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How
To Start a 401(k) Administration Practice
Listed
here are the steps required to tap the pension market for a new and
profitable consulting business. CPA
firms frequently field questions from their small business clients
about qualified 401k retirement plans. Just as frequently, after
getting that professional guidance the clients turn to a non-CPA
firm to administer those plans. That's
a major opportunity loss. With the right kind of planning, such
business could be retained and made into a profitable specialty of
the firm. Many
CPA firms are in a unique position to provide administration
services for qualified plans to their clients. After all, they are
familiar with clients' financial history and goals. If they fail to
capture this business, they may lose yet another opportunity: to
expand the relationship by providing personal financial planning
services to business owners. This article provides practical
guidance for CPA firms considering beginning or expanding 401k
retirement plan administration 401k practice. Before
a firm decides to undertake such a highly technical 401k practice,
its managing partners should determine the potential market and the
scope of services that could be offered. The assessment should
include a profile of clients that are most likely to require the
services and a marketing study to determine other potential clients
and the CPA firms that already are providing the services. In
assessing the competition, the firm's partners should not dwell on
competitors' style or services with a mind to emulating them. Firms
starting up in this specialty usually discover their range of
services is best selected by determining their own business goals
and the needs of targeted clients. If
the partners decide to add this 401k practice area, they should
examine all plan administration services and determine which they
believe will complement the firm's other services. Then they must
assess the size and experience of the firm's staff and the gap
between their current abilities and the resources the firm will need
to undertake the work--including the time, effort and money it is
willing to expend to develop those resources. One option, and it's the most expensive one, is to offer all plan administration services for all types of qualified 401k retirement programs in what amounts to a "turnkey" service--from design consulting through plan-termination services. Partners should be aware, however, that the range of qualified 401k retirement programs and service levels is extensive, requiring a significant amount of resources. Turnkey administration services include 401k
Fact: According to Southern California-based (401k) Enginuity
(www.401kenginuity.com), twenty-year veteran in developing and running 401(k) administration and 401(k) software and recordkeeping systems, the Internet will be the primary delivery system for 401(k)s by 2007. Many web-based 401(k) plans will run on administration and recordkeeping platforms that plan providers will outsource to 401k specialists and 401k Application Service Providers (ASP). *
Design-feasibility analyses. This is typically the initial phase for
services in the employee benefit 401k practice. It requires some
expertise in all types of qualified 401k retirement plan programs.
The staff must be able to illustrate the cost of a proposed program
(in terms of cash flow, executive and nonexecutive benefits and
projected tax savings) and other advantages and disadvantages of a
recommended benefit program. *
Implementation. This service involves providing the client with the
many documents it needs to begin the plan, which includes plan
descriptions, administrative manuals, employee notices, Internal
Revenue Service requests for a determination letter, salary
reduction agreements, beneficiary designations, survivor annuity
waiver forms, loan policies, etc. In addition, hybrid plans may
require the assistance of an attorney in drafting some documents.
The firm also must consider how it will assist clients in adopting
programs that it recommends. *
Annual administration. The type of qualified plan will dictate the
annual services the 401k practice will need to develop internally.
Annual services can include recordkeeping; contribution
calculations; Financial Accounting Standards Board financial
reporting calculations; summary annual reports; allocation of
contributions; minimum funding calculations; top-heavy calculations;
trust accounting; discrimination testing; benefit certificates;
reporting and disclosure to the IRS, Department of Labor and
participants; etc. As should be evident, the list is extensive. *
Ongoing compliance and consulting. When new or pending legislation
or government regulations require changes to the benefit program,
clients will expect the consultant to communicate how such changes
will affect their programs and the available options. If the 401k
practice encompasses design services, it should be prepared to
consult in this area. Document services include plan amendments
necessary to implement the required changes. *
Termination. Depending on the program, termination services can be
time-consuming and intricate. For instance, terminating a
profit-sharing plan is much different from terminating an Employee
401k retirement Income Security Act title IV qualified plan.
