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Benchmarking v2.0:
Improved Outcomes for Plan Sponsors and Participants
Tom Kmak, CEO
Fiduciary Benchmarks
Copyright© Fiduciary Benchmarks
All Rights Reserved
Agenda
1. FBi Benchmarking Basics
2. Benefits to Plan Sponsors
3. Benefits to Participants
1
Copyright© Fiduciary Benchmarks
All Rights Reserved
What are the duties of a Fiduciary?
• Fiduciaries have important responsibilities and are
subject to standards of conduct because they act
on behalf of participants in a retirement plan and
their beneficiaries. These responsibilities include:
• Acting solely in the interest of plan
participants and their beneficiaries and with
the exclusive purpose of providing benefits to
them;
• Carrying out their duties prudently;
• Following the plan documents (unless
inconsistent with ERISA);
• Diversifying plan investments; and
• Paying only reasonable plan expenses.
Source: www.dol.gov/ebsa/publications/fiduciaryresponsibility.html
2
Copyright© Fiduciary Benchmarks
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What does the DOL say about 401(k) Fees?
“When you consider the fees in your 401(k) plan and
their impact on your retirement income, remember that
all services have costs. If your employer has selected a
bundled program of services and investments, compare
all services received with the total cost. Remember, too,
that higher investment management fees do not
necessarily mean better performance. Nor is cheaper
necessarily better. Compare the net returns relative to
the risks among available investment options. And,
finally, don’t consider fees in a vacuum. They are only
one part of the bigger picture including investment risk
and returns and the extent and quality of services
provider.”
Source: A Look at 401(k) Plan Fees, U.S. Department of Labor, October 2010
3
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“That’s the trouble
with the world
today, nobody takes
the time to do a
really sinister
interrogation
anymore”
True or False:
Low Fees is the Fiduciary Standard
4
Copyright© Fiduciary Benchmarks
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v2 Improvement:
Additional Guidance for the Fiduciary
5
Copyright© Fiduciary Benchmarks
All Rights Reserved
True or False:
Reasonable Total Plan Fees is the Fiduciary Issue
6
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Distinct Benchmarking by Service Provider
7
Copyright© Fiduciary Benchmarks
All Rights Reserved
Agenda
1. FBi Benchmarking Basics
2. Benefits to Plan Sponsors
3. Benefits to Participants
8
Copyright© Fiduciary Benchmarks
All Rights Reserved
The impact per one prominent ERISA attorney:
1. Know what your fees are
2. Compare them to benchmarks
3. Monitor on an ongoing basis
4. Make sure you have real documentation
5. Hire Third-Parties for an independent review
6. Make sure you conduct a fiduciary audit
7. Have a Fiduciary Manual
Documenting the Process for Fiduciaries
Marcia Wagner, Plan Sponsor interview, December 2009
$16.5 million
“The lesson is to benchmark your plan’s services against
appropriate peer-group data. It would be difficult for a
plaintiff’s attorney to show that you were imprudent if you
take that step and if the results are reasonable.”
Fred Reish, Drinker Biddle, Plan Sponsor 7/2011
9
Copyright© Fiduciary Benchmarks
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The RIGHT Way to Benchmark (U.S. Patent 8,150,198)
1. Use Data that has Integrity:
• Right Source
• Accurate
• Timely
• Comprehensive
3. Provide Output that is Simple, Transparent & Practical:
• Concise
• Actionable
• Timely
• Procedurally Prudent
2. Employ a Method that is Fair and Independent:
• Build an “Apples to Apples” Comparison Group
• Collect and Normalize ALL Fees
• Examine Value for Participants, Sponsors & Providers
10
Copyright© Fiduciary Benchmarks
All Rights Reserved
True or False:
You can accurately benchmark using 5500 Data
Question:
Plan A Average Salary Deferral = $2,500
Plan B Average Salary Deferral = $2,273
Which plan actually has better Salary Deferrals?
1. Plan A
2. Plan B
3. I Don’t Know
This technique of
normalization is critical for
accurate comparisons and
this is why the 401(k)
discrimination test is
performed as a percentage
of compensation.
