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Federal
E-News  |
September 2006
Congressional Field Hearing Focuses on Public Plan Funding; Expect More to Follow The Subcommittee on Employer-Employee Relations of the U.S. House Committee
on Education and the Workforce held a field hearing in Springfield,
Illinois, on Wednesday, August 30, 2006, for the purpose of "examining
the retirement security of state and local government employees."
As expected, the hearing focused on funding issues, particularly those
that have become the focus of attention in the Illinois gubernatorial
race. Keith Brainard, NASRA's Director of Research, provided joint NCTR/NASRA
testimony, and Tom Lussier, president of Lussier, Gregor, Vienna &
Associates, NCTR's Federal Relations representative, was also present
to assist with the media, along with other public plan representatives.
Although the Chairman of the hearing, Minnesota Republican John Kline,
offered assurances that Congress was not prepared to begin regulating
public pension plans, a Committee press release issued after the hearing
which completely ignores any positive statements on public plans clearly
suggests that the foundation for such a Federal role is being prepared.
Heightened media attention to public pension issues also increases the
likelihood that more such Federal "fact-finding" efforts are
likely. The hearing, which had originally been scheduled for the beginning of August but was postponed, initially appeared to be more about local politics than some part of a Federal agenda regarding public plans. However, in the interim, former SEC Chairman Arthur Levitt issued his report on the City of San Diego's pension scandal, a number of new articles appeared in the national media criticizing public plan funding, particularly a series in the New York Times, and a new report by Standard & Poors cited funding declines for large city plans. The Times, pointing to San Diego, warned that "[a]cross the nation, a number of states, counties and municipalities have engaged in many of the same maneuvers with their pension funds." Furthermore, according to the August 8th article, "[i]t is hard to know the extent of the problems, because there is no central regulator to gather data on public plans. Nor is the accounting for government pension plans uniform, so comparing one with another can be unreliable." Finally, turning to Lance Weiss, an actuary with Deloitte Consulting in Chicago and an author of the recent Deloitte report discussed in the August NCTR Federal E-News, the Times story quoted him as saying: "There's no oversight; there’s no requirements; there's no enforcement." Not to be outdone, the Wall Street Journal weighed in with its August 18th editorial entitled "The Other Pension Crisis," stating "Now it's time to focus attention on the crisis in public pensions -- unless our politicians want to see San Diego's blow-up repeated elsewhere and often." The editorial concluded that "the current public pension system simply isn't sustainable in the long run" and that "[t]he long-term solution is for government to follow the private sector and wean public workers from the defined-benefit pension model to a defined-contribution plan…." In the midst of this, the report on San Diego’s pension woes found "years of reckless and wrongful mismanagement" of the city’s pension system by both city and pension board officials. Finally, Standard & Poors reported that, based on a sampling of the 20 most highly populated U.S. cities rated by S&P's Ratings Services, the mean funded ratio (the actuarial value of assets divided by the actuarial accrued liability) has dropped from 99.8% to 84% in the last 5 years. The rating agency attributed the drop to a variety of factors on both sides of the ledger, including poor investment performance, increased life spans of participants, and recent benefit enhancements. The report notes that a large contributing factor to the funding dip comes from the high exposure in equities for most funds, the steep drops in those assets in 2001 (16%) and 2002 (19%), and the impact of the smoothing of assets, typically over five years -- a practice that S&P notes "has the effect of not only cushioning the blow but also extending the effect, positive or negative, through the full smoothing period," meaning that fiscal 2002 losses would still be phased in through fiscal 2006. Clearly, these have all served to "up the ante" considerably,
and made the Congressional field hearing a potential magnet for further
bad press as well as a place holder for future Federal legislation.