Professional services in this area can include participant notices,
Pension Benefit Guaranty Corp. notification, application for IRS
determination letters and distribution calculations assistance. If
it's determined a full-service 401k practice is either too expensive
to implement or is not called for from a marketing viewpoint, the
other option is to establish a limited-service 401k practice. Once
again, the managing partners must assess the firm's area of
expertise and interests. Since the fees the firm ultimately charges
will depend on the type of personnel needed to complete the service,
the partners should determine which projects can be delegated to
clerical staff (for example, data entry) and which must be handled
by the professional staff. There
are two internal work styles traditionally used to handle plan
administration projects: the functional method and the client (or
team) method. Many administration firms use a hybrid of the two. With
the functional method, the work is divided up and assigned by
project or distinct function. For example, a typical job could be
broken into these components, with specialists handling each
function: actuarial, trust accounting, technical services and
research, employee recordkeeping and data entry, government forms,
calculations and allocations, review and plan terminations and
special studies. Many
CPA firms prefer the functional method because it's efficient and
gives each professional the opportunity to develop specialized
expertise. Generally, it's best for a small office. The
disadvantages include potential confusion over who is ultimately
responsible for the client's work and which staff person the client
should call with questions, potential inconsistencies in the quality
and content of the work and reliance on one or a few people for
expertise within a function. With
the client-team method, each team has its own clients. And, of
course, the team becomes more familiar with its clients and so is
better able to assess their needs. Also, it's clear who is
responsible for each client and the clients know which person to
call with problems. The disadvantages include the vulnerability of
the team's spirit if there is a lack of effective team leadership,
an uneven workload and the possibility of billing inconsistencies if
hourly rates vary. This method also requires the staff to be more
sophisticated than is the case in the functional method because each
staff member needs to be familiar with a much broader range of
technical areas. In
this age of computers, specialized software can make pension
administration much easier. But there are certain things that a CPA
firm should know before buying the software. When
working on a simple pension plan, a Lotus spreadsheet works fine.
But once the 401k practice gets beyond simple plans, it may find
that it will take a full-time systems analyst to maintain the Lotus
program. For example, administering a 401(k) plan requires numerous
variable functions for eligibility, vesting, allocation of earnings
and, most important, updates for the frequent legislative and
regulatory changes. The
alternative is to buy software specially designed to handle
administration functions. In making such a purchase, it's important
to determine if the program can meet the full range of the firm's
401k practice needs. The firm should determine whether other CPAs
who use it are satisfied. Also, the partners should check how long
the vendor has been in business. If the vendor goes out of business,
the firm may have no one to turn to for technical support, and since
tax and pension laws change frequently, there is a continual need
for program updates. Here are additional advisories to consider when
buying software: *
Can the software be expanded to perform other related functions? Can
the vendor supply related programs? *
How good is the vendor's technical support? *
Can the program import and export data from and to other programs? *
How quickly can it incorporate law changes into existing software? ESTABLISHING
QUALITY CONTROL One
of the keys to a successful plan administration 401k practice is
staff training. Probably all staff employees will require some
degree of training. Obviously, this does not apply to senior
management personnel, who are employed for their experience and
knowledge, of the subject. Because
training takes time, the firm should not expect any billing
production from most staff members in training for at least the
first six months. And it should be made clear to all new hires that
they will have to undergo extensive training. With
the ever-changing legislative and regulatory environment in the
qualified plan area, it's critical that the partner in charge
establish an internal structure for the operation, even if it is
informal. Once a basic structure is in place, all staff members
should participate in refining it. Specific attention should be
given to regular planning meetings with an assigned agenda to handle
technical decisions, workflow problems, external and internal
training schedules, overviews of resource guides, operational
inefficiencies and project goals. When
developing internal checklists, the entire staff should be given
time to assist with the project. The managing partner should go
through each type of service with each staff member from beginning
to end. Questions to ask: What steps are involved? What information
is needed? Where is the potential for errors? This
type of 401k practice involves lots of forms. As a result, the staff
members, in conjunction with the partner, should produce the
necessary checklists to develop and refine internal processing
formats, such as written communications, technical checklist forms,
file memorandums, "buckslips" (evidencing the completion
of required processing steps), form letters, client meeting
preparation forms, client conversations, external communications and
fee process-billable time logs. Once
created, forms and internal policies should be regularly refined.
