Chief Counsel memo regarding testing otherwise excludable employees
The IRS’ Office of Chief Counsel released Memorandum 201615013 concerning testing otherwise excludable employees. The taxpayer asked whether certain positions related to the definition of “otherwise excludable employees,” used for purposes of coverage testing under § 410(b)(4)(B) and computing the actual deferral percentage (ADP) under § 401(k)(3), are supportable.

To read the entire memo, click here.

Funded status plummets in June, Brexit a possible culprit

Wadia_ZorastMilliman today released the results of its latest Pension Funding Index (PFI), which analyzes the 100 largest U.S. corporate pension plans. In June, these pension plans experienced a $46 billion decrease in funded status primarily due to a $54 billion increase in pension liabilities. Investment gains partially helped to offset the funded status decline. The funded ratio for these pensions decreased from 77.5% to 75.7% at the end of June. As we pass the midpoint of 2016, the funded status deficit has ballooned to $447 billion, a $140 billion increase over the past six months – Brexit, and an overall discount rate drop of 71 basis points, point to the reasons why.

2269MEB_PFI-Fig1_blog_600px

Plans with fiscal years ending June 30th had a late-breaking surprise with the passage of Brexit. Falling 23 basis points, US discount rates certainly weren’t immune to the Brexit pain. The silver lining here lies with fixed income investments, which benefited from the discount rate decline. Those with heavy allocations towards fixed income are seeing investment gains.

Looking forward, under an optimistic forecast with rising interest rates (reaching 3.75% by the end of 2016 and 4.35% by the end of 2017) and asset gains (11.2% annual returns), the funded ratio would climb to 81% by the end of 2016 and 93% by the end of 2017. Under a pessimistic forecast (3.15% discount rate at the end of 2016 and 2.55% by the end of 2017 and 3.2% annual returns), the funded ratio would decline to 72% by the end of 2016 and 66% by the end of 2017.

A sustainable retirement plan for sponsors and participants

The Milliman Sustainable Income PlanTM (SIP) is a good retirement plan option for employers seeking predictable contributions while offering employees lifelong income. According to Milliman consultant Kelly Coffing, the SIP offers sponsors and participants the following:

• Professional asset management throughout participants’ working and retired years
• Maximized retirement benefits per dollar of employer contribution
• Lifelong inflation-protected income, and
• Stable, predictable contributions for sponsors.

For more perspective, read Kelly’s article in Money Management Intelligence entitled “Retirement plan innovation that opens up investment possibilities.”

The Stabilized Variable Annuity Pension Plan (VAPP) is now the Milliman Sustainable Income PlanTM(SIP).

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

IRS guidance on determination letter program and the six-year remedial amendment cycle
The IRS released Revenue Procedure 2016-37 providing modifications to the Determination Letter Program for tax-qualified individually designed plans and to the six-year remedial amendment cycle system for pre-approved retirement plans. Under the changes, sponsors of individually designed qualified retirement plans can request a determination letter only upon initial qualification or plan termination. The guidance also extends the remedial amendment period for individually designed plans until Aug. 1, 2017, and makes changes to the remedial amendment cycle for pre-approved plans.

To read the entire Rev. Procedure, click here.

Census Bureau releases 2016 first quarter data on public pensions
The U.S. Census Bureau released its Quarterly Survey of Public Pensions, covering the first quarter of 2016. The survey provides national summary data on the revenues, expenditures, and composition of assets of 100 of the largest defined benefit public employee pension systems for state and local governments, comprising 88.4% of financial activity among such entities, based on the 2012 Census of Governments.

To read the survey, click here.

How did financial markets respond to Brexit?

Throughout the month of June leading up to the Brexit vote, the markets appeared to have trouble deciding which way the vote would go. Equity markets began to sell off during the second week of June as Brexit appeared to be increasingly likely. On June 14, as sentiment changed and the likelihood of Brexit seemed to be waning, equity markets started to climb back to early June levels. Markets were firmly higher on the day of the vote, exhibiting confidence that Britons would choose to stay in the European Union. As vote counts came in, currency and futures markets grew increasingly volatile with the rising prospect that Brexit would prevail. The next morning, equity markets opened sharply lower, displaying the characteristics of a classic gap event. Milliman consultants Adam Schenck,  Jeff Greco, and Joe Becker provide more perspective in this article.