Therefore, NCTR, NASRA and other public sector representatives worked
hard to ensure that the hearing was balanced, and that the press who
covered the hearing were provided with a true picture of the public
pension system’s condition nationwide. In addition to the NCTR/NASRA
joint testimony, a statement for the record was also filed by 26 national
organizations, including NCTR, representing public pension systems,
public employees, public employers, and public unions. This strong group
statement underscored that there is a united front regarding defined
benefit pension plans and that claims that there is a pension crisis
are unwarranted. The Hearing Congressman John Kline (R-MN) and Congresswoman Judy Biggert (R-IL) attended the hearing; due to scheduling problems, there was no Democratic member participating. Mr. Kline announced that "[w]e are not here to announce that the Federal government wants to be, or should be, in the business of regulating state and local pension plans." However, he also said that "whether it's today or years in the future, the looming crisis in public pension underfunding is real, and without action on some level, will not go away." Congresswoman Biggert also stressed that the hearing was not simply a local political ploy, but, following the hearing, told reporters that because Congress has recently been so involved in reforming the private pension system, "we continue on from the private sector to the public sector." Press coverage of the hearing has been generally balanced as of this writing. For example, while the AP reporter focused on the in-state politics surrounding pension funding, when he did turn to the national implications, he noted that despite "a growing gap between what's in the bank and what's owed by public pension systems across the country, some experts told the subcommittee they don't see a crisis." The story went on to cite Keith Brainard’s testimony that there is nothing "magic" about a fully funded plan, and even with no changes to current systems, benefits can be paid for decades without trouble. One of the GOP witnesses, University of Illinois economist Fred Giertz, was also quoted as saying "I don't think it's a crisis," referring to Illinois' situation. "It's a problem and it's a problem that entails some pain to deal with, but we have the wherewithal to deal with it," Giertz told the Subcommittee. Other coverage also focused on the Illinois situation, with charges
that Illinois pension funds were inaccurately portrayed as being in
a state of crisis. Louis W. Kosiba, executive director of the Illinois
Municipal Retirement Fund (IMRF), criticized the testimony of Deloitte’s
Lance Weiss, who he accused of "overstating Illinois pension fund
problems and failing to acknowledge that there are pension funds in
Illinois like IMRF that are well funded and secure." Kosiba told
reporters that, "[w]hen analyzing the issue of public pension plans,
experts need to start by examining healthy plans like IMRF and follow
their example." However, despite this relatively good press, the full Committee on Education and the Workforce issued a press release after the hearing that speaks of a "troubling trend of underfunded state and local pension plans" and makes no mention whatsoever of the NCTR/NASRA testimony or any other statements defending pubic DB plans. Instead, the press release quotes Congresswoman Biggert as saying: "Just as I worked to reform private pension laws on behalf of my constituents who rely on the traditional retirement system, I feel the need to examine the public pension crisis in greater depth as well…." The Congresswoman goes on to state that "[t]axpayer dollars not only serve as the primary funding source for state and local pensions, but they also could be used to bail out a collapsed public plan," despite testimony to the contrary on both points. Finally, the press release points out: "Unlike private pension plans, which are required by the recently-enacted Pension Protection Act to reach a funding level of 100 percent, public pension plans are not held to the same federal standard." As Bob Dylan says, "You don't need a weather man to know which way the wind blows." No further hearings have been scheduled by the Education and the Workforce Committee, which technically has jurisdiction only over private pension plans subject to ERISA. However, in anticipation that some in Congress, flush with having "solved" the problems for private sector DB plans, may now be pushing for a similar exercise focused on funding of public plans, NCTR and a coalition of public sector organizations are already scheduling meetings with key Congressional staff on both this House Committee as well as its Senate counterpart, the Health, Education, Labor and Pensions (HELP) Committee. These meetings will underscore that public pensions are not in a state of crisis, but are instead generally well-funded with extensive regulation and public oversight. Where problems exist, they can and will be addressed at the State and local level, and do not require Federal intervention to see that they are properly fixed.
