ICI Data
Policymakers and regulators must use accurate data and sound economic analysis when proposing rules that could have a fundamental impact on Americans’ ability to save for retirement.
ICI expressed deep concerns about the economic analysis used by the Department of Labor (DOL) and the White House Council of Economic Advisers (CEA) in support of the DOL proposal. ICI data and analysis found that:
- Contrary to the DOL’s claims, investors who own funds that are sold with front-end loads actually have concentrated their assets in funds that outperform—not underperform—the average return for their fund category.
- The DOL ignored market realities and assumed that brokers will continue to offer advice and services despite substantial reductions in their compensation. It ignored the costs that investors would face if they could not afford to use brokerage accounts for retirement savings.
- The DOL failed to demonstrate that investment performance is different when an investor is advised by a fiduciary compared to when the investor is advised by a provider that is not a fiduciary.
- The DOL failed to identify and analyze societal harms resulting from its proposal—the inevitable risk that at least some retirement savers would lose access to advice and information they currently rely on to meet their savings goals.
- Despite DOL and CEA claims to the contrary, individual retirement account (IRA) investors are concentrated in funds that have lower costs on average, not in higher-cost funds.