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Automatic Enrollment and Qualified Default Investment Alternatives: Are They Right For Your Plan? Our Analysis Indicates They May Be Best For Both Plan Sponsors and Participants …And Eligible EmployeesBy Great-West Retirement Services At the request of many of our plan sponsors, this issue of Focus on 457 addresses three questions:
The Pension Protection Act of 2006 (PPA) provided guidelines for automatic enrollment and automatic deferral increase features for ERISA plans. While governmental plans are not subject to ERISA, you may wish to adopt the PPA standards as a best-practice guide for plan governance. The provisions for Automatic Enrollment and Qualified Default Investment Alternatives (QDIA's) in the PPA have prompted many governmental plan sponsors to take a closer look at all three of the questions above. Executive Summary of Our Findings Question #1: Is Automatic Enrollment a good idea? Our Conclusion: Automatic Enrollment is arguably the single most important action you can take as a plan sponsor. Most plan sponsors spend a considerable amount of time evaluating the plan investment options made available to participants and the individual performance of each of the funds. Studies have indicated, however, that individual fund performance is one of the least important variables in determining retirement wealth for plan participants. 1 One of the more recent studies on this topic concluded that the five most important factors in accumulating retirement wealth rank as follows in terms of their impact on retirement wealth accumulation: 2
Although individual fund performance is important, the Putnam study, as well as a number of others, concluded that the other four factors have a more significant long term impact on retirement savings accumulation. With deferral (saving) rates ranked as number one, it stands to reason that getting employees enrolled in the plan is essential. Automatic enrollment with automatic deferral increases accomplishes two things:
Since plan participation and deferral rates are the most important factors in determining long term retirement savings, automatic enrollment with automatic deferral increases is the single most important step you can take to help employees save for retirement. While the other four elements listed above are important, they are not as important as deferral rates over the long term. 3 Question #2: Which Qualified Default Investment Alternative (QDIA) has the greatest chance of helping participants in the long run? Our Conclusion: Managed Accounts. The proposed Department of Labor (DOL) regulations identify three Qualified Default Investment Alternatives (QDIA's) for plans with an Automatic Enrollment program:
Our findings (as summarized in the table below) indicate that managed accounts provide the best long term opportunity for the participant for three primary reasons:
The table on the following page summarizes the key elements of each QDIA and explains why managed accounts are likely the superior choice. We invite you to read the full analysis of this important topic in the background section of this document.
Question #3: Should you change your default investment option even if you do not offer Automatic Enrollment? Our Conclusion: If your default investment option is a fixed fund or a money market fund, it is time for you to take a serious look at the alternatives. Every plan sponsor knows that it is not a good idea for participants to invest all of their retirement savings in a fixed-income fund for their entire working career. Yet, when participants are defaulted into a fixed-income or money market fund, the vast majority of participants do not reallocate those amounts for a very long period of time, if ever. Studies show that most participants never make regular changes to their investment options or rebalance their funds.4 A large number never make any change at all. Inertia takes over and many participants are stuck in a fund that is too conservative. It is time to make inertia work for plan participants and not against them by changing your plan's default option to an asset allocation fund, target-date fund, or better yet, managed accounts. Even if you are not considering adding Automatic Enrollment to your plan, reconsidering your current default investment option may be wise. We invite you to read the following in-depth discussion of how we arrived at our conclusions. Automatic Enrollment Programs Are Easy to Implement In Some States But Not In Others As described in the August 22, 2006 edition of Focus on 457, (http://www.fascore.com/PDF/gwrs/Aug2006_22_457.pdf) the PPA provides guidelines for plan sponsors wishing to offer automatic enrollment with automatic deferral increases to their employees. A number of governmental plan sponsors are already planning to add such a feature. In some states, governmental plan sponsors may offer automatic enrollment without employee consent. Some state laws, however, prohibit employers from deducting any amount from an employee's paycheck unless employee consent is obtained. As of the date of publication of this issue of Focus on 457, the situation in each state may be summarized as follows:
Minimum wage laws are an issue in Arkansas, Massachusetts and the District of Columbia. Legislation has already been signed into law in Indiana and Virginia amending state and local governmental payroll statutes or anti-garnishment laws. Indiana's automatic enrollment program is effective July 1, 2007 and the Virginia program is effective January 1, 2008. Similar legislation has been proposed or is being reviewed in some other states. Alaska has an exemption for the automatic enrollment feature of its new mandatory defined contribution plan implemented in 2006. Many employers in the states where the current law requires employee signature before amounts may be withheld from their paychecks are asking employees to sign a consent form on the first day of work as part of their orientation package. This allows the employer to implement an automatic enrollment program while the state laws are being reviewed and revised. Qualified Default Investment Alternative (QDIA) Employers wishing to take advantage of the fiduciary protections provided by the PPA must select a "Qualified Default Investment Alternative" (QDIA) for the investment of contributions for participants who do not specify an investment option. Nearly all defined contribution plans have a "default investment option," normally a fixed account, a money market fund, or another conservative investment option designed to preserve principal. Under the proposed DOL regulations, however, a QDIA may not be a fixed account or money market fund, but rather must be:
The exclusion of fixed accounts and money market funds sends a clear signal that participants should be encouraged to be in a well-diversified, professionally managed investment arrangement. At the time of this writing, the DOL has yet to finalize the QDIA regulations, due mainly to the unusually large number of comments received from concerned taxpayers. It is not surprising that a number of the comments are from fixed-income investment providers who want fixed-income options included as a QDIA. The comments on QDIAs in this edition of Focus on 457 are relative to the requirements as we currently understand them 6 , although they may be modified by the DOL when the final regulations are issued. If a governmental plan sponsor offers automatic enrollment, one of the three QDIA options should be considered as the default investment option. In fact, using a QDIA is a best practice for governmental plans without an automatic enrollment feature. Which QDIA is Best For Your Plan? The most appropriate QDIA for your plan will depend on a number of factors, including your overall strategy for providing participants with professional investment management alternatives. The following discussion of the three types of QDIAs explains how they compare to one another. Balanced Funds Of the three QDIA options available, the balanced fund option is generally viewed as the least "personalized" when compared to the other two (target-date funds or managed accounts). A balanced fund may not be the best default option, however, because it is a "one size fits all" solution that may be inappropriate for participants as their only long-term asset management solution. A balanced fund is a relatively static mix of stocks and bonds, or stock and bond funds in the case of a balanced "fund of funds". In nearly every instance, a balanced fund is too conservatively managed for younger participants while being too aggressive for participants nearing retirement. Because the fund is managed the same way for a 25 year old participant as it is for a 60 year old participant, the best that can be said is that overall, the fund is inappropriate for the average participant. While balanced fund managers argue that a diversified, pooled fund is the same concept as managing a large pool of assets supporting a defined benefit plan, the comparison is flawed in two key areas. First, in a defined benefit plan the plan sponsor bears the investment risk so the participant is not affected by the actual performance of the fund. This is not the case in a defined contribution plan where the participant bears the investment risk. Secondly, the balanced fund manager must ultimately wrestle with accurately defining the primary investment objective of the fund during the investment phase: whether assets are to be invested primarily for younger participants with a greater tolerance for risk, or primarily for the benefit of older participants nearing retirement. It would be impossible to develop an investment policy for a single "balanced" fund that serves both constituents. In theory, the balanced fund manager must determine the risk level and portfolio composition that he or she deems consistent with the profile of the plan as a whole. Managing one fund that is intended to serve all participants equally regardless of age, risk tolerance or individual circumstance would be a difficult task. One of the arguments in favor of balanced funds is that they are less expensive to operate than asset allocation funds or managed accounts. This may or may not be accurate, but in any event, any comparison of fees alone would be very misleading. You should compare historical yields of the various alternatives, along with the fees charged to operate them. Finally, some proponents of balanced funds as the QDIA indicate that it is the simplest alternative and thus a good choice for plan sponsors preferring limited involvement in the QDIA selection and management process. This would be particularly true if a pre-packaged balanced fund was selected. They argue that participants who want to diversify investments will make their own selections. The primary problem with that logic is that the majority of participants never move their money out of the default investment option. If that is the case, you need to carefully consider whether a balanced fund is the most appropriate default investment option for participant funds knowing that the money may remain in that fund for decades, and that balanced funds do not take the individual's circumstances into account. Target Date (or Lifecycle) Funds Aside from their use as a QDIA, target date (or "lifecycle") funds are being heavily promoted by firms that offer such funds, and by some consulting and investment management firms. Some proponents have declared them the latest "must have" type of fund for defined contribution retirement plans. In case you are not familiar with the concept, here is how they work:
Target-Date Funds Are Not New Target-date funds are not new. Mutual fund companies have been offering them for years, and some have a history of 10 years or more. The concept is very similar to "risk-based funds" which are tailored to the degree of risk selected by the participant. For example, a collection of risk-based funds generally consists of five: conservative, moderately conservative, moderate, moderately aggressive, and aggressive. In some cases, the plan sponsor has simply opted for three risk-based funds (aggressive, moderate, and conservative). The main difference between risk-based funds and lifecycle funds is that the investment allocation of the risk-based funds remains static over time. If a participant decides their risk tolerance has changed, they must select a different risk-based fund. For target-date funds, the allocation changes over time, as participants in the fund age. An Old Concept That May No Longer Be Relevant For Many Participants The underlying premise (that a participant should invest more conservatively as they age) is the very foundation of target-date funds. It is an old concept and one that (in theory) is sound if you want to reduce your risk of loss as you get closer to needing your money. The problem is, for our contemporary society and, in particular government employees, it is a concept that may not only be outdated, but actually counterproductive. A "one size fits all" fund for everyone who is the same age (or within the same age range) can never take into account personal lifestyle differences, post-retirement or second-career plans, survivorship needs, or even something as simple as the retirement income of their spouse or partner, or their difference in age. Collective management of a group of people with similar ages might have worked well in the 50's and 60's when the work force was more homogeneous and "retirement" was more traditionally defined. Today, the period following employment may not even be a traditional "retirement". Many workers have plans for a second career or have income from other sources (such as a pension from a governmental employer). In many instances, these employees do not need their defined contribution funds immediately when they stop working. Or, if they do, perhaps they use some of these funds for lifestyle adjustments and keep the remaining funds invested. With greater longevity, many "retirees" may expect to live for as long as 20 or 30 years. Even the word "retirement" is no longer a relevant term for many who stop working in one career and then move to another during a later stage of life. We also know, from our own research and that conducted by others, that not everyone of the same age has the same risk tolerance or investment objectives. To the contrary, we found that employees of the same age grouping could have dramatically different investment, lifestyle, and risk tolerance objectives.7 Some studies have strongly challenged the age-risk correlation and categorized individuals by generation.8 Other studies found a closer correlation in classifications such as single, young families, baby boomers and pre-retirees.9 Therefore, the correlation between age and other lifestyle elements is just simply not precise, and in many cases, quite inaccurate. When you consider that the age-risk issue is the basic premise of target-date funds, it is unsettling, at best, because the correlation upon which it is based is largely inaccurate in the contemporary workforce. It is a premise that simply isn't true for most people. Target-Date Funds May Be Even More Inappropriate for Government Employees If you are a governmental plan sponsor considering target-date funds, the first fact you have to deal with is that virtually all the "pre-packaged" target-date funds from the mutual fund industry were created for the corporate sector. In particular, they were designed for the individual investor and the corporate 401(k) market. Why is that something you should be concerned about? There are several reasons:
Pre-Packaged Funds: Guess What You'll Find? You see them advertised all the time on national television, in magazines and newspapers. They have catchy names, and are made attractive in glossy advertising campaigns that cost millions. These pre-packaged or "off the shelf" target-date funds, some of which have ten years of history or more, are heavily promoted. While these funds are easy to implement there are some important considerations worth noting before a plan sponsor deems them appropriate for their plan:
This should be a concern to you unless you have chosen to use a bundled, proprietary plan design platform with recordkeeping and funds from one vendor. The majority of governmental plan sponsors, particularly larger plans, however, prefer the unbundled, open-architecture platform allowing them to select investment offerings on a "best of class" basis, with no preference for any particular fund manager. Every fund is selected on its own merits, based upon the plan's investment criteria. Selecting a pre-packaged series of target-date funds undermines the open architecture approach to fund selection. Here's why this can be problematic:
Finally, if you elect to use target-date (lifecycle) funds be sure you understand how the funds are constructed, and what the fund management policies are. One recent article published by JP Morgan Asset Management said that standard fund industry assumptions are oversimplified in managing target-date funds and in fact are fatally flawed when compared to actual participant behavior.10 The JP Morgan report says that the underlying assumptions in many target-date funds do not reflect actual spending and saving behavior of the participants in the funds, particularly since the report says that participants contribute less, borrow more, and have less in salary increases than assumed by the managers of the funds. It claims that the funds are missing the mark in providing retirement security to those who need it most. The point is that not all target-date funds are managed the same, and before a plan sponsor selects these funds as their QDIA, they have to know much more about them. Fiduciary Liability Implications If a plan sponsor selects a vendor to provide managed account services to their participants, that vendor is a fiduciary with respect to the managed account advice service. The vendor assumes fiduciary responsibility for the managed account or investment advice service for all participants who elect that service. The only fiduciary protection offered plan sponsors who choose to use pre-packaged target-date funds is through the QDIA regulations. The fiduciary liability issue is but one factor that should be evaluated when selecting target-date funds in addition to or in lieu of managed accounts or investment advice services. What About Custom Target-Date (Lifecycle) Funds? Larger plan sponsors can elect to establish their own custom target-date asset allocation funds rather than buying pre-packaged funds. If your plan is large enough to economically and administratively offer custom funds, they do have some advantages:
Carefully Consider the Motivation From Potential Vendors, and Who Has Liability for What Services As discussed at the opening of this article, target-date funds are the current hot topic in the defined contribution market. Some professionals think they are a key ingredient for a successful plan, while others think they are a passing fad that is fraught with problems, or may actually be counterproductive. The desirability of such funds to a mutual fund or investment manager who receives fees for managing them is obvious. The fees paid to lawyers and investment managers or consultants for custom target-date funds may not be so obvious. Many investment managers and consultants can provide asset allocation and rebalancing-management services for custom target-date funds. If you are going to pay a fund manager to manage your custom target-date funds, you need to carefully consider how many participants will benefit from this service and how it will be paid for. One reason more and more plan sponsors are opting for managed account services is because only those participants who use the service pay the fees. While some plan sponsors have made it mandatory to participate in managed account services, virtually all of them offer an "opt-out" feature. This makes the overall fee structure for a managed account program more equitable than spreading the costs of the target-date funds among participants who have not elected to use these funds. Finally, make sure that you, as the plan sponsor and your target-date fund manager understand your respective responsibilities. The target-date fund manager is responsible for, among other things, determining the asset allocation in each target-date fund as well as determining when and how often to rebalance the portfolio. In addition, the target-date manager is responsible for determining when and how each portfolio should be adjusted as the participants in that fund begin to age and become closer to the target-date of the fund. Sometimes this process is called the "glide path" to adjust each portfolio over time. In addition to hiring and evaluating the fund manager for any custom target-date funds, the plan sponsor should also determine key policy questions such as:
Target-Date Fund Management: Conflict of Interest or an Economic Convenience? Many consultants or potential target-date fund managers are quite objective in pointing out the above risks and benefits. Some firms will offer to provide overall investment consulting services or target-date fund management services, but not both. Others will agree to, or prefer to, do both. It is up to you to determine which is most appropriate for your plan when custom funds of any type are involved. Some plan sponsors have taken the position that a plan consultant who recommends the use of custom target-date funds (or any particular investment option) can not then be used to manage such funds because of a potential conflict of interest. The issue may become more complicated if you use the same consulting firm to evaluate all core investment options as you use to manage the asset allocation funds. Some plan sponsors have not deemed it appropriate for the same consultant who evaluates the core funds to also evaluate their own performance on the target-date funds. Their position stems from the question whether you would let one of your investment managers evaluate their own performance on a fund they manage. If you take this position as well, then it will likely mean you may need two investment consultants if you offer custom target-date funds - one to evaluate all core options and one to manage the custom target-date funds. On the other hand, some plan sponsors have taken the position that having one consultant evaluate all the funds, and manage the asset allocation funds at the same time are a matter of economic convenience and do not pose a serious conflict of interest. When in doubt, seek the advice of counsel in this regard since it is easier to evaluate your liability before any such conflict arises in a lawsuit or fiduciary action from another party. Despite the issues above, larger plan sponsors will likely prefer to create and manage their own target-date funds, if you choose to offer them at all. Assuming you actively monitor and groom your core funds, you may be able to offer target-date that have lower operating expenses and greater fund diversification than pre-packaged retail funds. Plus, you can be certain that all of the funds in your