The Department of Labor (DOL) has been thinking about either requiring or facilitating the projection of retirement income on quarterly participant benefit statements for defined contribution plans. The DOL's next step will be the solicitation of comments about the best way to do that.

Three sample quarterly statements have been developed which will likely be released to the public for comment. The first, and simplest, sample statement provides only for the projection of the current account balance to a participant's retirement age.

In reviewing the sample statement, it provides little additional value to participants, since the projected account balance is so large (almost $700,000) that it would leave a participant with the sense of great wealth ─ but with little idea of the income that it would provide.

The second sample statement includes both the projection of the account balance to retirement and an estimate of the amount of monthly income (using joint and 50 percent survivor payments). The "great wealth" of almost $700,000 is projected to yield about $2,500 per month ─ somewhere short of living in luxury.

The second sample is helpful. It gives participants a sense of the monthly income that could be provided from their account using reasonable withdrawal rates. And, it reinforces the fact that the ultimate purpose of the participant's account is to provide retirement income.

The third sample is essentially the same as the second, except that the projected numbers are rounded. We assume that the purpose of the rounding is to emphasize to participants that these projections are estimates and should not be viewed as the actual amounts the participant will have at retirement.

The samples describe the underlying assumptions, which are:

  • Gender-specific life expectancy assumption.
  • Retirement age of 67 (which is the normal retirement age for Social Security for most workers today).
  • Joint-and-survivorship annuity with level monthly payments, assuming the participant and his/her spouse are the same age and that the survivor benefits are equal to 50 percent of the monthly payments to the retired participant.
  • An inflation rate of 3 percent.
  • An investment rate of return of 7 percent. (Note that the effect of a 3 percent inflation rate is to provide a "real" return of 4 percent. All of the numbers are based on present values.)
  • That the current employer and employee contribution rates grow 3 percent annually.

Two additional thoughts:

The projection of retirement income appears on the second page of sample statements 2 and 3. This may run contrary to the purpose of the projection. Participants want to know how they are doing and they want to know quickly and efficiently. Since projected income is a critical part of the answer to that question, it would be most effective if placed on the first page.

The projections also include helpful information about the impact of increasing deferrals. That information makes the statement lengthy, complex and perhaps confusing. However, it is needed information; the issue is how to streamline the presentation.

When these materials are distributed to the benefits community, the burden will be on us to review them and provide the DOL with meaningful and helpful comments. If properly done, this change could affect how participants evaluate their retirement savings, as well as their behavior, including important decisions about increasing deferrals, delaying retirement, and living standards.

Fred Reish is a partner in the firm's Employee Benefits & Executive Compensation Practice Group, Chair of the Financial Services ERISA Team and a member of the Retirement Income Team. His practice focuses on fiduciary issues, prohibited transactions, tax-qualification and retirement income. He represents plans, employers and fiduciaries before the governing agencies (e.g., the IRS and the DOL); consults with banks, trust companies, insurance companies and mutual fund management companies on 401(k) investment products and issues related to plan investments and retirement income; and represents broker-dealers and registered investment advisers on issues related to fiduciary status and compliance, prohibited transactions and internal procedures. Fred is a well-known speaker and author on ERISA topics.

Bruce Ashton is a partner in the firm's Employee Benefits & Executive Compensation Practice Group and serves on the Financial Services ERISA and Retirement Income Teams. Bruce's practice focuses on all aspects of employee benefits issues, especially representing plan service providers (including RIAs, independent record-keepers, third party administrators, broker-dealers and insurance companies) in fulfilling their obligations under ERISA and in assisting service providers and plan sponsors in addressing the retirement income needs of participants. He is a well-known speaker and author on employee benefits topics.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.