Tag: fee disclosure

401k plan fees – Do you know what they are?

I joined Martin Financial Group recently to work with businesses on their company sponsored retirement plans. I specifically have worked with many businesses on varied aspects of their 401k plans at my prior employer. This blog post is specifically geared towards business owners, plan sponsors, trustees, and people involved in human resources. Many 401k plan participants may be curious how 401k fees work on a plan as well.

My goal is to write a series of blog posts that will help you understand 401ks better and hit on topics that are relevant and important to employers and employees. Martin Financial Group’s goal is to make your organization’s retirement plan more effective, efficient, and align with your organization’s overall objectives. We are happy to help pull, review, and analyze your plans current fee disclosure.

When working with plan sponsors, I ask if they know the fees they are paying. Many times the plan sponsor can tell me the amount the business pays in hard dollar fees to the recordkeeper and the third-party administrator. What the plan sponsor typically doesn’t know or is unfamiliar with is the internal expense of the 401k plan. Typically, where you find these internal expenses is on a document or documents called a 408(b)(2).

What is a 408(b)(2)?

The 408(b)(2) should be received by the plan sponsor from each service provider who is receiving payment from the company’s 401k plan.

A “payment from the plan” means that the fees are being collected from the plan participants. Service providers can include advisors, recordkeepers, third party administrators, custodians, auditors, and anyone who provides a plan service. Employers might only receive disclosures from providers that are paid out of the plan and not necessarily from providers that they make a hard dollar direct payment to.

What is a 404(a)?

The 404(a) is a document that is distributed to participants and is intended to give plan participants a better understanding of the costs associated with the 401k so they can make more informed investment decisions. It typically does not lay out any specific asset based fee or any admin costs that are passed on to the plan.

Parties typically compensated by a 401k

  • Third Party Administrator- Usually a flat dollar amount plus a variable per head fee or sometimes a percentage of assets paid from the recordkeeper. Ex. ($1000-$5000)
  • Recordkeeper– Can be a % of assets fee, some providers are a flat fee plus a per participant fee,  or some also get compensated within the investments Ex. (A 1,200,000 plan with a .5% asset fee is $5000)
  • Investments- Different share classes have different fees. If sold by a broker the broker could be paid out of the investments. The same fund could range quite a bit depending on the share class. Ex. (American Funds Balanced R1- 1.37%, American Funds Balanced R6- .28%)
  • Advisor- Can be paid by the 12-b1 in the investments or if a fee based advisor it can be pulled separate. Ex. (Typically .25%-1.5% of the assets in the plan)
  • Fidelity Bond- A fiduciary bond provides insurance protection against the possibility of fraud or embezzlement by a fiduciary Ex. ($100-$300)

It’s worth pointing out that there are two methods used to collect service provider fees from participants. Some plans remove fees directly from a participant’s account. Such fees are transparent, making it easier for plan sponsor and participant alike to measure service value. However, some plans use a “revenue-sharing” method where the fees are removed from the participant’s investment returns before they become a part of the participant’s retirement account. Such “hidden” fees are not reported in a participant’s quarterly plan statement, are difficult to identify and have led some plan participants and plan sponsors to believe their retirement plans are free. I’ve outlined where the fee components are usually taken from in the section below.

Where do we find this 408(b)(2) document?

Typically, a good starting point is on the recordkeepers plan sponsor website (ADP, VOYA, John Hancock, Fidelity, Principal, etc.). This would be labeled as the plan fee disclosure or 408(b)(2). You can also request them from your financial professional.

Employers must comb through the 408(b)(2) documents in detail to first understand the services being provided and whether the service provider or the financial professional is a fiduciary. Service providers or financial professionals acting as fiduciaries must specifically state that they are doing so. If a provider is silent regarding fiduciary status, it is not a fiduciary.  

Fee components on a 401k plan usually include:

1. Take-over or conversion fees—Employer
• A one-time expense
2. Investment management fees—Participant
• Charge by money manager
• Asset-based charge
3. Administrative fees—Employer or Participant
• Annual fees for recordkeeping services
• Base fee and/or per-employee cost
• Asset-based charge
4. Transaction fees—Employer or Participant
• Activity-based charges—loans, distributions
• Dollar amount per transaction
• Asset-based charge
5. Insurance features—Participant
• Mortality and expense-risk fee
• Asset-based charge
6. Direct or indirect fees—Employer or Participant
• 12b-1 fees
• Advisory fees

 

Therefore the 408(b)(2) can be a long document that is not the easiest to understand. Understanding and compiling your plan fees from the 408(b)(2) and fees paid hard dollar can be confusing, but it doesn’t have to be with our experience and knowledge. A proper review of a plan’s provider disclosure report by a fiduciary can result in plan improvements to the benefit of business and the participants.

Martin Financial Group acts as a fiduciary on our clients 401k plans, discloses all fees, and can help you comb through your current provider to meet your fiduciary duties on benchmarking and reviewing the fees on the plan. You can read more about fiduciary responsibilities on the Department of Labor website . If you’d like help with your 401k or retirement plan, click here.

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