Seven suggestions for designing a 401(k) investment menu

Part of your job as a retirement plan sponsor is to select and monitor investment lineups—in fact, these are your duties as an ERISA fiduciary. There’s a lot you need to consider as you make your choices. Here are seven considerations to designing a 401(k) investment menu that can help you implement a prudent process for selecting and monitoring investments and help you as an ERISA fiduciary.

Designing a 401(k) investment menu requires balancing different needs. You have a fiduciary responsibility to choose investments with the skill of a prudent person and to monitor those investments with care and diligence.¹ An investment menu should be diverse enough to satisfy a wide range of participant objectives—but not have so many choices that participants become overwhelmed. Consider adopting a written investment policy statement (IPS) to guide your decisions. 

Suggestion #1—Follow a written 401(k) investment policy

You may want to formalize your goals as a plan sponsor—what you expect your 401(k) plan to accomplish for your participants—and the process you’ll follow to achieve them in a written IPS. An IPS isn’t required by ERISA, so no two are exactly alike. But there are certain elements that every IPS should contain, such as:

  • Your plan’s investment objective—for example, replacing a certain percentage of preretirement income
  • Individual roles and responsibilities—stating who in your organization or among your service providers is responsible for what
  • Investment selection and monitoring criteria—outlining how investments are chosen, how they’ll be evaluated, and how they’ll be changed (if needed)
  • Participant education and communication—defining how the plan will fulfill its obligations under ERISA Section 404(c) to provide participants with investment information material

Some IPS documents contain specific language and read like an instruction manual, while others are more general. Talk to an ERISA lawyer about the most appropriate level of detail for your plan. Whether detailed or more general, it’s important to maintain flexibility, which may be accomplished by noting that the IPS can be amended at any time. And remember to follow the IPS and document your decisions in the form of meeting notes, to prove that you followed a prudent process.  

Suggestion #2—Pick 401(k) investments purposefully

If the plan is intended to comply with ERISA Section 404(c), which protects plan fiduciaries from losses due to participant investment choices, the plan must offer a broad range of investment options and meet certain requirements. This means that the plan’s investment menu offers at least three investments that:

  • Are diversified, such as mutual funds that own many securities,
  • Have materially different risk and return characteristics,
  • Allow participants to diversify by selecting investments with risk and return characteristics within an appropriate range geared for the plan’s participants, and
  • When added to other investment options under the plan, tend to minimize participant investment risk by adding greater diversification.  

A typical 401(k) plan offers 28 investment options.

Source: BrightScope/Investment Company Institute, 2020.

Three funds likely represent too few, while 28 funds—which is what a typical 401(k) plan offers—may be too many. Offering too many investments can lead to participant confusion and flawed shortcuts, such as allocating an equal amount to each.²

How can you avoid these extremes? Start with the principle that every investment should serve a purpose (e.g., stock funds provide growth, bond funds deliver income, and capital preservation funds provide safety). Then, look for a fund to serve each purpose, and consider avoiding overlap.  

Suggestion #3—Shop around for the best manager for the job

You probably don’t rely on the same vendor for paper supplies and digital storage. Think of your investment managers as vendors providing different kinds of market exposure. Some are experts in stock fund management, while others specialize in bond fund management. While it’s possible that a certain manager excels in many areas, firms that specialize can develop an edge in the context of today’s complex financial markets. It’s worth focusing, therefore, on finding and hiring managers who are the best at what they do—keeping in mind that an individual asset manager doesn’t need to answer all of your 401(k) investment option needs. 

Suggestion #4—Consider including passive and active funds

A passive (or index) fund attempts to match the performance of a market-tracking stock, bond, or hybrid index by offering broad, cost-effective market exposure and using automated rules for buying and selling. An active fund attempts to outperform a market-tracking index through the selection of the underlying investments by using fundamental analysis, quantitative strategies, or a combination of investment disciplines. Passive and active management can both play a role in a diversified portfolio, serving different purposes and appealing to different investors. 

