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Retirement Planning > Saving for Retirement > IRAs

IRA Rollovers Can Have Steep Costs When Done Wrong, New Study Shows

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What You Need to Know

  • Investors in 401(k)s may have access to lower-fee investments than they would in a rollover IRA.
  • New DOL rules require advisors to conduct a detailed analysis of whether, and why, a rollover would be in a client's best interest.
  • Fees are not the only factor advisors need to compare in the rollover decision.

Rollovers from 401(k) plans to individual retirement accounts (IRAs) without expert guidance can cost savers a lot of money, as a recent issue brief from the Pew Charitable Trust illustrated. Funds frequently impose higher fees on retail share classes than on institutional shares, and the brief examined the long-term impact those higher fees can have on retirement savings. 

Here’s an example from the study. A 65-year-old employee retires with $250,000 in her 401(k) account that generates an assumed 5% real annual return. She plans to withdraw $1,000 each month for her life expectancy of 25 years until age 90. The 401(k) plan charges a 0.46% annual fee and she rolls the account over to the same fund in an IRA that charges 0.65%.

Over the next 25 years, she’ll pay $37,091 in IRA fees versus $27,233 if she had kept the funds in her 401(k). At age 90, she’ll have $197,040 in her IRA versus $217,553 in the 401(k). The study provides two other examples with the same result: The IRAs’ higher fees add up and reduce the savers’ wealth over the long term.

DOL Regulations Impose More Rollover Requirements

The study makes a case that savers should consider leaving their savings in their former employer’s 401(k) because of the potential cost savings versus IRAs’ retail shares. It’s sound advice, but with the implementation of the Labor Department’s Prohibited Transaction Exemption (PTE) 2020-02, that evaluation is now a pre-rollover requirement for advisors and firms. 

In its April 2021 guidance, New Fiduciary Advice Exemption: PTE 2020-02, Improving Investment Advice for Workers & Retirees Frequently Asked Questions, the DOL lists the factors advisors and firms should consider and document with each rollover analysis.

The goal is to give investors an objective, written review of their available options with specific reasons why a rollover recommendation is in the investor’s best interest. From FAQ no. 15 (emphasis added):

“For recommendations to roll over assets from an employee benefit plan to an IRA, the relevant factors include but are not limited to:

  • the alternatives to a rollover, including leaving the money in the investor’s employer’s plan, if permitted
  • the fees and expenses associated with both the plan and the IRA
  • whether the employer pays for some or all of the plan’s administrative expenses, and
  • the different levels of services and investments available under the plan and the IRA.”

FAQ no. 15 provides additional guidance to supplement the high-level factors. For example, suppose an advisor’s analysis finds that the employee’s 401(k) actively managed equity fund’s performance is highly correlated with the S&P 500 index’s performance. The advisor’s rollover IRA can access an S&P 500 index fund at a lower cost than the employee’s current holding. 

That lower fee comparison is insufficient, the DOL cautions: “When considering the alternatives to a rollover, the financial institution and investment professional generally should not focus solely on the retirement investor’s existing investment allocation, without any consideration of other investment options in the plan.”

In other words, if the employee can invest in an S&P 500 index fund in the 401(k) plan, the plan’s index fund should be considered as an option. 

The DOL lists several other factors to consider in a rollover analysis:

  • the long-term impact of any increased costs
  • why the rollover is appropriate notwithstanding any additional costs, and
  • the impact of economically significant investment features such as surrender schedules and index annuity cap and participation rates.

PTE 2020-02 means more work and disclosure for possible rollovers. The good news is that clients have more confidence in the advice they receive and they’ll have a better understanding of their options’ fees and other costs.


Ed McCarthy is a freelance financial writer who holds the certified financial planner and retirement income certified professional designations.