This is my second article about the interesting observations “hidden” in the preambles to the fiduciary regulation and the exemptions. The recommendation of investments and insurance products to plans, participants, and IRAs will be subject to the best interest standard of care. (The best interest standard is a combination of
While you have probably read articles that summarize the DOL’s final fiduciary rule and exemptions—and perhaps even articles that discuss specific aspects of the rules, there are a number of interesting observations “hidden” in the preambles to the regulation and exemptions. In many cases, those comments are so focused on
A reporter recently asked me to explain why people are saying that, under the DOL’s fiduciary proposal, an adviser should not recommend that a participant take a distribution and roll over to an IRA, but instead should provide distribution education. Here’s my answer: There are two issues. The first is
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This is the second article in our series on navigating retirement risks, based on our White Paper, Creating Sustainable Retirement Income in 401(k) Plans Using Managed Risk Funds (www.milliman.com/new401k). The first article addressed how long a 401(k) participant will need his retirement money to last. We also discussed how market
Insurance guarantees for retirement benefits — such as annuities, QLACs, and GMWBs—are increasing in popularity . . . because they guarantee that the money lasts for a lifetime. However, there is not much guidance about the fiduciary process for selecting a particular annuity or GMWB product to provide those guaranteed
I recently wrote an article for JP Morgan about the fiduciary process for implementing investment policy statements . . . with particular emphasis on the monitoring of investments and investment managers in participant-directed plans. The article outlines a step-by-step approach for identifying investments to be placed on a watch list,
American workers are living longer. But a long life has its risks . . . especially the risk that retirement savings won’t last. Bruce Ashton and I have written an article about the sequence-of-returns risk created by market volatility (based on a white paper that Bruce Ashton and I wrote
In Advisory Opinion 2013-03A, the Department of Labor said: “This letter also does not address any fiduciary issues that may arise from the allocation of revenue sharing among plan expenses or individual participant accounts . . .” In effect, the DOL was saying that it has not issued any guidance—and
The ABB case has been thoroughly analyzed and widely discussed. Most of that analysis and discussion, though, has been about expenses and revenue sharing. This email focuses on the duty to follow the terms of investment policy statements (IPS). More technically, section 404(a)(1)(D) of ERISA requires that fiduciaries follow the
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