Suggestion #5—Consider lowest-net-cost 401(k) investments

There are many ways to pay your retirement plan provider and your other retirement plan partners. Consider using lowest-net-cost share classes, no matter how you pay for recordkeeping expenses. Otherwise, your participants may be paying more than they have to for investment management.

Suggestion #6—Make sure fees are reasonable

Generally, under ERISA, reasonable fees mean that they’re in line with going market rates. With investments, an accepted way to determine whether fees are reasonable is to benchmark them. Keep in mind, however, that there’s no requirement to use the least expensive funds; fees must be reasonable, with consideration given for the services provided. A relatively high fee may be reasonable if a manager delivers something unique and valuable—such as high returns. And lower fees may not be reasonable if the fund’s performance is inferior. When you’re comparing cost, consider net-of-fee performance.  

Suggestion #7—Select your 401(k) default fund carefully

When a participant doesn’t make an investment choice for elective deferrals or employer contributions or when a participant who’s automatically enrolled doesn’t make an investment choice, their money goes into a plan’s default fund. To obtain fiduciary relief, most 401(k) plans offer a qualified default investment alternative (QDIA). By law, a QDIA must be³:

  1. A target-date fund (TDF),
  2. An asset allocation or balanced fund, or
  3. A professionally managed account.
75 percent of plan sponsors use at target date fund as their qualified default investment.

TDFs⁴ and asset allocation/balanced funds⁵ offer professional management, diversification, and automatic rebalancing in an all-in-one option. TDFs are a popular choice for a QDIA because their asset allocations “glide” with a participant’s changing risk profile as they near retirement.

A professionally managed account also does all of these things, with the added benefit of personalization. Which QDIA is right for your plan depends on how much your workforce’s goals and retirement readiness vary.

A diverse 401(k) investment menu can help you and your participants

There’s a lot of factors to balance when you’re choosing the investments for your 401(k) investment lineup. An IPS can help guide your process and decision-making, and meeting notes can provide evidence of prudence when making fiduciary decisions. Your investment strategy should strike the right balance of simplicity and diversification, as well as active and passive management. And the plan’s investment offerings and QDIA will depend on your participants’ goals, level of investment knowledge, and need for assistance with investing. These seven considerations—and the assistance of a financial professional—can help you strike the right balance.

1 29 U.S. Code §  1104 – Fiduciary duties. 2 “Heuristics and Biases in Retirement Savings Behavior,” Journal of Economic Perspectives, American Economic Association, 2007. “Fact Sheet: Default Investment Alternatives Under Participant-Directed Individual Account Plans,” Employee Benefits Security Administration, U.S. Department of Labor,, September 2006. The target date is the expected year in which investors in a target-date portfolio plan to retire and no longer make contributions. The investment strategy of these portfolios is designed to become more conservative over time as the target date approaches (or, if applicable, passes) the target retirement date. Investors should examine the asset allocation of the portfolio to ensure it is consistent with their own risk tolerance. The principal value of your investment, as well as your potential rate of return, is not guaranteed at any time, including at, or after, the target retirement date. Asset allocation does not guarantee a profit or protect against a loss. Asset allocation may not be appropriate for all participants, particularly those interested in directing their own investments.

For complete information about a particular investment option, please read the fund prospectus. You should carefully consider the objectives, risks, charges, and expenses before investing. The prospectus contains this and other important information about the investment option and investment company. Please read the prospectus carefully before you invest or send money. Prospectus may only be available in English.

The content of this document is for general information only and is believed to be accurate and reliable as of the posting date, but may be subject to change. It is not intended to provide investment, tax, plan design, or legal advice (unless otherwise indicated). Please consult your own independent advisor as to any investment, tax, or legal statements made herein.

There is no guarantee that any investment strategy will achieve its objectives. 

MGTS-P 42992-GE 09/20-42992       MGR0911201299944