This working paper surveys the decumulation services offered by investment robo-advisors as a case study with which to examine regulatory and market structure issues raised by automated financial advice. We provide a short introduction to decumulation, describing some of the uncertainties involved in identifying optimal decumulation strategies and sketching a few of the ‘rules of thumb’ that financial advisors have developed in this area in the face of this uncertainty. Next we describe behavioral effects that could inhibit consumers from following an optimal decumulation strategy, concluding that, left to their own devices, consumers are likely to make sub-optimal decumulation decisions. Then we describe some potentially useful automated decumulation services that are available on the market and present the results of a survey assessing whether those services are offered by investment robo-advisors. Finally, we discuss market structures that may inhibit financial advisors from implementing optimal decumulation strategies for their clients and explore whether there are regulatory strategies that could encourage financial advisors to provide better decumulation services. Two promising strategies are (1) adopting a record-keeping requirement for robo-advisors that is conceptually similar to the ‘black box’ requirement for commercial airlines, and (2) developing a set of robo-advice ‘do’s and don’ts’ and related input/output tests to confirm that these requirements are met.
Investment advice, financial services, automated decumulation, retirement planning, robo advisers, robo-advisers, roboadvisers, longevity risk management, consumer protection, behavioral effects, regulatory requirements
The Disruptive Impact of Fintech on Retirement Systems
Baker, Tom and Dellaert, Benedict, "Behavioral Finance, Decumulation, and the Regulatory Strategy for Robo-Advice" (2019). Faculty Scholarship at Penn Carey Law. 1993.
Banking and Finance Law Commons, Behavioral Economics Commons, Computer Law Commons, Consumer Protection Law Commons, Economic Policy Commons, Finance Commons, Finance and Financial Management Commons, Internet Law Commons, Law and Economics Commons, Policy Design, Analysis, and Evaluation Commons, Retirement Security Law Commons, Science and Technology Law Commons, Technology and Innovation Commons
In THE DISRUPTIVE IMPACT OF FINTECH ON RETIREMENT SYSTEMS (Julie Agnew & Olivia S. Mitchell eds., Oxford 2019)