H.R. 4, the Pension Protection Act of 2006, became Public Law 109-280 when President Bush affixed his signature to it on August 17, 2006. NCTR’s President, Clare Barnett, was present at the bill signing ceremony held in the historic Dwight D. Eisenhower Executive Office Building adjacent to the West Wing of the White House. While there is much in the new law for the public sector to celebrate – from EGTRRA permanency to important clarifications affecting the purchase of service credits – implementation of the new public safety retiree health benefit is generating considerable concern among affected plans. Efforts are underway to obtain IRS guidance on the new program, which is eligible to be implemented beginning in 2007. The President was joined by three of his cabinet members as well as several Senators and Congressmen, including Senator Mike Enzi (R-WY), Chairman of the Senate Health, Education, Labor, and Pensions (HELP) Committee, House Majority Leader John Boehner (R-OH), and Congressman Bill Thomas (R-CA), Chairman of the House Ways and Means Committee. In his prepared remarks, the President praised the bill’s focus on funding, pointing out that the legislation "insists that companies measure their obligations of their pension plans more accurately." He also noted that it "closes loopholes that allow underfunded plans to skip pension payments," and singled out the fact that the new law "prevents companies with underfunded pension plans from digging the hole deeper by promising extra benefits to their workers without paying for those promises up front." The new law’s road to enactment was a rocky one, and there were times when many in Washington predicted that it would not be finalized before the 109th Congress adjourned for the November elections. However, after some last-ditch, last-minute daredevil maneuvers on the part of the House leadership, the pension bill finally managed to fight its way free of other, more controversial agendas. In the meantime, it helped wreak major violence on the role of the Congressional conference committee in the legislative process. Now that the dust is settling, new bumps in the road are being identified. As always, new laws raise questions of implementation. However, the requirement that plans pay qualified health insurance premiums directly to providers from retiree benefits on a pre-tax basis is raising a number of particularly thorny issues, and many affected plans -- particularly those that are not presently involved with the administration of health benefits – are concerned with new administrative burdens and their associated costs. NCTR is working with NCPERS and other organizations who were involved with the drafting of the original provision to sort through some of these issues and provide guidance to affected members. One approach that is being developed involves a letter to the Internal Revenue Service requesting answers to a number of questions that have been raised. If you have additional questions/issues, please forward them to us so that they can hopefully be included in any final request. NCTR will serve as a clearinghouse on this subject for our members as questions, comments and suggested responses are developed. Since it is likely that there will be a "lame-duck" session of Congress following the November elections, it is possible that technical corrections to the new pension law will be under consideration. Therefore, it is most important that any needed changes with regard to this particular provision be identified as soon as possible.
New Revenue Ruling on Employer Pick-Up Avoids Controversy The Internal Revenue Service on Aug. 8 released a new ruling clarifying the conditions that must be met in order for employer "pick-ups" of employee contributions to public pension plans to be non-taxable for the worker. Despite concerns that the new ruling might impose burdensome new restrictions on the elective pick-ups of purchased service credits, it is a fairly straightforward statement of the conditions that must be met for pick-ups to be treated as employer contributions -- and, thus, not counted in the employee's gross income – focusing on formal written documentation of the date a governmental employer becomes responsible for making the plan contributions of their employee. Revenue Ruling 2006-43 addresses the types of actions that are required for a governmental entity to "pick up" employee contributions so that they are treated as employer contributions under Internal Revenue Code Section 414(h). Specifically, a contribution to a qualified plan established by a State or local government will not be treated as picked up by the employing unit under Section 414(h)(2) unless the employing unit (1) formally specifies that the contributions, although designated as employee contributions, are being paid by the employer; and (2) does not allow employees to either opt out of the "pick-up," or to receive the contributed amounts directly. The formal action that is required must be taken by a person duly authorized to take such action with respect to the employing unit, and the action must apply only prospectively and be evidenced by a contemporaneous written document (e.g., minutes of a meeting, a resolution, or an ordinance). In order to provide adequate time to come into compliance with this requirement, governmental entities are given until January 1, 2009, to obtain the required documentation. Several IRS private letter rulings (PLRs) have allowed purchases of service credit (including those made in connection with an employee's election that occurred after the employee began participating in the relevant plan) to be treated as picked up. In addition, at least one PLR allowed an employee to make more than one election to have purchases of service credit picked up. There were concerns that the new Revenue Ruling was intended to adversely impact such rulings. However, it explicitly provides that it does not modify or revoke any private letter ruling issued to any taxpayer prior to August 28, 2006.
