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  • Writer's pictureBrian Allen, CFP®

The Threat of Managed Accounts for Plan Advisors

This article was originally published in Advisor Perspectives on December 7, 2020 and can be viewed here.


The growing use of managed accounts within 401(k) plans is threatening the financial security of plan participants and the integrity of those advisors who recommend them.

The fees charged to 401(k) plans are negative investment returns. Consider the long-term impact they have on your client’s retirement. Simply put, the fees that 401(k) participants incur will reduce their balance available and income it can produce in retirement years.

For the people who oversee 401(k) plans on behalf of their employees (often referred to as plan committees or fiduciary committees), fees are a big responsibility. They decide which services are provided to the plan and its participants, and with each service added will need to evaluate potential vendors and expenses. Their decisions have major consequences for the plan’s participants, as any fee paid by the plan is ultimately borne by the participants.

Keeping those costs low is a vital aspect of a good plan.

The Employee Retirement Income Security Act (ERISA) provides general guidance to the fiduciary committee in its Section 408(b)(2), stating that to avoid running afoul of the statute’s prohibited transaction provisions, the fiduciaries should furnish services that are necessary to the operation of the plan, while paying no more than reasonable compensation to the provider of those services.

In light of the large consequence of 401(k) fees and the fiduciary committee’s legal responsibility to them, class action lawsuits have been rising dramatically in the last 10 years. Participant lawsuits alleging fiduciary wrongdoing are now commonplace.

However, a recent case alleging excess fees grabbed my attention because it is the first that mentions so-called “managed accounts” in 401(k) plans. Rebecca Moore, managing editor for the digital division of, reported that a participant in Nestle’s 401(k) savings plan had filed the proposed class action lawsuit, alleging that the company and its board of directors breached their fiduciary duties under ERISA.

Managed accounts generally work like this: The participant speaks with an advisor or representative; the participant gives them an expected retirement date; the advisor takes an assessment of risk tolerance,, and details current plan assets, any other retirement assets, and expected annual contributions, among other things. The meeting usually lasts 30-45 minutes.

After the information is collected, the advisor uses a software program to recommend a custom portfolio for the participant among the plan’s investment menu. Typically, the portfolio will be rebalanced periodically and gradually reallocated to a more conservative posture as the participant grows older.

Moore’s article states that the participants in Nestle’s 401(k) savings plan were offered a managed account service that was provided by Voya Retirement Advisors. The annual fees were 0.5% of assets up to $100,000, 0.4% on the next $150,000, and 0.25% on assets above $250,000.

Managed accounts and their associated fees are the result of a continuing underlying problem: the general lack of knowledge among plan participants to invest their retirement money appropriately. While 401(k) plans have grown exponentially in the last 30-plus years, America’s financial literacy hasn’t kept pace. So the need grows for professional guidance when it comes to selecting investments among the plan’s menu of options.

Thus, managed accounts have become an increasingly popular service for plan advisors to recommend to their clients, competing with robo advisors, target-date funds and educational tools such as asset allocation models. Managed accounts represent a huge opportunity for plan advisors. Some plan advisors earn more from managed account fees charged directly to the participants than from fees they charge for traditional plan services.

Which road will you take?

Remember here how this happens and how the distribution role is affected.

Part of the fee charged by the managed account service provider is shared with the plan advisor for distributing the service. Since the advisor stands to gain financially from the plan fiduciaries authorizing its availability to its participants, this distribution role subsequently creates a conflict of interest for the advisor.

The philosophical question then becomes: Are managed accounts a valuable service that addresses a substantial need among plan participants, or are they an easy sell that plan advisors can use to drive up their income?

Too often, managed accounts are being pitched to plan advisors as a way to increase their fees and make more money. If advisors succumb to that selfishness, it is a shortsighted mistake that will hurt them, and their profession, in the long run.

Think about the consumer, who is seeking honest, fiduciary-based financial advice when they engage with an advisor. Shouldn’t that be the goal of the plan advisor when working with the plan’s participants?

This is a fork in the road, and plan advisors need to decide which path they will take.

The right road is one of enhanced reputation, which leads to increased income because it’s being earned the reputable, honest way. The client’s interests must come first.

Sadly, financial advisors have taken the selfish route, and that has led to plan participants being skeptical to seek their advice. We have a great opportunity to choose the better route. Plan advisors should be the objective scrutinizer, not the sales team. We are professionals, offering value to our clients. Let’s not allow ourselves to become the distribution arm for anyone – record-keepers, mutual fund companies, brokers/dealers, or managed account providers.

Our job as plan advisors is to evaluate opportunities and advise. It’s valuable and honest work. It’s what clients want from their advisors, and for the betterment of their clients and their profession, it’s what we should demand of ourselves.


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