plan, including the target-date funds, are subject to the same evaluation and screening process. The larger the plan, the easier and more economical it is to offer custom funds of any type. And Finally, A Very Important Point: How Participants Use These Funds Plan sponsors who decide to offer pre-packaged target-date (lifestyle) funds, or create custom funds of your own need to have realistic expectations regarding usage by participants. First of all, you should speak with your record keeper about any administrative or other costs, particularly with custom funds. Then, you should have a candid discussion with your record keeper (or whomever handles your employee communication and education program) about their experience with target-date funds. Our direct experience with target-date funds (a span of over ten years), and managed accounts and investment advice (over more than six years) is summarized below. Overall, Target-Date Funds Have a High Incidence of Improper Use In our own most recent study on this issue involving a major transit agency and a large state plan, we found that only 24% of the participants in the funds were properly using them (target-date funds). The most common forms of misuse are discussed below. We also know that the findings of our study were not unique. Another major record keeper addressed the same misuse issues during their session at the 2006 NAGDCA conference. While every form of asset allocation or investment advice program is subject to misuse, our findings of improper use by over 70% of participants in the funds is very high. Another study by an independent consulting firm found that as few as 6% of participants in target-date funds invested all of their account in a single target-date fund over time. While every situation can be different, here are the most common issues regarding participant usage of target-date funds:
The Managed Accounts Alternative A well-constructed managed account program offers the following advantages when compared to a balanced fund or target-date fund alternative:
Our own research indicates that there are four primary behaviors among plan participants in defined contribution retirement plans:
Based on our own research and focus groups among governmental employees, we have found that about more than half of all plan participants want "someone else to do it for me" when it comes to managing their retirement funds. About 20% can use guidance tools and other market information to "do it themselves" and are likely "knowledgeable investors" to some degree. Another 20% are "validators" who can use tools like investment advice to help them validate or re-in force their decisions. In actuality, we have found that the percentage of "delegators" is higher than the 50% or so who describe themselves as such. When managed account services are available along with investment advice and investment guidance, participants tend to select managed accounts overwhelmingly. In fact, as of the date of this writing, based on our own governmental plans, of the participants who make a selection between one of the three services, 96% select managed accounts, 1.7% select advice, and 2.4% select guidance. However, when measured in terms of assets, approximately 70% of assets are in managed accounts, 13% is in investment advice, and 17% in guidance, which reflects the larger account balances among the advice and guidance participants as opposed to managed account participants, who tend to have smaller balances, at least initially. Interestingly, other studies have found the same behavior classifications among retirement plan participants in their studies. The JP Morgan study referred to earlier classified participants as "40% to 70% are "delegators" - least likely to be actively engaged.12 Another report emphasized the fact that once they make an initial election at enrollment, most participants do not make an additional asset allocation change - "85% of participants are on allocation autopilot."13 Our findings have been similar with fewer than 14% of participants in our governmental plans making a trade or rebalancing their funds in the past 12 months. Finally, when comparing overall plan usage, many plan sponsors with target-date funds find their usage capping out at about 10% of plan assets. A study by an independent consulting firm indicated that usage of target-date funds at the macro plan level has been flat at about 10% for some time and in fact decreased from a high of 15% in 1995.14 Our experience has shown that the misuse of these funds (discussed earlier) is a primary reason for their lack of long term appeal for most plans. To the contrary, plans where the full suite of investment guidance, investment advice, and managed account services have been offered for two years or more, overall usage is at much higher levels than asset allocation funds. What About Fees? As with any other investment option, fees are an important element when considering a QDIA selection. Earlier in this article we mentioned that the balanced fund option may be the least expensive from the standpoint of total fees. Target-date (lifecycle) funds are usually "funds of funds" which means the total fee is a weighted average of the investment management and other fees applicable to the underlying funds, plus any fee assessed on the entire fund to provide the asset allocation, rebalancing, glide path, etc. In some situations where the target-date funds are composed 100% of the fund manager's own proprietary funds, there is no other fee in addition to the fees in the underlying funds. In other situations, particularly for custom target-date funds, the fee ranges from .10% to .40% or more of fund assets to provide the target-date fund management services for each portfolio. When comparing funds, be sure you are looking at a "total" net