(Just Because) Survey Says?

  We’re often told (via surveys) of any number of retirement plan options that plan participants want. Should it matter?

Most recently, we’re assured that participants are clamoring to have access to private market investments. Before that, it was cryptocurrency — and for what seems like months now it’s all been about retirement income. Apparently vast majorities of participants are eager to have access through their 401(k) to an array of complex financial instruments to which they have, thus far, been largely (or totally) barred — or so surveys say.

Indeed, I’ve always been amazed that organizations are able to find so many ostensibly knowledgeable participants to weigh in on these complex topics — particularly since there is an abundance of (other) surveys that suggest that when it comes to financial matters, participants are, largely, clueless.

Not that that seems to dampen their collective interest in these new options — though when given a chance to put their money where their mouth is, participants seem to be about as cautious as you’d expect (want?) largely financially clueless individuals to be.  Doubtless the questions posed in these survey instruments are less complex than the actual decision points turn out to be.   

So, why bother asking participants what they (think they) want in the first place?

It’s not that there isn’t value to be gleaned in assessing participant sentiment but — as noted above, the actual take-up rate on those products, even when offered by a plan, has traditionally been…disappointing, certainly from the standpoint of the manufacturers of those offerings.

Manufacturers that, it bears noting, inevitably turn out to be the sponsors of these surveys claiming that participants want what they rarely seem to take. That doesn’t make them irrelevant, of course, nor does it mean that the results are hopelessly biased — but it is, I would argue, worth some caution in blindly embracing (or sharing) the results, even when a reputable canvassing body is involved. At a minimum, a visible footnote acknowledging that specific “interest” in the outcome seems warranted.

The reality is that these types of surveys are rarely designed to actually gauge participant interest — savvy product manufacturers have likely already done some of that alongside the inevitable market and profit margin projections. Rather, they are a means to create and/or fuel public awareness, but perhaps more specifically to encourage plan sponsor/fiduciary consideration on the path to the ultimate acceptance of options they might otherwise be disinclined to entertain.

Prudent plan fiduciaries should, of course, take note of such things — but arguably with a grain of salt, certainly as it pertains to their specific workforce. However fervent the interest of a group of unrelated individuals might be, that doesn’t make it relevant for those under your care.

Indeed, ERISA’s standard of care is a high threshold, one that requires that the services engaged not only be reasonable in terms of fees and applicability, but solely in the best interests of plan participants and their beneficiaries.

And, as any parent can attest, sometimes those in our care want things that don’t meet that standard, whatever their opinion may be at the time.

Regardless, plan fiduciaries shouldn’t feel coerced into incorporating options just because a sponsored survey says (some) participants want it — participants who, of course, might not know what they’re asking for. Because, after all, prudent plan fiduciaries are expected to.

- Nevin E. Adams, JD