11
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100% of data should come directly from the source: Service Providers
All data is thus current, accurate and consistent with 408(b)(2) disclosures.
v1 Holdover:
Use Data That Allows Valid Comparisons
12
Copyright© Fiduciary Benchmarks
All Rights Reserved
The RIGHT Way to Benchmark (U.S. Patent 8,150,198)
1. Use Data that has Integrity:
• Right Source
• Accurate
• Timely
• Comprehensive
3. Provide Output that is Simple, Transparent & Practical:
• Concise
• Actionable
• Timely
• Procedurally Prudent
2. Employ a Method that is Fair and Independent:
• Build an “Apples to Apples” Comparison Group
• Collect and Normalize ALL Fees
• Examine Value for Participants, Sponsors & Providers
13
Copyright© Fiduciary Benchmarks
All Rights Reserved
True or False:
Average Balance impacts the Benchmark Group
14
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All Rights Reserved
v2 Improvement:
Benchmark Groups Customized BY PROVIDER
15
Copyright© Fiduciary Benchmarks
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True or False:
Plans with Identical Funds Have Identical Fees
16
Copyright© Fiduciary Benchmarks
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v2 Improvement:
Plan Weighted Investment Expense
17
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True or False:
General Accounts have No Fees
18
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v2 Improvement:
Detail on General Accounts (and Stable Value)
19
Copyright© Fiduciary Benchmarks
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True or False:
You Can’t Predict Fees
20
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v2 Improvement:
Regression Analysis on Fees
21
v2 Improvement:
Greater Emphasis on Fees AND Value
Advisors
• Investments
• Vendor Mgmt
• Plan Mgmt
• Participant Svcs
RKs and TPAs
• Plan Complexity
• Recordkeeping
• Administration
• Compliance
• Communications
• Participant Success
Investment Mgrs
• Alpha
• Beta
True or False:
Performance Reviews are a commodity
Provide and Review Performance Reporting
Review
RK/TPA-
Provided
Performance
Reports
Use Standardized
Screening Tool
(i.e. Morningstar,
Lipper, etc.)
Use Customized
Version of Standard
Reporting Tool
(i.e. Customized
Morningstar, Lipper,
etc.)
Create Fully-
Customized
Reporting Using a
Tool Like MPI
Utilize Proprietary
Service to Generate
Custom Reporting
(i.e. RPAG)
Use Fully-Customized
Reporting and Have
Shared Investment
Staff (CFA, CIMA)
Performing Analysis
Use Fully-Customized
Reporting and Have
Dedicated Investment
Staff (CFA, CIMA)
Performing Analysis
MORE WORKLESS WORK
v2 Improvement:
Degree of Difficulty for Services
True or False:
The DOL allows you to consider Quality of a Provider
v2 Improvement:
Background of Service Provider
The RIGHT Way to Benchmark (U.S. Patent 8,150,198)
1. Use Data that has Integrity:
• Right Source
• Accurate
• Timely
• Comprehensive
3. Provide Output that is Simple, Transparent & Practical:
• Concise
• Actionable
• Timely
• Procedurally Prudent
2. Employ a Method that is Fair and Independent:
• Build an “Apples to Apples” Comparison Group
• Collect and Normalize ALL Fees
• Examine Value for Participants, Sponsors & Providers
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Fees and Value for a Provider on 1 page
28
Copyright© Fiduciary Benchmarks
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v2 Benchmarking
Helping a Plan Sponsor Protect Themselves
 Make sure the service is Independent, Comprehensive and Informative
 Benchmark Fees AND Cost-Driver/Value-Factors/Quality of the Provider
 Are they using the right data to benchmark?
 Have they considered Fees from the Insurance Company General Account?
 Have they considered differences in Asset Allocation?
 Are they considering the Value provided by ALL of your Service Providers?
 Are they providing you information on Plan Complexity and Administrative Difficulty?
 Are they providing information on helping your participants prepare for Retirement?