President Announces New Health IT Initiative President Bush signed an Executive Order on August 22, 2006, intended to promote transparency, health information technology (health IT) standards, quality and efficiency measurements and incentives such as pay for performance in the U.S. healthcare marketplace. Specifically, the Order directs major Federal agencies that administer or support health insurance programs to take certain steps that should result in more complete and open information for consumers, including the use of interoperable health IT products, so that data can be easily shared. The Administration intends to encourage other employers, including private industry as well as state and local governments, to band together and sway their healthcare providers to do the same thing. However, without legislation, the Administration cannot provide funding for health IT or require national standards for interoperability for all purchasers. Congressional action is still needed, but the future of health IT legislation remains unclear. The President’s order applies to the Medicare (but not Medicaid) program; TRICARE and other systems under the Department of Defense; the Federal Health Benefits Program; Indian health care programs; and the Veterans Administration's healthcare network. Medicaid and the Children's Health Insurance Program (CHIP), designed for families who earn too much money to qualify for Medicaid, yet cannot afford to buy private insurance for their children, are not affected. According to the Department of Health and Human Services (HHS), the Executive Order affects about one in four Americans with health coverage. In addition to health IT mandates, the Federal agencies will have to improve their data reporting on the cost and quality of health care they provide and make that information available to those in the health programs they administer. This will include some gauges of care quality, such as a possible star-rating system for hospitals. Beneficiaries will receive price information for run-of-the-mill medical procedures so that they will be able to tell if they are being over-charged. According to the Administration, consumers will then be able to bring market pressures to bear and costs will be lowered through more aggressive competition. "The fact is, if you have excellent information about quality, about service and about price, people make good decisions," the President explained. Along with these "transparency" initiatives, the Executive Order also requires affected Federal agencies to use interoperable computer systems and electronic health records (EHR) wherever possible. These Federal departments are also to promote the same kind of gradual improvements in capability outside of the government through their contracts with providers, plans, or issuers. The agencies need to begin the process by January 1, 2007. In the meantime, legislation that could provide monies necessary to fund health IT, as well as the establishment of national standards of interoperability, remains on hold, awaiting the appointment of conferees once the Congress returns from its August recess on September 5th. The House passed its version of the health IT (H.R. 4157) by a vote of 270-148 on July 27, 2006, which must now be reconciled with its companion Senate bill, S. 1418, passed last year by a unanimous vote of that chamber. However, there is some concern that partisan squabbles that served to delay House consideration of what was previously thought of as easily “do-able” health legislation may prevent the appointment of conferees. And, the example of the new pension bill notwithstanding, no conference agreement typically means no final bill for the President’s consideration. Whether the new White House initiative will serve to further discourage Congressional action for the remainder of this Congress – or spark a renewed effort to share the limelight -- remains to be seen.
As Criticism of Sarbanes-Oxley Continues, SEC Extends Compliance Dates for Smaller Public Companies Amid continuing complaints that compliance with the Sarbanes-Oxley Act (SOX) is unnecessarily increasing costs while providing little if any benefits for investors, the Securities and Exchange Commission (SEC) announced on August 9, 2006, that it has proposed extended compliance deadlines in connection with Section 404 of the Act for smaller public companies. In addition, the agency has proposed a new transition period for the filing of Section 404 reports by all newly public companies, and has granted a one-year extension of compliance dates with certain auditor requirements for about one quarter of all foreign private issuers that are subject to the Exchange Act. Nevertheless, for some, SOX is beyond repair, and nothing short of outright repeal will prove satisfactory. The SEC’s actions were taken in furtherance of the "next steps” for the implementation of SOX that the Commission announced when it decided in May of this year to ignore the advice of its Advisory Committee on Smaller Public Companies and determined that ultimately "all public companies will be required to comply with the internal control reporting requirements of Section 404." The new proposal would extend the date by which the smallest filers must start providing a report by management assessing the effectiveness of the company's internal control over financial reporting, providing them with an additional year. In addition, the date by which they must begin to comply with the Section 404(b) requirement to provide an auditor's attestation report on internal control over financial reporting in their annual reports would also be extended. In addition, for any newly listed public company, including a foreign private issuer that is listing on a U.S. exchange for the first time, the SEC has proposed that such a company would not be required to provide either a management assessment or an auditor attestation report pursuant to Section 404 until it has previously filed one annual report with the Commission, thereby providing a new, one-year transition period. Finally, the SEC has acted to provide a one-year extension of the compliance dates for the Section 404(b) auditor attestation requirement for certain foreign private issuers who are "accelerated filers." (Generally, an accelerated filer is one which has a common equity public float of $75 million or more and is not eligible to use small business issuer forms.) Only the largest accelerated filers will still be required to meet the current deadlines. According to the SEC, its proposals for smaller public companies will help significantly ease compliance burdens with Section 404 of SOX. Furthermore, according to John W. White, Director of the SEC’s Division of Corporation Finance, the proposed transition relief for newly public companies "should enhance the attractiveness and cost-effectiveness of participating in our markets both for companies contemplating IPO's and for foreign companies considering listing in the U.S. for the first time, without sacrificing important investor protections." However, for some, including William A. Niskanen, chairman of the Cato Institute, this is still not enough. In an August 2nd article, the head of this well-respected Libertarian think tank (that has, it should also be noted, been a long-time advocate of Social Security privatization) said that SOX substantially increases the risks of serving as a corporate officer or director; decreases the chance that foreign and small firms will list their stock on an American exchange; and reduces the incentive of corporate executives and directors to seek legal advice. "At a minimum,' he says, "Congress should clarify that the criminal penalties in the SOX require proof of malign intent and personal responsibility for some illegal act." In addition, if Congress were wise, it would also eliminate the "expensive new and wholly unnecessary PCAOB." But, he argues, a "Congress that is both wise and brave would repeal the SOX – lock, stock, and barrel." Given that wisdom and bravery do not appear to be among Congress’ long suits of late, it is unlikely that such repeal will take place anytime soon. But as the debate continues to rage over the question of whether the benefits of Sarbanes-Oxley outweigh its costs, reform of the landmark 2002 law may well be in the works in the next Congress. This is particularly true if Republicans retain control of the House of Representatives in November.
