"Make" Shift

Financial literacy has long been touted as something of a “silver bullet” in helping workers make better financial decisions – and now there’s a call to make it a mandatory employment offering. 

Now, we all know that lots of workers get their first (and for many only) exposure to financial markets via their workplace retirement plan. Ditto their only education about investing, diversification, or even mutual funds. Little wonder that those who are tasked with delivering those lessons have long championed the need for some basic level of financial education in school curricula.

The issue was most recently raised earlier this year in a paper titled “Defined Contribution Plans and the Challenge of Financial Illiteracy.” Authored by Jill Fisch of the University of Pennsylvania Law School, as well as financial literacy icon Annamaria Lusardi and Andrea Hasler from George Washington University School of Business, the paper compares the relative financial acumen of what it terms “workplace-only” investors with active investors.

The report notes that the former (some 28% of the investor group) only have investments through an employer-sponsored plan, the latter have private retirement accounts that they have set up themselves and/or other investments. Arguably, and as the paper acknowledges, some of those in the latter group may well have begun their investment experience in workplace plan, but have now rolled those investments into an IRA (the paper says that about half of this group have both a self-directed account and “other financial investments”).

Mandate State?

It’s this combination – what they claim are big gaps in financial literacy coupled with a reliance on a defined contribution-oriented retirement system that is so dependent on individual choices – that has now led these academics to call on for a mandate on employers to fill the gap with financial literacy programs.

Specifically, they propose that employers be required to provide a self-assessment “enabling their employees to measure their financial knowledge and capability.” They suggest that the Labor Department “could introduce minimum requirements as to what should be included in a program to provide the working knowledge and skills necessary to navigate the defined contribution system” – requirements that could, they note, “include both specific information about the 401(k) plan, the investment options contained in that plan, and the process of saving and investing for retirement,” but that could also “extend to more general components of personal financial decision-making that contribute to an employee’s financial well-being.”

‘Big’ Deal

I think it’s fair to say that there are lots of retirement plan savers who aren’t very investment savvy, though I’ve a sense that the academics are overly broad in their characterizations, and perhaps lack a full appreciation for the education that is currently provided in the context of workplace plans. Further, for their assessment of financial literacy (more precisely, the lack thereof), they rely on the responses to a “big three” set of questions. 

Now, those “big three” questions have been utilized in academic circles for years as an assessment as to whether an individual is financially literate or not. I’ll accept at face value the belief of gifted individuals who have studied the subject of financial literacy in far more detail, and with more expertise in such matters than I, that a correct response to those questions constitutes a level of literacy in financial matters.

I’m happy to say that I have, for years, been able to accurately answer those “big three” questions that purport to provide an accurate gauge of financial literacy[i] – but to this day I am unable to articulate exactly how those specific knowledges would help me answer the questions that seem most pertinent to achieving retirement financial security; notably how much should I save, how should I invest those savings, when should I rebalance, and – ultimately – how (and when) do I draw down those savings in retirement.

The studies I have seen – and a point made by the authors of this proposal – suggest that timing is critical to retention. In other words, teaching someone about investments years before they actually have any investments probably won’t have much retentive impact. That’s why the best financial wellness programs are effective – because, rather than one-size-fits-all education, they focus on specific people and targeted groups of people who have specific needs – and do so in a manner proximate in time to either when those decisions must be made, or will have an impact.

It’s hard to argue that a greater focus on financial literacy wouldn’t be of some benefit – though I would say preferably sooner and more consistently than is likely in the employment context. That said, I’m skeptical about the impact of a financial literacy campaign mandate on employers. First off, the vast majority of employers who sponsor a plan already provide some level of education (does anyone not?), on their own, or with the assistance of a recordkeeper, TPA or advisor. A growing number are doing so with the broader emphasis on outcomes and financial wellness. The Labor Department might well be able to craft a more practical set of financial literacy guidelines than the academics, but I doubt it – and that’s assuming they’d even want the job.

Putting that obligation on employers ignores decades worth of experience that many, perhaps most, individuals don’t take full advantage of the education materials already furnished. Moreover that they appreciate – and in most ways and many cases are better served by the convenience of plan design solutions – like automatic enrollment and qualified default investment alternatives – that counter human misbehaviors and help even the financially literate make better choices than busy lives often allow.[ii] 

More significantly, I suspect that a financial literacy mandate on employers who sponsor plans would only mean fewer employers sponsoring plans – and that’s before we consider the potential for a brand new angle for the plaintiffs’ bar.

In sum, there seems little to be gained from a financial literacy mandate on employers. But it’s worth keeping in mind that those who currently participate in those employment-based retirement programs have something to lose.

- Nevin E. Adams, JD

[i]The Big Three
Consider that, even in making the case that there is a financial literacy gap, the academics rely on what they call the “Big Three” financial literacy questions, specifically:

1. Suppose you had $100 in a savings account and the interest rate was 2% per year. After five years, how much do you think you would have in the account if you left the money to grow?

A. More than $102, B. Exactly $102, C. Less than $102 

2. Imagine that the interest rate on your savings account was 1% per year and inflation was 2% per year. After one year, how much would you be able to buy with the money in this account?

A. More than today, B. Exactly the same, C. Less than today

3. Please tell me whether this statement is true or false: “Buying a single company’s stock usually provides a safer return than a stock mutual fund.” 
♦True ♦False

[ii]Those are mostly accumulation options, however. On the drawdown/withdrawal side, while there are certainly many alternatives, there is arguably still a gap.

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