Defined Contribution Quarterly
In Focus: Private Market Investments in DC Plans
Private market investment has grown meaningfully over the past decade and incorporating private market strategies into defined contribution (DC) plans is an emerging trend with the potential to enhance long-term retirement outcomes. Compared to public market investments, private market strategies can offer the potential for higher returns, higher risk and portfolio diversification through long-term commitments, active business management, and operational value creation. However, some of their characteristics in the areas of liquidity, pricing and investment horizons can present questions regarding structuring and implementation in the context of DC plans. Addressing these considerations for DC plans requires innovative solutions and thoughtful plan design to ensure these strategies can be effectively and responsibly utilized, providing participants with access to a broader set of potential growth investment opportunities.
For a deeper dive into this topic, please read Private Market Investments in Defined Contribution Plans, which covers:
- Potential for enhanced investment returns
- Growth of private market companies and assets
- Growth in products and innovation
- Greater utilization in professionally managed portfolios
- Potential considerations for plan sponsors
- Potential plan design considerations
In The News
Defined Contribution Industry
Key Developments
- Recordkeepers and insurance companies team up to offer guaranteed income annuity contracts in defined contribution plans. Partnerships of Allianz and Empower, as well as T. Rowe Price and Pacific Life, are now offering these guaranteed life income annuity plans on their recordkeeping platforms.
- A new Pooled Employer Plan (PEP) has been launched for Head Start learning programs. For some, PEPs may be a financially and administratively less burdensome way of offering retirement programs to employees.
- Rhode Island announced plans to introduce an auto-IRA program, in conjunction with Connecticut, for those employees who are not covered under an employer-sponsored retirement plan.
SECURE 2.0 Corner
The DOL’s Retirement Savings Lost and Found database has begun collecting data from plan administrators, recordkeepers and other service providers. The DOL also announced it they will be able to access information from Forms 8955-SSA to populate the database. This SECURE 2.0-mandated database will allow participants who have separated from their jobs to locate retirement accounts.
Several provisions included in SECURE 2.0 are effective as of January 1, 2025:
- Mandatory automatic enrollment for plans established after December 29, 2022.
- Long-term part-time employees must be permitted to participate in defined contribution plans if they have worked at least 500 hours for two consecutive years.
- Increased catch-up contributions for those participants who turn ages 60-63 during the year. This increased catch-up contribution limit is $11,250 for 2025.
- Automatic Portability: Terminated participant accounts with balances under $7,000 can now be automatically transferred to a new employer’s account. The Portability Services Network is live with three recordkeepers and has plans for an additional three to join in 2025.
Regulatory, Legislative & Litigation
Regulatory
- The IRS clarified that 403(b) plan sponsors do not have to extend eligibility to student employees who would otherwise qualify as a long-term part-time employee under SECURE 2.0 provisions.
- President Trump nominated Lori Chavez-DeRemer, for Secretary of Labor. Chavez-DeRemer has historically shown support for pro-union policies.
Legislative
- The Social Security Fairness Act was approved by Congress and subsequently signed into law by former President Biden. The Act repeals two provisions that previously reduced Social Security payments for those individuals, as well as their spouses and survivors, who also received a government pension.
- The Retirement Simplification and Clarity Act was introduced in the House in an effort to make distribution instructions for separated employees more understandable. Additionally, the bill would allow in-service rollovers to annuities.
Litigation
- Plan litigation reported on this period focused in large part on investment fees and performance, the use of forfeitures, and fees for recordkeeping and managed accounts and one additional case challenging a plan’s stable value fund. Settlements reported during the covered period ranged from $980,000 to $69 million and included non-monetary terms of recordkeeping RFPs and retaining plan investment consultants. A number of dismissals took place at the district court level.
- A circuit court affirmed that an arbitration clause was unenforceable against plaintiffs in a lawsuit alleging imprudent plan management.
- American Airlines was found by a district court in Texas to have violated its duty of loyalty under ERISA in connection with the proxy voting and shareholder activities of an underlying plan manager, BlackRock (who is not a named defendant in the suit). The court did not rule on damages and directed the parties to submit briefings on the topic for further review and ruling.
Quarterly Snapshot
Target date fund (TDF) flows in Q4 were reported to be either lower than or in line with the prior quarter. Plan participants continue to seek more stable investments as we see inflows in bonds and money market funds compared to larger outflows from equity. Last-twelve-month asset class performance has been positive for most asset classes, though 3-month performance has been mixed across the board. Active managed outperformance has been most pronounced in international equity and intermediate term bonds.

Source: Strategic Insight, Simfund. As of December 31, 2024. For open-end mutual funds only. For illustrative purposes only.

Source: ICI “The U.S. Retirement Market, Third Quarter 2024.” As of Q3 2024 (latest available). For illustrative purposes only.

Source: Morningstar. As of December 31, 2024. Past performance does not guarantee future results, which may vary. For illustrative purposes only.

Source: Morningstar. As of December 31, 2024. Net of fees. Please refer to the disclosures for benchmarks. Past performance does not guarantee future results, which may vary. For illustrative purposes only.
