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Picking 401(k) Investments and Related Services Is Easy When Fiduciaries Know Their Options

Eric Droblyen

January 5, 2023


When a small business sponsors a 401(k) plan, several investment-related decisions must be made by fiduciaries. Dramatically different fees and expenses can result from this decision-making, so fiduciaries should know their options in order to make “prudent” decisions on behalf of plan participants – an obligation under ERISA. Otherwise, personal liability can result.

Fortunately, prudent 401(k) investment decision-making does not need to be difficult or time-consuming. All 401(k) plans require just two basic investment decisions:

  • Pick a fund lineup and
  • Choose the nature of participant investment advice to offer.

These important decisions can be simple to make when plan fiduciaries know their options.

ERISA responsibilities related to 401(k) investment decision-making

Plan fiduciaries have 2 primary ERISA responsibilities when making 401(k) investment decisions - a) pick funds that allows participants to sufficiently diversify their accounts (and minimize the risk of large investment losses) and b) ensure participants only pay reasonable fees and expenses for investments or investment-related services.  

Pick a fund lineup

There are literally thousands of 401(k) investment funds available. All of these options can make investment selection overwhelming for many plan fiduciaries. It doesn’t need to be. ERISA has very basic diversification requirements and fund selection can be easy when simple benchmarks are used to qualify funds.

  • 404(c) diversification requirements – plan fiduciaries want to pick a fund lineup that meets ERISA section 404(c) diversification requirements. Why? Because when all 404(c) requirements are met, plan fiduciaries are relieved of liability resulting from participant investment losses.

    • To qualify for 404(c) relief, a fund lineup must include at least 3 core options with materially different risk and return characteristics. Generally, a lineup that includes equity (stock), fixed income (bond), and capital preservation (money market or stable value) funds satisfies this requirement.
    • A 401(k) fiduciary can pick additional funds, but they are not obligated to do so to meet ERISA diversification requirements.

  • Index funds as a benchmark for fund selection. For decades, actively-managed mutual funds were the most popular type of investment used by 401(k) plans. Actively-managed mutual funds employ portfolio managers to attempt to select stocks that beat market benchmarks like the Standard & Poor’s 500.

    Recently, however, passively-managed index funds have grown increasingly popular. In contrast to actively-managed funds, Index funds try to track (not beat) the performance of a particular market benchmark—or "index"—as closely as possible. Generally speaking, index funds are less expensive than actively-managed funds.

    If a 401(k) fiduciary prefers actively-managed funds, hiring a professional financial advisor is highly recommended. It takes a lot of skill to consistently pick actively-managed funds that outperform their index fund counterparts. Using actively-managed funds also requires much more sophisticated monitoring to ensure investments outperform their index benchmarks.

    I like to consider index funds a baseline for 401(k) investments – participants should never earn less than index fund returns. Further, fiduciary liability can result if high-priced actively managed funds underperform their lower-priced index fund counterparts. Click here to view an example of a low-cost index fund lineup.

Choose the nature of participant investment advice

Participant investment advice is important. An Aon Hewitt study found that median investment returns for 401(k) participants using Target Date Funds (TDFs), managed accounts and personal investment advice were 3.32% greater than returns earned by participants that picked an investment portfolio themselves. In short, professional advice is proven to help participant investing success.

Generally-speaking, there are two ways 401(k) plans provide investment advice to participants today:

  • Fund-based – a TDF family is added to a fund lineup to give participants access to professionally-managed investment portfolios. Participants can then invest 100% of their account in the TDF that best matches their estimated retirement date.
  • Advisor-based - A professional financial advisor is hired to either 1) construct custom TDFs or TRFs or 2) give one-on-one investment advice.

Both approaches have merit. While the fund-based model is generally less expensive, the advisor-based model can help increase 401(k) participation via more personalized advice.

Don’t be confused - know your options!

I meet a lot of plan fiduciaries confused about the investment decisions they need to make for their 401(k) plan. I get it. There is a dizzying array of 401(k) investments and services available. However, this process doesn’t need to be overwhelming. The key for fiduciaries is breaking this process into its two basic decisions and knowing the options for making these decisions.

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