ERISA Retirement Plans: Fiduciary Compliance and Risk Management for Investment Fund Selection and Fee Disclosures

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1 Presenting a live 90-minute webinar with interactive Q&A ERISA Retirement Plans: Fiduciary Compliance and Risk Management for Investment Fund Selection and Fee Disclosures Discharging Fiduciary Duties and Limiting Fiduciary Liability THURSDAY, AUGUST 8, pm Eastern 12pm Central 11am Mountain 10am Pacific Today s faculty features: Lisa H. Barton, Morgan Lewis & Bockius, Pittsburgh Lindsay B. Jackson, Morgan Lewis & Bockius, Washington, D.C. Michael B. Richman, Of Counsel, Morgan Lewis, Washington, D.C. The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions ed to registrants for additional information. If you have any questions, please contact Customer Service at ext. 10.

2 Sound Quality If you are listening via your computer speakers, please note that the quality of your sound will vary depending on the speed and quality of your internet connection. If the sound quality is not satisfactory and you are listening via your computer speakers, you may listen via the phone: dial and enter your PIN when prompted. Otherwise, please send us a chat or immediately so we can address the problem. If you dialed in and have any difficulties during the call, press *0 for assistance. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again.

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4 If you have not printed the conference materials for this program, please complete the following steps: Click on the + sign next to Conference Materials in the middle of the lefthand column on your screen. Click on the tab labeled Handouts that appears, and there you will see a PDF of the slides for today's program. Double click on the PDF and a separate page will open. Print the slides by clicking on the printer icon.

5 webcast ERISA Retirement Plans: Fiduciary Compliance and Risk Management for Investment Fund Selection and Fee Disclosures Presenters: August 8, Lisa Barton Lindsay Jackson Michael Richman

6 Today s Topics Fiduciary Duties for Providers and Sponsors ERISA Fiduciary Duties Plan Governance Roles and Responsibilities Plan Investments Target Date Funds and QDIAs Developments in Fee Disclosure Rules ERISA Section 404(c) Key Case Law Developments 6

7 Fiduciary Duties for Providers and Sponsors 7

8 Statutory Framework ERISA Who is a fiduciary? What are a fiduciary s duties? 8

9 ERISA and the Code ERISA Reason for enactment Sets forth a comprehensive scheme to protect employee benefits Coverage Are plan assets involved? 9

10 Who Is a Fiduciary? Functional test a person is a fiduciary to the extent he or she: exercises discretionary authority or discretionary control respecting management of the plan exercises any authority or control respecting management or disposition of plan assets renders investment advice for compensation with respect to plan assets has any discretionary authority or discretionary responsibility for plan administration 10

11 Who Is a Fiduciary? (continued) A person becomes a fiduciary by: being formally designated as a fiduciary functioning as a de facto fiduciary appointing other fiduciaries default: if a plan administrator is not named, the plan sponsor (usually the employer) is considered to be the plan administrator 11

12 What Are a Fiduciary s Duties? The exclusive purpose rule Avoidance of prohibited transactions The prudent investor standard process is key Diversification Following the terms of the plan 12

13 Plan Governance Process, Process, Process Clearly defined roles Qualified people Well-reasoned decisions 13

14 Plan Governance Roles and Responsibilities Nonfiduciary Roles Settlor (Plan Sponsor) Functions Plan/trust creation, amendment, termination, contributions May wear two hats Ministerial Functions Nondiscretionary actions 14

15 Plan Governance Roles and Responsibilities (continued) Designated Fiduciaries Plan Administrator (Administrative Fiduciary) Designated in the plan document and SPD Responsible for discretionary aspects of day-to-day plan operation (e.g., loans, QDROs) Named Fiduciary (Investment Fiduciary) Designated in plan document or appointed via procedure in plan document Primarily responsible for selection and monitoring of plan investment options 15

16 Plan Governance Dealing with Plan Service Providers Fiduciary duties apply to selection, monitoring, and payment Suggestions for managing risk: Initial due diligence Proper allocation of responsibilities Ongoing monitoring 16