 Are they doing all of this PROACTIVELY?
29
Copyright© Fiduciary Benchmarks
All Rights Reserved
Agenda
1. FBi Benchmarking Basics
2. Benefits to Plan Sponsors
3. Benefits to Participants
30
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
6th Place
31
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
5th Place
32
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
4th Place
33
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
3rd Place
34
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
2nd Place
35
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
1st Place
36
Copyright© Fiduciary Benchmarks
All Rights Reserved
Why Women Live Longer Than Men
Runner-Up
37
Copyright© Fiduciary Benchmarks
All Rights Reserved
SAVING
• Participation Rate: Overall, HCE and NHCE
• Deferral Rate: Overall, HCE and NHCE
• Percent Maximizing Company Match
• Percent on an Auto-Escalate Program
• Percent utilizing Catch-up
• Percent of Assets in Auto-Diversified Options
• Percent of Delegators with 90% in 1 ADO
• Percent of Delegators Auto-Rebalancing
SPENDING
• Percent NOT “cashing-out”
KNOWING • Having a personal Retirement Goal
• On track to achieve that Goal
• Success Measures
that have a
proven impact on
increasing
Retirement
Readiness
Generating Retirement Readiness
38
Copyright© Fiduciary Benchmarks
All Rights Reserved
What If Analysis:
39
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Closer Link of Plan Design to Retirement Readiness
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Closer Link of Plan Design to Retirement Readiness
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Closer Link of Plan Design to Retirement Readiness
Copyright© Fiduciary Benchmarks
All Rights Reserved
v2 Improvement:
Closer Link of Plan Design to Retirement Readiness
Copyright© Fiduciary Benchmarks
All Rights Reserved
Versus
Cost Drivers
Value Factors
Quality of Provider
Fees
v2 Improvement:
Much Greater Emphasis on Value Components
44
Copyright© Fiduciary Benchmarks
All Rights Reserved
This material has been prepared solely for
informational and educational purposes. It is
not intended to provide, and should not be
relied upon for, investment, accounting, legal
or tax advice.
www.fiduciarybenchmarks.com
5335 Meadows Road, Suite 210  Lake Oswego, OR 97035  866.516.4909
45

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Benchmarking v2.0

  • 1. Benchmarking v2.0: Improved Outcomes for Plan Sponsors and Participants Tom Kmak, CEO Fiduciary Benchmarks
  • 2. Copyright© Fiduciary Benchmarks All Rights Reserved Agenda 1. FBi Benchmarking Basics 2. Benefits to Plan Sponsors 3. Benefits to Participants 1
  • 3. Copyright© Fiduciary Benchmarks All Rights Reserved What are the duties of a Fiduciary? • Fiduciaries have important responsibilities and are subject to standards of conduct because they act on behalf of participants in a retirement plan and their beneficiaries. These responsibilities include: • Acting solely in the interest of plan participants and their beneficiaries and with the exclusive purpose of providing benefits to them; • Carrying out their duties prudently; • Following the plan documents (unless inconsistent with ERISA); • Diversifying plan investments; and • Paying only reasonable plan expenses. Source: www.dol.gov/ebsa/publications/fiduciaryresponsibility.html 2
  • 4. Copyright© Fiduciary Benchmarks All Rights Reserved What does the DOL say about 401(k) Fees? “When you consider the fees in your 401(k) plan and their impact on your retirement income, remember that all services have costs. If your employer has selected a bundled program of services and investments, compare all services received with the total cost. Remember, too, that higher investment management fees do not necessarily mean better performance. Nor is cheaper necessarily better. Compare the net returns relative to the risks among available investment options. And, finally, don’t consider fees in a vacuum. They are only one part of the bigger picture including investment risk and returns and the extent and quality of services provider.” Source: A Look at 401(k) Plan Fees, U.S. Department of Labor, October 2010 3
  • 5. Copyright© Fiduciary Benchmarks All Rights Reserved “That’s the trouble with the world today, nobody takes the time to do a really sinister interrogation anymore” True or False: Low Fees is the Fiduciary Standard 4
