Sponsor gateway: Introduction to self-service plan administration
Entrance into your 401k Easy plan administration and participation occurs, respectively, through your customized Plan Sponsor Gateway
and Plan Participant Gateway
The Plan Sponsor Gateway gives your authorized personnel Internet-based access to self-service 401k administration.
The Plan Participant Gateway gives everyone in your company Internet-based access to self-service 401k participation, which includes access to information about your company plan and participating in it.
The exact features and capabilities accessible through each gateway depend on
the customization options
you as Plan Sponsor choose for your company plan and those that the eligible employee chooses for his or her individual 401k account.
The Plan Sponsor Gateway is the plan sponsor's path to customized self-service plan administration, including convenient communication with company employees.
Access is user-name and password protected. Only those individuals at your company whom you authorize can enter your Plan Sponsor Gateway.
Functions are separated into two streams: Plan configuration functions (see next topic) control overall plan information and operation parameters, while day-to-day plan administration functions (see the topic after next) power and monitor day-to-day administrative activity.
Participant gateway: Introduction to self-service plan participation
401k Easy empowers plan participants to serve themselves to their 401k account activity and information, which they can do at any time, day or night, from any location connected to the Internet.
401k Easy self-service plan participation gives eligible employees on-the-spot access to enrolling in the plan, updating personal information, making and updating investment designations, viewing and printing activity reports and account statements, and 401k loan, transfer and distribution modeling and submissions, among other things.
General as well as plan-specific investment information is available at a mouse click.
Self-service plan participation is extremely convenient for plan participants and can greatly boost plan participation rates.
Self-service plan participation means far less work for your in-house plan administrator.
401k Easy creates a home page for each plan participant. Upon login, the participant arrives at his or her home page.
As plan sponsor, you can have 401k Easy display certain categories of information on each participant's home page, for instance, the participant's investment designations, account balances, and/or recent account activity.
As plan sponsor, you can compose Bulletins via your Plan Sponsor Gateway for posting on employees' home pages. (Scroll up or
use the middle tab in this page's topics menu to read about 401k Easy's plan administration features, which are accessed via the Plan Sponsor Gateway.)
Participants update information themselves
Plan participants never have to involve the plan administrator in routine account information updates:
Participants can amend their address, telephone number(s), disbursement preferences, passwords, and more. 401k Easy immediately notifies your designated plan administrator via e-mail of any changes.
Participants update investment designations themselves
Plan participants never have to go through your 401k plan administrator to access and/or amend investment designations.
The participant's customized Plan Participant Gateway displays available plan investments and indicates those to which the participant is contributing and at what rates.
The participant can, at any time, opt to amend his/her designations.
Participants monitor, model and apply for loans, transfers and distributions themselves
Plan participants never have to go through your 401k plan administrator for transaction information on existing loans, transfers, distributions, etc.. Instead, they simply go online and access the information themselves.
In addition, participants considering a new loan, transfer or distribution can have 401k Easy model the effect of such on their 401k account:
During the modeling process, 401k Easy calculates the availability of funds based on money sources, aged buckets (if applicable), and other applicable rules.
To accept a new loan, transfer or distribution, the participant must correctly answer one of the security questions that the employee established in setting up his or her Log In name and Password.
New loans, distributions, and transfers must be approved by the 401k plan administrator and are indicated as Pending until so approved.
401k Easy gathers all the information the 401k plan administrator needs to approve or deny an application.
You can elect to have 401k Easy automatically decline any new submissions for loans, transfers or distributions if an application for such from the employee is already in the system as pending approval of your plan administrator. This works as a safeguard against plan participants flooding the system with applications for the same transaction while the plan administrator awaits, for instance, consent of spouse approval.
Within the Loans, Transfers, and Distributions panel, the participant also has the option of downloading and/or printing necessary forms to request loans, distributions, and transfers in person from your 401k plan administrator and to manually perform other related account maintenance activities.
Participation is more than simply password protected
Plan participants enter the Plan Participant Gateway by keying in the user name and password they establish during their first visit.
Your 401k plan administrator issues a temporary password for that first visit to allow an employee entrance into the system.
Eligible employees not currently enrolled in the plan can easily be granted temporary passwords by your 401k plan administrator so they can learn about the company 401k plan, investigate the online self-service system and see how easy saving money via the company's online 401k plan will be.
When establishing their user name and password, plan participants also establish three identifying questions and answers, such as "Mother's maiden name?" answer: "Johnson." The questions are later used to confirm the participant's identity when the participant attempts certain transactions (for instance, applying for a 401k loan, or retrieval of his/her password).
The system houses a log of each employee's user name, password and three questions/answers within the Plan Sponsor Gateway. Plan participants can request help from your 401k plan administrator (via the 401k Easy, in person, by phone, etc.) at any time.
Advisors and ESIRA Q & A
The following is a summary, in question and answer form, of the Department of Labor's position regarding financial advisory services rendered to 401k pension plans. These guidelines can change without notice, so it is important to review them with your legal council before relying upon them:
Is it legal to provide investment advice services or portfolio management services, or both, to ERISA plan participants?
Yes. In fact, the U.S. Department of Labor is on record saying that it wants participants to have as much assistance as possible, and that it encourages plan sponsors to offer participants investment advice if plan sponsors determine their participants need it to make informed decisions. In addition, the DOL, Congress and the Administration have increasingly voiced strong support of investment advice for participants.
Portfolio management services have been used in ERISA plans for many years. ERISA includes provisions for plan sponsors to appoint investment managers, and the Department of Labor regulations on 404(c) plans discuss various examples involving investment management services.
Would doing nothing, in other words, not providing these services to participants, be safer from a legal perspective?
Not really. We think that providing advice and/or portfolio management can actually reduce your risk as a plan sponsor. Employees who make uninformed decisions about savings and investing are less likely to be prepared for their retirements. By making advice and/or portfolio management available, you ensure that your employees have access to the help and information they need to plan for their futures, decreasing the chances of dissatisfaction and possible litigation.
Furthermore, if you as a plan sponsor/fiduciary know that the participants in your plan need help with investing for retirement, you should provide the needed help, whether it is education, advice, professional management, or all three. This is supported by ERISA section 404(a)(1)(B), which requires that all plan fiduciaries exercise their responsibilities "with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims." (Emphasis added.)
What is the Department of Labor's view on providing advice and/or portfolio management?
The Department of Labor has stated that providing advice can actually reduce a sponsor's fiduciary risk. In a major policy speech on September 15, 2000, Leslie Kramerich, Acting Assistant Secretary of Labor, Pension and Welfare Benefits Administration had this to say on the subject:
"[W]e believe that employers can be responsive to the investment education and investment advice needs of their employees, without significant burdens or risk of liability. The selection of providers that offer informed, unbiased and appropriate investment education or investment advice will, in our view, not only serve to increase the likelihood of employees achieving retirement security, but also significantly reduce the potential for employee dissatisfaction and possible litigation."
Is providing investment education a sufficient way to fulfill my role as a fiduciary?
Informed policymakers caution that relying on education alone is no longer enough. According to DOL's current Assistant Secretary, "[m]eaningful comprehensive investment advice is more important now than it has ever been" and "[i]nvestment education, while important, is simply not enough." Assistant Secretary Ann L. Combs delivered this message to Congress on July 17, 2001 in connection with testimony on the subject of "Retirement Security Advice Legislation" to the Subcommittee on Employer-Employee Relations of the House Committee on Education and the Workforce.