409A deferral election results: A mixed bag

Pizzano-DominickThis blog is part of a 12-part series entitled “The nonqualified deferred compensation plan (NDCP) dirty dozen: An administrative guide to avoiding 12 traps.” To read the introduction to the series, click here.

The process of deferring a portion of a participant’s pay under a nonqualified deferred compensation plan (NDCP) can, at first glance, appear quite similar to how such deferral would be handled under a 401(k) plan. Participants designate a specified dollar amount or percentage of their pay they wish to defer under the plan. The plan sponsor then arranges for such amounts to be deducted from the participants’ pay and allocated to an account maintained on their behalf under the plan. However, upon delving deeper, we see stark differences that must be observed by NDCP participants and sponsors in order to comply with Internal Revenue Code Section 409A. As with many of 409A’s rules, the restrictions on deferral elections require tight timing. This blog will highlight the differences between permissible 401(k) and NDCP deferral elections while also describing some of the plan design options available to provide participants with at least some flexibility when making their NDCP deferral elections with respect to salary and bonuses. While 409A also contains specific rules governing other types of deferrals (e.g., short-term deferrals, commission, etc.), analysis of such rules is beyond the scope of this series.

NDCP deferrals: Generally “Election Day” comes just once a year
Typically, 401(k) plans permit participants to make deferral elections as soon as their first payroll periods coincident with or next following the date on which they meet the plan’s eligibility requirements. If any participant fails to defer when first eligible, a 401(k) plan could allow them to begin deferring as of any subsequent payroll period. Similarly, a 401(k) plan can generally permit participants to increase, decrease, or discontinue their rates of deferrals as of any subsequent payroll period. In contrast, while a participant’s initial deferral opportunities under an NDCP are somewhat similar to the 401(k) plan, once the first deferral chance passes, there is considerably less flexibility.

Under an NDCP, in the case of the first year in which a participant becomes eligible to participate in the plan (whether it is a brand new plan or an existing plan for which the individual has just become eligible), participants have until 30 days after they first become eligible to make their salary deferral elections. Such elections must only apply to compensation (whether in the form of salary or bonus) paid for services to be performed beginning with the first payroll period after the election. If participants pass on this initial deferral option, they will not have another deferral opportunity until January 1 of the next calendar year. Similarly, for those participants who do elect to defer a portion of their salaries when first eligible, no changes to such initial elections can be made until January 1 of the next calendar year.

Because all NDCP deferral elections (including elections not to defer) are “locked in” for the calendar year in which they are made, plan sponsors need to be sure that their corporate cultures and populations are the right fit and that they have effectively provided the appropriate caveats before deciding to offer participants “evergreen elections.” Under such elections participants have the ability to make an NDCP deferral election and then have that election automatically roll over from year to year unless they specify otherwise before the applicable January 1. Without such a fit and/or without any proactive measures in place, such a design runs the risk of participants forgetting to get decrease or discontinuance requests to sponsors on time and then being stuck for the coming year with deferral rates that they do not want, or worse, may not be able to afford, given their anticipated cash flow and expenses for such year. In order to prevent this predicament, the NDCP sponsor can instead require that the participants reenroll each year by making a new salary election prior to January 1 of each year. This design is particularly effective in decreasing potential participant complaints if combined with a strong annual communications campaign during an open enrollment period that begins as early as October and ends on whichever day in December is the last day that the plan administrator is able to accept the election in order to process it for the first payroll period in January, during which the participant earns pay attributable to services performed in the new year. (Note: any “carry-over” pay from the previous year, i.e., pay earned in the previous year but not payable until January of the current year, will be subject to the previous year’s deferral rate.)

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