  • 6. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Additional Guidance for the Fiduciary 5
  • 7. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: Reasonable Total Plan Fees is the Fiduciary Issue 6
  • 8. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Distinct Benchmarking by Service Provider 7
  • 9. Copyright© Fiduciary Benchmarks All Rights Reserved Agenda 1. FBi Benchmarking Basics 2. Benefits to Plan Sponsors 3. Benefits to Participants 8
  • 10. Copyright© Fiduciary Benchmarks All Rights Reserved The impact per one prominent ERISA attorney: 1. Know what your fees are 2. Compare them to benchmarks 3. Monitor on an ongoing basis 4. Make sure you have real documentation 5. Hire Third-Parties for an independent review 6. Make sure you conduct a fiduciary audit 7. Have a Fiduciary Manual Documenting the Process for Fiduciaries Marcia Wagner, Plan Sponsor interview, December 2009 $16.5 million “The lesson is to benchmark your plan’s services against appropriate peer-group data. It would be difficult for a plaintiff’s attorney to show that you were imprudent if you take that step and if the results are reasonable.” Fred Reish, Drinker Biddle, Plan Sponsor 7/2011 9
  • 11. Copyright© Fiduciary Benchmarks All Rights Reserved The RIGHT Way to Benchmark (U.S. Patent 8,150,198) 1. Use Data that has Integrity: • Right Source • Accurate • Timely • Comprehensive 3. Provide Output that is Simple, Transparent & Practical: • Concise • Actionable • Timely • Procedurally Prudent 2. Employ a Method that is Fair and Independent: • Build an “Apples to Apples” Comparison Group • Collect and Normalize ALL Fees • Examine Value for Participants, Sponsors & Providers 10
  • 12. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: You can accurately benchmark using 5500 Data Question: Plan A Average Salary Deferral = $2,500 Plan B Average Salary Deferral = $2,273 Which plan actually has better Salary Deferrals? 1. Plan A 2. Plan B 3. I Don’t Know This technique of normalization is critical for accurate comparisons and this is why the 401(k) discrimination test is performed as a percentage of compensation. 11
  • 13. Copyright© Fiduciary Benchmarks All Rights Reserved 100% of data should come directly from the source: Service Providers All data is thus current, accurate and consistent with 408(b)(2) disclosures. v1 Holdover: Use Data That Allows Valid Comparisons 12
  • 14. Copyright© Fiduciary Benchmarks All Rights Reserved The RIGHT Way to Benchmark (U.S. Patent 8,150,198) 1. Use Data that has Integrity: • Right Source • Accurate • Timely • Comprehensive 3. Provide Output that is Simple, Transparent & Practical: • Concise • Actionable • Timely • Procedurally Prudent 2. Employ a Method that is Fair and Independent: • Build an “Apples to Apples” Comparison Group • Collect and Normalize ALL Fees • Examine Value for Participants, Sponsors & Providers 13
  • 15. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: Average Balance impacts the Benchmark Group 14
  • 16. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Benchmark Groups Customized BY PROVIDER 15
  • 17. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: Plans with Identical Funds Have Identical Fees 16
  • 18. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Plan Weighted Investment Expense 17
  • 19. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: General Accounts have No Fees 18
  • 20. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Detail on General Accounts (and Stable Value) 19
  • 21. Copyright© Fiduciary Benchmarks All Rights Reserved True or False: You Can’t Predict Fees 20
  • 22. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Regression Analysis on Fees 21
  • 23. v2 Improvement: Greater Emphasis on Fees AND Value Advisors • Investments • Vendor Mgmt • Plan Mgmt • Participant Svcs RKs and TPAs • Plan Complexity • Recordkeeping • Administration • Compliance • Communications • Participant Success Investment Mgrs • Alpha • Beta
  • 24. True or False: Performance Reviews are a commodity