Federal Small Business Advocate Calls for Repeal of New 3% Withholding Mandate The Federal government’s Chief Counsel for Advocacy has called for the repeal of the new 3 percent withholding requirement adopted in the dark of night as part of the Tax Increase Prevention and Reconciliation Act (TIPRA), the new tax law that extended President Bush’s capital gains and dividend tax cuts for another two years. This unfunded intergovernmental mandate would require that, beginning in 2011, all states and many local governments, as well as certain instrumentalities thereof, withhold three percent on all payments to persons providing them with property or services. Although it does not appear that this requirement would apply to pension payments, it would certainly appear possible that it could apply to a number of plan activities, such as consultant contracts, fees paid to money managers, and payments to healthcare providers where the plan administers health benefits. Legislation was introduced to repeal the provision by Senator Larry Craig (R-ID) on the same day the provision became law, but to date, no action has been taken on the bill, S. 2821. The Chief Counsel for Advocacy was created as an independent office within the U.S. Small Business Administration (SBA), and is charged with representing the views of small businesses before Federal agencies and the Congress. In an August 31st letter to Senator Craig, Thomas M. Sullivan, the current Chief Counsel for Advocacy, expressed his support for S. 2821, stating that the TIPRA withholding provision will "impede the cash flow of small entities" and "amounts to a tax penalty on government contractors without a clear path for reimbursement." Mr. Sullivan also noted that his views do not necessarily reflect the views of the SBA or the Administration. Sullivan said that the provision was not just a problem for small businesses, pointing out that it may also impose "unintended administrative costs on all levels of government required to collect the tax." At a minimum, the new requirement will require changes to be made to the accounting methods and software used by governmental jurisdictions. "That may be why the Congressional Budget Office described the withholding provision as an unfunded intergovernmental mandate," Sullivan pointed out. While this new law and its provisions were first reported on in the June NCTR Federal E-News, there has been little feedback concerning its potential impact on NCTR member systems. If you have not yet done so, please provide NCTR with your input as to the potential impact, if any, of this provision on your plan. Since it was adopted in part to provide additional Federal revenue, estimated at $7 billion dollars over 10 years once implemented, any repeal of the provision will impose a “cost” that will have to be paid for in the form of offsetting revenue increases. Therefore, even though 2011 may seem to provide plenty of time, getting this provision eliminated will not be as easy as it might at first appear.
