Full Disclosure

Who gets how much money to run defined contribution retirement plans is often as clear as mud. That’s troubling because plan sponsors are responsible for informing their employees about the costs of building their nest eggs. The lack of transparency concerns employee advocates and, increasingly, government overseers, who worry that the murkiness may conceal high fees and make it difficult for plan sponsors to comparison-shop among providers.

通过20世纪90年代的牛市，没有人关注的费用，这是由友好投资回报掩盖的费用。但是，当熊市于2000年开始时，计划赞助商和他们的参与者让他们更接近审查。

Now regulators are also taking an interest. The Department of Labor has three initiatives under way, the result of several years’ study. And last November, Congress asked the Government Accountability Office, its investigative arm, to examine the transparency of fees charged in retirement accounts. The first part of the GAO’s report is due by the end of this year.

“Many service providers flatly refuse to disclose their fees,” says Kevin Wiggins, an ERISA attorney with West Virginia law firm Steptoe & Johnson. He doesn’t think that providers are trying to hide anything. Rather, he says, “they simply are not willing to bend over backward to explain their fee structure.”

Some plan sponsors and their advisers snipe that as the markets have rebounded and defined contribution assets have grown in recent years, providers have made windfall returns without lowering their fees.

“资产的增长速度意味着计划产生的收入在较快的剪辑中增长得多，而不是运行计划的成本，”马修·纳比西克（The Matthew Gnabasik）争夺基于芝加哥的Blue Prairie Group是有咨询计划赞助商的几家咨询公司之一挑战和减少他们的费用。

在整个行业中，费用被征收并以复杂的方式分开，缺乏透明度并不只是将计划赞助商处于劣势。它还可以使提供者竞争更加困难。

“There is no standard fee disclosure form,” grouses Laurie Nordquist, business director of Wells Fargo & Co.’s Institutional Trust Services unit, which administers approximately $30 billion in defined-contribution-plan assets. Nordquist acknowledges that her shop is “not the lowest-cost vendor,” but she contends that Wells’s fees would appear more competitive if its rivals disclosed theirs more fully. She’s taking the tack of disclosing Wells’s fees directly to plan sponsors in the hope that her clients, both current and prospective, will demand the same of her competitors.

Wells Fargo直接分发其退休计划服务，不像许多依赖于经纪人销售网络的提供商一样，他们又作为费用收集者。井有收费组合的账单：对计划赞助商的直接罚款;每位参与者征收的费用，并指控计划赞助商或参与者;而且，最典型的资产基于资产的费用，该费用被指控参与者个人账户，以及大多数情况下直接从其余额中扣除。大多数提供商 - 任何使用经纪人 - 只能将基于资产的费用直接从参与者的余额中扣除，因此被遮挡。

Asset-based fees are routinely spelled out in the prospectuses of mutual funds. But for the retirement share classes, the dense boilerplate language can seem impenetrable and vague, while indicating a wide range of fees.

There are reasons aplenty for the range. The cost of administering retirement plans can be a shifting target, rising and falling as participants sign up for more loans, pay them off or demand other services. Meantime, the revenues generated from asset-based fees can increase steadily as accounts swell with regular contributions and investment returns.

“We try to do an annual fee review with our clients for precisely that reason,” notes Wells Fargo’s Nordquist. “We frequently end up lowering our fees or adding services. Or we might move participants from paper-based loan transactions to electronic ones that are much cheaper.”

劳工首次监管倡议部将要求赞助商挑选出于投资基金的费用率笼罩的费用，并在其年度申请中报告，称为5500形式。DOL将于本月发出第一个提案。

“我们的目标日期拟议规则的通知，为5500份的变更为2006年8月，”DOL养恤金股的监管部门负责人“Notes Louis Campagna。“当然，这是遵循的标准评论，然后重写规则来反映这些评论。”

The second initiative by the DoL — to clarify that plan sponsors are responsible for making sure that fees are reasonable — is expected to be announced by year-end. And a third initiative, requiring plan sponsors to explain their plan’s fees to participants, is on the horizon. “Of the three changes, this last will have the biggest impact,” says Wells Fargo’s Nordquist.

这些变化将在提供者上有多大部分效果是一个开放的问题。DOL对计划赞助商有限的监管机构;它只能要求他们要求共同基金提供费用信息。

Still, consultant Gnabasik and other industry observers think that plan sponsors’ increasing demands for transparency could drive down prices (it’s harder to overcharge once everything’s spelled out clearly), spur more competition among providers on services and lead to more consolidation among managers as margins tighten. “I’m interested in using information to draw down the costs of plans,” asserts Gnabasik.

计划赞助商在减轻费用，只要这些费用已经退出参与者的账户余额，就没有太多兴趣。然而，随着责任的锐化，原告的酒吧将更有可能将赞助商的脚拿到火中，以确保收费合理和清楚地披露。

从参与者的账户扣除投资经理，记录人员或管理员，受托人，托管人和子系统代理所产生的费用所扣除的费用。Providers take either a fully integrated approach, in which the asset manager offers the investments and most administrative services, or they depend on unbundled arrangements in which the plan provider is paid out of (or joins in) the investment manager’s fees, either through so-called revenue-sharing agreements or 12b-1 fees.

The managers of investment firms that also offer administrative services (including Fidelity Investments, T. Rowe Price Group and Vanguard Group) have typically been reluctant to disclose their intracompany payments that show the relative profitability of business units. Unbundled arrangements do not require full disclosure of payments that have been only vaguely described in prospectuses.

在任何一种情况下，成本往往难以确定。随着参与者人数的增加（每位参与者而且以可变利率降低，根据所需的服务水平），运营定义缴费计划的费用（每位参与者减少），而且平均账户余额增加。这种变化的景观经常导致所有服务提供商之间的持续谈判，使其更重要的是首先使这些费用清晰地规划赞助商，然后保持这种清晰度。

Congress is also setting its sights on retirement plan fees. Last November, California Democrat George Miller, the ranking minority member of the House Education and Workforce Committee, which oversees labor laws, wrote to the GAO asking for a full-scale investigation of fees: who pays them, how well they are disclosed and what can be done to improve the disclosure. In his letter Miller pointed out that both average and median 401(k) balances — $45,000 and $15,000, respectively — fall woefully short of the $1 million that would provide adequate retirement income. Miller is looking for legislative remedies to help boost those savings, with a heavy emphasis on fee disclosure.

Notes Michael Barry, president of Plan Advisory Services, which consults with plan sponsors, “The issue of 401(k) fees could take off if the House Republicans pick it up or if the Democrats take back the House this fall or if there’s some major publicity similar to the mutual fund scandals.”