17 Plan Governance Communicating with Participants Plan fiduciaries have duty to: Provide certain disclosures under ERISA Not lie when asked Suggestions for managing risk: Establish procedures for participant communications Include discretion and reservation-of-rights clauses Maintain records of all participant communications 17

18 Plan Governance Claims Administration Benefit claims present heightened risk Suggestions for managing risk: Good plan and SPD language Full and fair review of initial decision Meet all time deadlines Draft denial letters carefully Get deferential standard of review on appeal 18

19 Plan Governance Investment Process Source of most fiduciary litigation Suggestions for managing risk: Seek advice of independent professionals Adopt and follow investment policy statement Meet on regular basis Document all decisions Invoke available ERISA protections 19

20 Managing Fiduciary Liability Process Use third-party service providers and select them carefully Hold regular meetings Take appropriate and detailed minutes Carefully consider all actions; document thought process details Monitor those whom you appoint Review all investment reports carefully Establish appropriate procedures for communicating with participants Engage independent fiduciaries when there are possible conflicts or prohibited transactions Document all claims carefully 20

21 Plan Investments (Target Date Funds and QDIAs) 21

22 Plan Investments: Qualified Default Investment Alternatives Qualified Default Investment Alternatives (QDIAs) Protection from liability for investments made in the absence of participant direction if certain conditions are met Can be very helpful for plans with automatic enrollment or in fund mappings Does not protect from liability for imprudent selection of the QDIA 22

23 Plan Investments: Qualified Default Investment Alternatives (continued) Primary components of QDIA compliance The investment alternative is a QDIA Life cycle or target date funds Balanced funds Managed accounts Not stable value or money market (subject to some grandfathering) The participant had the opportunity to direct the investment, but did not Notice (prior to first default investment and annually) 23

24 Target Date Funds Department of Labor ( DOL ) Released Target Date Fund TIPS in February 2013 Outlines process for comparing and selecting funds Process for periodic review of investments Understanding how the investments will change To or through glide path? Review fees and expenses Inquire about custom or nonproprietary alternatives 24

25 Target Date Funds (continued) Develop effective employee communications Upcoming DOL Target Date Fund Regulations may change disclosure requirements Take advantage of available sources of information Document process 25

26 Developments in Fee Disclosure Rules 26

27 Participant Disclosures Recent 401(k) participant disclosures requirements are held to a fiduciary standard Initial disclosures were required by August 30, 2012 Three categories of disclosures General plan information Plan administrative expenses Investment information Performance Fees and expenses Other investment-related disclosures Some of the disclosures annually; others quarterly Differs from other reporting obligations under ERISA where the consequences for noncompliance are fines, penalties, etc. 27

28 Participant Disclosures (continued) DOL recently clarified timing of annual participant disclosure Initial disclosure required by August 2012 Ongoing disclosures must be delivered at least once in each calendar year 28

29 Review of Fees and Expenses Monitoring, reviewing, and determining reasonableness of plan fees and expenses are fiduciary duties Section 408(b)(2) service provider disclosure requirements reflect DOL focus on fees and expenses Significant area of 401(k) plan litigation Importance of prudent process for fee and expense review Periodic review of service providers Benchmarking RFPs 29

30 ERISA Section 404(c) 30

31 404(c) Relief Overview Section 404(c) of ERISA A significant fiduciary risk management tool for 401(k) plan fiduciaries Protection from liability for investment decisions made by participants if certain conditions are met DOL and some courts have taken the position that Section 404(c) does not protect from liability for imprudent selection of investment alternatives 31

32 404(c) Relief Overview (continued) 404(c): In the case of a pension plan which provides for individual accounts and permits a participant or beneficiary to exercise control over the assets in his account:... no person who is otherwise a fiduciary shall be liable under this part for any loss, or by reason of any breach, which results from such participant s or beneficiary s exercise of control. 32

