June 30, 2010
I am fascinated that both the DoL and SEC continue to overlook an easy resolve to the serious communication and investment related problems that plague and will continue to affect Target Date Funds (TDFs). Repeal the ERISA exemption on these self-dealing mutual funds and rescind the fiduciary relief under the PPA 2006.
Why is the DoL/SEC continuing to waste valuable resources on disclosure and communication - it does not work. The original industry answer to the communication/education problem in 401(k) plans is TDFs. We're now coming back to trying to get participants to read and comprehend more disclosures - what happened to TDFs being easy. Naming conventions and marketing materials will only serve to confuse participants more - think about this from their vantage point. It's interesting that many investors in TDFs are automatically defaulted in these funds anyway, they will never see or be interested in reading disclosure documents or marketing materials.
The DoL has implied to plan sponsors that TDFs have the governments seal of approval. The flaws surrounding these products are structural and the SEC is worried about how to graphically illustrate glidepaths - let's make sure that participants are well-invested first and then worry about drawing pictures later.