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Nokia of America 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $4.50bn of the $9.83bn in the Nokia of America 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

24,381 people have a balance in the Nokia of America 401(k), and it holds $9.83bn. Of the $4.51bn whose vehicle the plan reports, essentially all of it sits in funds that publish no record of how they voted your shares — collective trusts and separate accounts, which unlike a mutual fund file no Form N-PX and leave no public trace of a single vote.

SourceThe plan’s own annual report to the Department of Labor — Form 5500, Schedule H, plan year 2024 · filed by NOKIA OF AMERICA CORPORATION as “NOKIA SAVINGS/401(K) PLAN” · EIN 223408857, plan number 003 · search the filings

What the plan holdsVoting recordValue
Common/collective trusts NONE $4.50bn
Directly held common stock Voted by the plan trustee $2.25bn
Government bonds No shares to vote $699m
Corporate bonds (other) No shares to vote $297m
Corporate bonds (preferred) No shares to vote $246m
Participant loans No shares to vote $22m
Registered funds (mutual funds and ETFs) PUBLISHED $15m
Employer stock Voted by the plan trustee $252,000
Directly held preferred stock Voted by the plan trustee $176,000

Every asset class the plan itemised on Schedule H, straight from the filing. These are categories, not fund names: Schedule H asks what KIND of vehicle the money is in, never which one, which is why no fund is named on this page.

Why there is no list of Nokia of America’s funds anywhere

Some employers file a Form 11-K with the SEC each year, and it contains a schedule naming every investment in the 401(k), fund by fund. Nokia of America does not file one, and that is not an oversight: a plan only has to file an 11-K when interests in it are registered securities, which in practice means the 401(k) offers a company stock fund. Plans that pay equity as RSUs outside the plan, as most large technology employers do, never trigger the requirement.

So the only public account of this plan is the Form 5500 above, which reports what categories the money sits in and never which funds. That is the whole reason this page can tell you 99.7% of the identified money votes in secret and cannot tell you which manager cast those votes.

Why the secrecy, and what you can do

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.

Check whether your plan offers any registered mutual 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 →

CoverageThe plan reports the vehicle for 81.7% of its assets. The remaining $1.74bn is filed under headings that do not say what kind of vehicle holds it, and is excluded from the percentage above 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.

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