33 404(c) Relief Overview (continued) Applies to defined contribution plans that permit participant-directed investment Upon satisfaction of procedural requirements, plan fiduciaries are relieved of fiduciary duty with respect to participant investment elections Some uncertainty as to the scope of this fiduciary relief Full, or at least substantial, compliance required 33

34 404(c) Relief Requirements Three Primary Components of Section 404(c) Compliance Offer a broad range of investment alternatives At least three Each must be diversified Each must have materially different risk and return characteristics Offer each participant a reasonable opportunity to give investment instructions Provide each participant with specified information about the investment alternatives to allow the participant to make informed choices Same information as required by the Section 404(a) participant disclosures 34

35 404(c) Relief Requirements (continued) Providing sufficient information includes: Description of investment alternatives Explanation of investment election process and any restrictions on elections (e.g., day-trading limits, etc.) Description of fees and expenses Fund prospectuses (subject to fee disclosure regulation changes) Plan account information 35

36 404(c) Safe Harbors 404(c) relief generally predicated on participants making an affirmative election and exerting control over their accounts 404(c) originally did not contemplate negative or deemed elections Pension Protection Act of 2006 added two safe harbors for negative elections the Mapping safe-harbor and the QDIA default safe-harbor 36

37 404(c) Mapping Safe Harbor 404(c) relief preserved in situations where a plan is changing investment funds if: Participants are provided notice within the day period before the change Notice must include information about the funds being added and eliminated Notice explains the nature of the negative election Replacement fund has investment characteristics that are reasonably similar to the investment fund being replaced (investment characteristics include risk and rate of return ) 37

38 404(c) Mapping Safe Harbor (continued) Facts and circumstances aspect of the mapping safe-harbor can make 404(c) relief uncertain In some situations (e.g., phasing out a particular sector fund without a similar replacement), mapping safe harbor is not available Preferred approach by record-keepers because of ease of administration 38

39 404(c) Mapping Safe Harbor (continued) Pre-safe harbor mapping legacy may lurk in plans Special issues when replacing a stock fund 39

40 404(c) QDIA Safe Harbor 404(c) relief preserved in situations where amounts are defaulted into a qualified default investment alternative (QDIA) This QDIA safe-harbor is available if: Participants provided at least 30 days advance notice Participants provided annual notice thereafter Plan provides a broad range of investment alternatives (at least three diversified funds) 40

41 404(c) QDIA Safe Harbor (continued) Participants have opportunity to elect to transfer amounts into and out of QDIA fund at least quarterly Any restrictions on transfer rights must be no more onerous than those that apply to individuals who affirmatively elected to invest in the QDIA No unusual fees/expenses shall be imposed on such transfers 41

42 404(c) QDIA Safe Harbor (continued) Amounts defaulted into a recognized QDIA (target or lifecycle fund, balanced fund, individually managed fund or, for grandfathered amounts, stable value fund) QDIA safe-harbor is broader and more certain, but potentially results in more drastic change than mapping safe-harbor QDIA safe-harbor is more of a challenge for recordkeepers QDIA safe harbor generally includes Target Date Funds and Balanced Funds 42

43 Key Case Law Developments 43

44 Key Case Law Developments Hecker v. John Deere, Nos , , 2009 WL (7 th Cir. June 24, 2009) Tussey v. ABB, Nos , CV-C-NKL (United States District Court, W.D. Missouri, Central Division, November 2, 2012) Tibble v. Edison International, Nos , , 2013 WL , No , 2013 WL (9th Cir. Mar. 21, 2013) Leimkuehler v. Am. United Life Ins. Co., _ F.3d _, 2013 WL (7th Cir. 2013). 44

45 Presenters Lisa H. Barton, Partner Michael B. Richman Lindsay B. Jackson, Associate

46 DISCLAIMER This communication is provided as a general informational service to clients and friends of Morgan, Lewis & Bockius LLP. It should not be construed as, and does not constitute, legal advice on any specific matter, nor does this message create an attorney-client relationship. IRS Circular 230 Disclosure To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. For information about why we are required to include this legend, please see 46

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