Insights for the evolving Retirement Industry

Offering timely updates and insights on the retirement industry for service providers, plan sponsors, and registered investment advisors. 

Alternative Assets (25)—DOL Proposal and the Six Defined Factors: The Liquidity Factor (4)

The DOL’s proposed regulation on selecting investments, including alternative assets, 2026-06178.pdf, identifies six factors that should be considered in the process of selecting any investments for participant-directed plans, such as 401(k) plans and private sector 403(b) plans. The six factors are: Performance, Fees, Liquidity, Valuation, Performance Benchmark, and Complexity. The proposal describes each of those factors and provides 20 examples of their application. In earlier posts, I covered four of the factors—Performance, Fees, Performance Benchmarks and Complexity, and their examples. In my last three articles, Alternative Assets (22), Alternative Assets (23) and Alternative Assets (24), I looked at the Liquidity factor and the first two examples of the application of that factor.  This article looks at the third example: (3) Example. Plan-level liquidity— (i) Facts. Plan terminations, changes in plan recordkeepers or investment providers, and corporate sponsor mergers and acquisitions are examples of circumstances that may impose relatively short-term liquidity demands on a plan’s designated investment alternatives. This is especially true in the case of a designated investment alternative (such as a pooled investment vehicle) with a strategy involving a target position in certain private assets along with public assets (e.g., publicly traded securities). With such designated investment alternatives, a

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