expense figure that includes all the fees on the underlying funds and fees assessed on the overall fund itself, if any. Managed account programs are usually (but not always) offered as part of a suite of services that includes investment guidance, investment advice, and managed accounts. In most cases investment guidance is free, and it helps the participant select asset class allocations but not specific funds. Investment advice is usually provided for a flat fee of $25-$75 annually and while it does identify specific funds and an asset allocation, the participant must actively elect the funds and rebalance their portfolio on a regular basis. The managed account option permits the participant to have their account professionally managed, in which case the manager selects the funds, automatically rebalances the portfolios and adjusts the mix of stocks, bonds, and fixed funds in the portfolios as required by age, life events or other conditions specified by the participant. On an individual basis, professional fund management can be 1.00% of assets per annum or more if bought on a retail basis from a brokerage firm or investment manager. For corporate and governmental defined contribution plans, fees are usually half the retail rate, or less. In most situations a "full service" managed account program will start at about .55%-.70% of assets per annum and decrease as assets grow. Most firms offer a sliding scale whereby the fee decreases as assets increase, with final breakpoints as low as .20% or thereabouts. In most cases the average participant will be paying about .50% of assets or less, plus the underlying fund management fees. Determining the most effective QDIA on a cost/reward basis is quite easy. Balanced funds and target-date funds publish their returns in a manner that can be easily compared over time. In addition, most managed account providers can give you actual results on how well participants in the managed account block have done compared to participants in the plan who do not use the service. While managed account historical performance may not be as long as balanced funds or target-date funds, there is enough historical data from most providers to permit the plans sponsor to make an assessment of which type of QDIA provides the best historical results in terms of return minus cost. In our own analysis, this information was easy to get and fairly easy to assess over reasonable periods. While there is no guarantee of future performance, the historical comparison is a good place to start. Conclusion We are not against target-date funds. Our intention in this edition of Focus on 457 is to summarize our own experience with all three options (balanced funds, target-date funds and managed accounts) over the past ten years, and the issues to consider before offering any of them, particularly as your QDIA selection. Our own experience thus far clearly indicates that managed accounts have more benefits and fewer drawbacks as a QDIA than target-date funds. Balanced funds have even more problems with a "one size fits all" philosophy than the target-date fund options. This may not be true in every situation, and of course each plan sponsor needs to arrive at their own conclusion on this topic. While there may be reasons to include balanced funds and target-date funds in your investment array, each clearly has disadvantages as a QDIA when compared to managed accounts. Our own experience with these funds and the research we have conducted, as well as research that was done by others referenced herein has led us to a "best practices" model on this subject:
Each plan sponsor must determine which QDIA is best for their plan. As we said at the opening section of this issue of Focus on 457, automatic enrollment, and automatic deferral increase are probably the most significant steps you can take to boost the accumulation of retirement savings assets in your plan. To implement such a program, you must select a QDIA, and while none of the QDIA options is perfect each has unique advantages over the traditional "default investment options" most plans are using today. Please refer to the table in the Executive Summary for a side-by-side comparison of the three options. Footnotes: 1 "DC Plans Missing the Forest for the Trees" by Putnam Investments Strategic Research, February 16, 2007. 2 "DC Plans Missing the Forest for the Trees" by Putnam Investments Strategic Research, February 16, 2007. 3 "DC Plans Missing the Forest for the Trees" by Putnam Investments Strategic Research, February 16, 2007. 4 98.4% of participants don't make regular allocation changes, and 60.4% do not do a fund transfer according to a Great-West Retirement Services study of participants' accounts over a 20-year period (1985-2004). 5 Governmental Plans ok. Some issues may exist for non-governmental, non-ERISA plans in certain states. 6 Published in the Federal Register September 27, 2006 7 Focus group research on investment advice and fund management for government employees, conducted by Great-West and Advised Assets Group, LLC in 2004. Details of this research are available to Great-West clients on request. 8 Center for Retirement Research, "Retirement at Risk: A New National Retirement Risk Index", June 2006 9 MetLife Fifth Annual National Survey, "Study of Employee Benefits Trends". 10 "Ready! Fire! Aim? How some target date fund designs are missing the mark on providing retirement security to those who need it most", by JP Morgan Asset Management, March 2007 11 AIG Study 12 " Ready! Fire! Aim? - How some target date fund designs are missing the mark on providing retirement security to those who need it most" a white paper report by JP Morgan, March 20, 2007 13 Corporate Executive Board Retirement Services Roundtable 2002 14 Hewitt - In Brief - 401(k) Evolution 06/2005 |
