A four part series that will address important themes of plan management
Last installment we tackled the first 4 letter “F”, fund as in mutual funds. This entry will examine the next 4 letter “F” – Fees. Fees and funds go hand and hand as every dollar that you pay in fees lessen the dollars available for retirement. However, I must disclose that I do not believe that cheapest is best and to date, there are not any federal regulations that state your plan has to be the cheapest. What the regulations do state is that as a fiduciary to your company’s retirement plan you have a duty to understand and monitor the fees associated with operating the plan.
The first fee to consider when analyzing the overall cost of your plan is the mutual fund expense ratios. On http://www.morningstar.com an expense ratio is defined as the annual fee that all funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for fund expenses, including 12b-1, management fees, operating costs, and all other asset-based costs incurred by the fund. Let’s breakdown each component by first looking at the 12b-1 fee. A 12b-1 fee is earmarked for the financial professional’s compensation and can range from 0.25% up to 1.00%. It should be noted that not all mutual funds have a 12b-1 fee. If you work with a financial professional that is fee-based or fee for service, then that adviser may select funds that do not pay a 12b-1 fee since he or she does not rely on that fee for compensation. The information on how much each fund in your plan pays in 12b-1s should be accessible through the fund prospectus. Next management fees and operating costs are the portion of the expense ratio that is used to compensate the mutual fund manager for his or her expertise in running the fund and for any costs the mutual fund company incurs in managing the fund (producing prospectuses, mailing costs, building costs, etc). This is typically the largest portion of the overall cost of the fund and is usually higher in actively managed funds than in passively managed funds. Finally there is the mysterious “all other” portion. In the retirement space the “all other” can be especially important since many times this is referring to the recordkeeping service fees (RSFs) or subtransfer agents fees (subTA) that are paid to the recordkeeper of your 401(k) plan. In general both the RSF and subTA fees are paid by the mutual fund to the recordkeeper for keeping all the individual records of its investors; in the retirement plan space that means all of your participant’s records on their individual investments. The tricky thing about these fees in particular is that they are negotiated between each recordkeeper and each mutual fund; therefore they are not consistent or readily disclosed. For example, ABC mutual fund may pay DEF recordkeeper 0.15% in an subTA fee, but ABC fund might also pay GHI recordkeeper 0.10% in a subTA. While the RSF or subTA fee may not be the largest portion of the overall expense ratio, it can be very important to understand the next aspect of your overall retirement cost and that is the cost associated with your recordkeeper and third party administrator (TPA).
In February 2012, the Department of Labor issued its final regulations on plan level fee disclosure under section 408(b)(2); now simply known as the 408(b)(2) disclosure. The very simplistic explanation over the 408(b)(2) regulation is that it was designed to disclosed to the plan sponsor the cost of doing business with covered service providers (CSPs) including recordkeepers and TPAs. While it did help to uncover some hard dollar fees and the formulas for calculating compensation, it is still fairly difficult in some cases to truly understand what you are paying to whom. If you work in a bundled arrangement, where the same provider serves as your recordkeeper and TPA, then chances are that the subTAs or RSFs that they are receiving from the mutual funds may cover all costs associated with administering the plan; resulting in a $0 hard dollar billable to you the plan sponsor. These plans are sometimes sold as “free” because there is not a hard dollar cost; however, you know now know that the plan is not in fact “free” but rather that the cost is being subsidized by the money received from the mutual funds. If you are working in an unbundled arrangement where there is a separate firm providing recordkeeping services and another providing TPA services, then you may experience a bill from your TPA and “free” services from the recordkeeper. Again, note that the recordkeeper may be receiving money from the mutual funds to cover their costs. Also, in many cases the recordkeeper may be sharing revenue with the TPA in order to help lessen their billed fees to you. If as a plan you are currently receiving any billable expenses that you pay from the company or pass on to your participants to pay, then chances are the mutual funds in your plan have no or low subTAs or RSFs that do not cover the entire cost to run the plan.
The final cost to understand is what you are paying your financial representative. He or she may receive the 12b1 from the mutual fund if you are not in a fee based arrangement. Please note that if compensated by a 12b-1 fee, then his/her compensation is determined by the share class of mutual fund in your plan. In general an A Share fund pays 0.25% and an R share pays 0.50% (there are other share classes, but these are the most common in retirement plans). If you are in a fee based arrangement with your representative, than he/she may charge a flat hard dollar fee or an asset based charge (0.25% of plan assets). There is not a right or wrong way to compensator your financial professional for their time, but like all of the other fees that we have discussed it is just important that you understand how they get paid.
One of my favorite business quotes is “Cost is only an issue in the absence of value.” and this is especially true as it pertains to your company’s 401(k) plan. As I said in the outset, you don’t necessarily have to have the cheapest plan, but you do have to be able to demonstrate that you understand what you are paying and what you are getting for those dollars. If you are unsure of what you are paying any of your vendors or if those costs are reasonable, then please contact me. We are happy to help you answer this “What the “F”?”!
Investments are subject to risk, including the loss of principal. Because investment return and principal value fluctuate, shares may be worth more or less than their original value. Some investments are not suitable for all investors, and there is no guarantee that any investing goal will be met. Past performance is no guarantee of future results. Talk to your financial advisor before making any investing decisions.
Please consider the investment objectives, risks, charges, and expenses carefully before investing. The prospectus, which contains this and other information about the mutual fund, can be obtained from your financial professional. Be sure to read the prospectus carefully before deciding whether to invest.
Jamie Kertis, AIF®, QKA
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162