That is the other side of the leakage equation. Keeping assets inside a plan may preserve an investment structure that benefits the former employee, but doing so can transfer costs, obligations and risks back to the employer.

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Plan sponsors therefore have reason to distinguish participant education and assistance from commercial opportunity. The harder those activities are for participants to separate, the more important it becomes for fiduciaries to understand where one ends and the other begins.

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None of those tasks necessarily prevents a plan sponsor from making a change, but collectively they can make the decision considerably more complicated than comparing price and service.

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As bundled platforms spread, the recordkeeper’s technology became the environment in which the plan lived. The platform did not merely keep records of decisions made elsewhere; it increasingly determined how those decisions could be implemented and presented.

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Conflicting economic priorities create a problem legislation cannot solve merely by adjusting a number in the tax code. Increasing contribution capacity will not revive a benefit structure that no longer fits the decisions employers and employees actually make.

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The same challenge appears in required participant disclosures. Compliance may require sending documents, but sending documents does not guarantee that participants receive useful information.

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In my decades of experience, I have never encountered a pension fiduciary or board that fully understands the risks, costs, underperformance and performance vagaries related to alternatives and private investments.

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