GASB Announces New Project on Disclosure Requirements for Governmental Pension Plans and New Research Initiative to Assess Effectiveness of Existing Governmental Pension Accounting Standards The Governmental Accounting Standards Board (GASB) announced on August 31st that it would be adding a new project to its current technical agenda, "to be completed expeditiously," that is intended to bring current pension disclosure requirements for governments in line with those recently required for other post-employment benefits (OPEB). In addition, a concurrent research project to determine the effectiveness of existing governmental accounting standards in this area is also being conducted. Depending upon "constituent feedback," further changes to current governmental accounting standards for pensions may be imposed. The action comes at a time when complaints in the media and elsewhere regarding current accounting standards approved for use by governmental plans have been increasing and GASB’s slow process of reviewing them for improvement has also been criticized. A formal proposal is expected before the end of 2007. The short-term project is geared to addressing "certain shortfalls" in pension disclosures that GASB says were first identified during the development of the OPEB standards. Some of the new disclosure requirements that might be required to be included in the notes to the financial statements of plans and certain employers include the current funded status of the plan as of the most recent actuarial valuation date; the funded status and a multi-year schedule of funding progress using the entry age actuarial cost method in certain instances; and additional disclosures about actuarial methods and assumptions used. Also, disclosure by cost-sharing employees of how the contractually required contribution rate is determined might also be a new requirement, as well as the presentation of the required schedules for a cost-sharing plan in which an employer participates in the employer's report in certain instances. According to Robert Attmore, GASB Chairman, "While accounting standards do not and cannot require funding of such pension plans, the information they provide enhances constituent knowledge about how well these obligations are being met." IBM Wins Appeal; Cash Balance Conversion Ruled Legal A lower court decision that had called into question conversions of defined benefit plans to cash balance plans as age discriminatory has been overruled. While the case involved ERISA language protecting older workers’ benefits, the same statutory provisions are included in the Age Discrimination in Employment Act (ADEA), which applies to public pension plans. The recently-enacted Pension Protection Act contains amendments to ADEA as well as ERISA that generally mirror the new court ruling. On August 7, 2006, the U.S. Court of Appeals for the Seventh Circuit overturned a 2003 ruling by the U.S. District Court for the Southern District of Illinois in Cooper v. IBM Personal Pension Plan that found that IBM discriminated against older workers in violation of the Employee Retirement Income Security Act (ERISA) when it converted from a defined benefit plan to a cash balance plan in 1999. IBM’s cash balance plan provided that 5% of an employee’s annual taxable income would be credited to his or her account, which was to earn interest at a rate of 100 basis points above the rate on one-year Treasury bills. The conversion was challenged as age discriminatory because, under this formula, when an individual’s accrued benefit is valued as an annuity payable at age 65, the rate of growth in the accrued benefit is lower for older employees than for younger employees. That is, the rate of a participant’s benefit accrual diminishes the closer the participant is to age 65. The U.S District Court ruled that this formula therefore violated ERISA’s prohibition against ending a benefit accrual or reducing its rate on account of age. However, the Seventh Circuit found instead that the district court was incorrect when it equated "benefit accrual" with "accrued benefit." "Benefit accrual," according to the appellate court, refers to the amount the plan sponsor puts into the plan for each employee, while "accrued benefit" refers to the final amount which plan participants can withdraw when they retire. In short, the district court was wrong to treat the "time value of money" as age discrimination. "[E]very covered employee receives the same 5% pay credit and the same interest credit per annum," the court noted. Neither allocations nor accruals stopped based on age, nor did the rate at which they accrued. The fact that younger employees had more time to accrue interest did not mean that the plan discriminated against older workers. "Under the district court’s analysis,' the Seventh Circuit pointed out, "compound interest becomes a scourge, for the younger the employee when any given year’s salary is earned, the greater the payout ‘expressed in the form of an annual benefit commencing at normal retirement age.’" Finally, the new ruling also underscores that merely because an older worker would have received more under a former plan (in this case, IBM’s original DB plan) does not constitute age discrimination. As the court notes, "a cash-balance plan removes the backloading of the pension formula; older workers (accurately) perceive that they are worse off under a cash-balance approach than under a traditional years-of-service-times- final-salary plan." However, the court goes on to say, "removing a feature that gave extra benefits to the old differs from discriminating against them. Replacing a plan that discriminates against the young with one that is age-neutral does not discriminate against the old." The Pension Protection Act's amendments dealing with cash balance plans are generally consistent with this ruling. The new law amends both ERISA and the tax code as well as the ADEA by providing that a cash balance plan is not age discriminatory if a participant’s accrued benefit is equal to or greater than that of any "similarly situated" younger participant. ("Similarly situated" means identical in every respect, such as period of service, salary, position, etc.)
EBRI Sees Progress in 401(k)s, But Half of Accounts Still Below $20,000
Among 401(k) plan participants who held accounts from 1999 to 2005, the average account rose about 50 percent during that time to $102,014. The average for all participants, however, was $58,328 and the median was just $19,398. The numbers are pulled from a database maintained by EBRI and the Investment Company Institute that holds information on 17.6 million 401(k) plan participants.
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