How to Address Retirement Income in Investment Policy Statements

Recently, the US Department of Labor (DOL) turned its attention to the adequacy of a retirement plan participant’s account balance, stimulating two debates about how to improve participant outcomes.[1] The first debate concerns how to help participants measure their “retirement readiness” in terms of income replacement at retirement. The second centers on whether there are retirement income-oriented investment strategies that can serve participants better than traditional strategies, which typically focus on capital accumulation.

How Did We Get Here?

In 2010, the DOL noted that defined contribution (DC) plan sponsors offer no promise about the adequacy of a participant’s account balance at retirement or of the available income stream, and that DC plans typically only make lump sum distributions available. Then, in 2013, the DOL expressed its intention to pass regulations that would require DC plans to describe participants’ total benefits accrued, including a projected account balance at their normal retirement age and a lifetime income stream illustration. The proposed regulations would also require DC plans to provide methodologies for calculating these benefits.

With respect to the first debate, a variety of tools and services are currently available to measure retirement readiness at the plan level. Some also allow measurement of individual participant retirement readiness, requiring advisors to work one-on-one with participants to evaluate their retirement income needs, projected retirement income based on current resources and contribution rate, and any increase in plan contributions necessary to address any shortfall.

Regarding the second debate, plan sponsors and their advisors should consider measures to address participant retirement readiness and investment options that provide some measure of guaranteed retirement income. Nothing requires plan sponsors to adopt any of these concepts, but from a best practice perspective, these opportunities bear consideration.

Making IPS Changes

For fiduciaries, care should be taken to ensure conformity with relevant prudent practices. Specifically, advisors and plan sponsors should consider evaluating what changes are required to the Investment Policy Statement (IPS) whenever making changes to the nature of services or investment vehicles that will be used by a plan sponsor or offered to participants. The advisor and plan sponsor client should consider adopting IPS provisions appropriate to the new products and services and income-focused investment options to be included in the investment menu.

Benchmarking Progress

The S&P Shift to Retirement Income and Decumulation (STRIDE) Indices combine a target date glide path with a new risk management framework to serve as a benchmark for investors saving to fund consumption in retirement, reflecting a transition from wealth creation to inflation-adjusted retirement income. As such, they can be used to evaluate target date retirement income strategies that follow a liability-driven investing philosophy. The S&P STRIDE Indices also include a monthly cost of retirement income for each retirement cohort, which can be used to translate account balances to estimated retirement income. By using the S&P STRIDE indices as a benchmark, those who adopt retirement income provisions into an IPS receive an appropriate yardstick against which they can gauge their progress.

The challenges facing a DC plan participant are complex, dynamic, and multi-faceted. Solving these challenges begins with plan sponsors, consultants, and advisors who must develop a sound IPS and enable a framework that manages the risks participants face.

[1] See the DOL’s advanced notice of proposed rulemaking (ANPRM) on lifetime income illustrations: Pension Benefit Statements, 78 Fed. Reg. 26727 (proposed May 8, 2013)


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