  • 25. Provide and Review Performance Reporting Review RK/TPA- Provided Performance Reports Use Standardized Screening Tool (i.e. Morningstar, Lipper, etc.) Use Customized Version of Standard Reporting Tool (i.e. Customized Morningstar, Lipper, etc.) Create Fully- Customized Reporting Using a Tool Like MPI Utilize Proprietary Service to Generate Custom Reporting (i.e. RPAG) Use Fully-Customized Reporting and Have Shared Investment Staff (CFA, CIMA) Performing Analysis Use Fully-Customized Reporting and Have Dedicated Investment Staff (CFA, CIMA) Performing Analysis MORE WORKLESS WORK v2 Improvement: Degree of Difficulty for Services
  • 26. True or False: The DOL allows you to consider Quality of a Provider
  • 27. v2 Improvement: Background of Service Provider
  • 28. The RIGHT Way to Benchmark (U.S. Patent 8,150,198) 1. Use Data that has Integrity: • Right Source • Accurate • Timely • Comprehensive 3. Provide Output that is Simple, Transparent & Practical: • Concise • Actionable • Timely • Procedurally Prudent 2. Employ a Method that is Fair and Independent: • Build an “Apples to Apples” Comparison Group • Collect and Normalize ALL Fees • Examine Value for Participants, Sponsors & Providers
  • 29. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Fees and Value for a Provider on 1 page 28
  • 30. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Benchmarking Helping a Plan Sponsor Protect Themselves  Make sure the service is Independent, Comprehensive and Informative  Benchmark Fees AND Cost-Driver/Value-Factors/Quality of the Provider  Are they using the right data to benchmark?  Have they considered Fees from the Insurance Company General Account?  Have they considered differences in Asset Allocation?  Are they considering the Value provided by ALL of your Service Providers?  Are they providing you information on Plan Complexity and Administrative Difficulty?  Are they providing information on helping your participants prepare for Retirement?  Are they doing all of this PROACTIVELY? 29
  • 31. Copyright© Fiduciary Benchmarks All Rights Reserved Agenda 1. FBi Benchmarking Basics 2. Benefits to Plan Sponsors 3. Benefits to Participants 30
  • 32. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 6th Place 31
  • 33. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 5th Place 32
  • 34. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 4th Place 33
  • 35. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 3rd Place 34
  • 36. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 2nd Place 35
  • 37. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men 1st Place 36
  • 38. Copyright© Fiduciary Benchmarks All Rights Reserved Why Women Live Longer Than Men Runner-Up 37
  • 39. Copyright© Fiduciary Benchmarks All Rights Reserved SAVING • Participation Rate: Overall, HCE and NHCE • Deferral Rate: Overall, HCE and NHCE • Percent Maximizing Company Match • Percent on an Auto-Escalate Program • Percent utilizing Catch-up • Percent of Assets in Auto-Diversified Options • Percent of Delegators with 90% in 1 ADO • Percent of Delegators Auto-Rebalancing SPENDING • Percent NOT “cashing-out” KNOWING • Having a personal Retirement Goal • On track to achieve that Goal • Success Measures that have a proven impact on increasing Retirement Readiness Generating Retirement Readiness 38
  • 40. Copyright© Fiduciary Benchmarks All Rights Reserved What If Analysis: 39
  • 41. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Closer Link of Plan Design to Retirement Readiness
  • 42. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Closer Link of Plan Design to Retirement Readiness
  • 43. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Closer Link of Plan Design to Retirement Readiness
  • 44. Copyright© Fiduciary Benchmarks All Rights Reserved v2 Improvement: Closer Link of Plan Design to Retirement Readiness
  • 45. Copyright© Fiduciary Benchmarks All Rights Reserved Versus Cost Drivers Value Factors Quality of Provider Fees v2 Improvement: Much Greater Emphasis on Value Components 44
  • 46. Copyright© Fiduciary Benchmarks All Rights Reserved This material has been prepared solely for informational and educational purposes. It is not intended to provide, and should not be relied upon for, investment, accounting, legal or tax advice. www.fiduciarybenchmarks.com 5335 Meadows Road, Suite 210  Lake Oswego, OR 97035  866.516.4909 45