Committees should be assigned to review, improve and update forms
and internal control functions, as well as work assignments. Additional non-profit websites that include relevant unbiased information about 401k plans include: www.401ksoftware.info TECHNICAL
SUPPORT The
partner in charge will have still other issues to resolve. For
example, how will each staff member answer such difficult "gray
area" questions as the proper order for distribution of excess
Internal Revenue Code section 415 contribution or excess deferrals?
Also, what procedures will be established to analyze such
problematic judgment calls? And what procedures will be followed to
double-check these issues and their resolution? In addition, the
partner will have to establish guidelines, for example, for
determining the staff member responsible for new legislation and
regulation, designing a workbook for completing technical
calculations and developing a client inquiry procedure. It's
important to detail the continuing education requirements of all
staff members; this should be established by the partner in charge.
In addition, the policy should list the steps by which the staff
will achieve its educational goals, which may include internal and
external classes and conferences and evening classes at local
educational institutions.
PRICING FOR FEE-BASED SERVICES Two
methods traditionally are used for pricing 401k retirement plan
administration services: the unit charge and time and expense. It's
becoming more common for administration firms to use a hybrid of
these two methods. For instance, handling a profit-sharing
allocation, employee recordkeeping and form 5500 may be a unit
charge, using a base fee, plus an additional unit charge for each
participant or eligible employee. Charges for additional consulting
outside the scope of these services may be on a time and expense
basis. To
determine a unit charge, the firm should first decide which staff
member will complete the work, who will review that work and what
hourly charge will be assigned to each staff member. The next step
is to determine the time necessary for each level of preparation and
review. The unit charge should reflect the amount of time spent at
the hourly rate of the staff members. After
this, a manager should compare the charges with prevailing rates in
the local market. If the firm's unit charges are higher, they should
reflect the quality controls that have been implemented and result
in superior service for clients. Remember, an inferior result at a
discounted price is still an inferior result. The
qualified 401k retirement plan administration service area can be
exciting, challenging and profitable. Properly planned, a CPA firm
can provide this value-added service in addition to the other
professional services it is already providing small and medium-sized
businesses. But to be successful, the firm's partners must plan
entry to the 401k practice carefully. LISA
C. GERMANO, CPA, is president and cofounder of Actuarial Benefits
& Design Co., Midlothian, Virginia. She chairs the American
Institute of CPAs employee benefits taxation committee and is
chairperson of that committee's working group on plan administration
401k practice. The
author acknowledges the help of Kenna Payne, CPA, in the preparation
of this article. EXECUTIVE
SUMMARY *
MANY CPA FIRMS are in a unique position to provide administration
services for qualified pension plans to their clients. If they fail
to capture this business, they may lose yet another opportunity: to
expand the relationship by providing personal financial planning
services to business owners. *
BEFORE A FIRM DECIDES to undertake such a highly technical 401k
practice, its managing partners should determine the potential
market and the scope of services that could be offered. *
IF PARTNERS DECIDE to proceed, they should examine all plan
administration services and determine which they believe will
complement the firm's other services. *
ONE OPTION is to offer all plan administration services for all
types of qualified 401k retirement programs in what amounts to a
"turnkey" service. Partners should be aware, however, that
the range of qualified 401k retirement programs and service levels
is extensive, requiring a significant amount of resources. A less
costly option is to establish a limited-service 401k practice. *
THERE ARE TWO internal work styles traditionally used to handle plan
administration projects: the functional method and the client (or
team) method. Many administration firms use a hybrid of the two. *
ONE OF THE KEYS to a successful plan administration 401k practice is
staff training. Because training takes time, the firm should not
expect any billing production from most staff members in training
for at least the first six months. *
TWO METHODS traditionally are used for pricing 401k retirement plan
administration services: the unit charge and time and expense. It's
becoming more common to use a hybrid of these two. rrp
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