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Dillard's 401(k) retirement plan: the investment options
Does your 401(k) vote the way you would? $266m of the $2.88bn in the Dillard's plan votes in secret. Fidelity 500 Index Fund, the most common fund in the plans we track, publishes every vote: answer 3 of its ballots, then see your result.
The question on the ballot
As filed
Dillard's 401(k) match and balances, from the filing
- Company money in
- about $850 per active participant
- $22m in plan year 2024
- Employees saved
- about $1,950 each
- $51m in plan year 2024
- Average balance
- $81,300
- 36,958 people with a balance
- In the plan
- $3.00bn
- at the end of plan year 2024
Company money is the match plus any other employer contributions, averaged over all 26,070 active participants, including anyone who did not contribute. The filing reports dollars, not the match formula; the plan’s summary plan description states the formula.
SourceThe plan’s annual report to the Department of Labor — Form 5500, Schedule H, plan year 2024 · filed by DILLARD'S, INC. as “DILLARD'S, INC. INVESTMENT & EMPLOYEE STOCK OWNERSHIP PLAN” · EIN 710388071, plan number 111 · search the filings
The Dillard's 401(k) holds $2.88bn. Of the $266m we could identify from the plan’s own filing, every dollar sits in a fund that publishes no record of how it voted your shares — collective trusts, which unlike a mutual fund file no Form N-PX and leave no public trace of a single vote.
SourceDillard's’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing
| What the plan holds | Vehicle | Voting record | Value |
|---|---|---|---|
| Dillard's, Inc.listed as “Common Stock, par value $.01 **” | Employer stock | Voted by the plan trustee | $2.09bn |
| SEI Trust Companylisted as “Galliard Stable Return Fund X **” | Collective trust or separate account | NONE | $175m |
| State Streetlisted as “State Street S&P 500 Index SL Class II **” | Not identified from the filing | Not counted either way | $147m |
| Harbor Fundslisted as “Harbor Capital Appreciation CIT Class 4 **” | Collective trust or separate account | NONE | $91m |
| Dodge & Coxlisted as “Dodge & Cox Income X **” | Not identified from the filing | Not counted either way | $70m |
| American Fundslisted as “American Funds Washington Mutual Investors R6 Fund **” | Not identified from the filing | Not counted either way | $68m |
| JP Morganlisted as “JP Morgan Mid Cap Equity R6 Fund **” | Not identified from the filing | Not counted either way | $42m |
| State Streetlisted as “State Street U.S. Bond Index SL Class XIV **” | Bonds | No shares to vote | $39m |
| State Streetlisted as “State Street Global All Cap Equity ex-US Index SLClass II **” | Not identified from the filing | Not counted either way | $30m |
| State Streetlisted as “State Street U.S. Inflation Protected Bnd Idx SL Cl II **” | Not identified from the filing | Not counted either way | $27m |
| American Fundslisted as “American Funds EuroPacific Growth Fund R6 **” | Not identified from the filing | Not counted either way | $21m |
| Goldman Sachslisted as “Goldman Sachs Small Cap Value Fund Inst I **” | Not identified from the filing | Not counted either way | $20m |
The 12 largest holdings in the plan. “Vehicle” is the description the filing itself gives each investment.
Why there is nothing to show
A mutual fund has to file Form N-PX every year listing every vote it cast on your behalf. A collective investment trust does not. It is a bank-run vehicle sold only inside retirement plans, it is cheaper, and it is now where most 401(k) default money sits — including most target-date funds, which is where savers who never chose anything are put.
So the shares bought with Dillard's employees’ retirement savings are voted every proxy season — on executive pay, on board seats, on climate and workforce proposals — and there is no public document anywhere recording how. This is not an oversight by Dillard's; it is what the disclosure rules currently require, which is to say: nothing.
What you can do
Check whether your plan offers any registered fund as an alternative — those publish their records, and you can read them here. If it does not, the menu itself is the thing that has to change, and that is a decision made by the plan’s fiduciary committee, not by you alone.
See how funds that do publish voted →
CoverageWe classified 83.6% of this plan’s assets from the filing. The figure above is the share of the money we could classify; anything we could not identify is excluded from it rather than assumed either way.
Other employer plans
The largest employer plans on the site, and a few more. Each page shows what the plan’s funds did with the shares its savers paid for.