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Unified Trust Company Comment Letter to EBSA on Proposed Rules for Pension Benefit Statements (PDF)

"We believe that unless certain steps are taken the statements can do more harm than good. Our concern is that an over simplified methodology can unintentionally mislead the plan participant. In particular, we are concerned that the proposed 'safe harbor' methodology will lead to widespread adoption by most vendors since it will be perceived as the only 'safe choice,' even though it mi ght give materially inaccurate projections and stifle innovation. We believe six modifications will greatly improve the proposed rule by adding flexibility and help more plan participants to reach retirement success."

Third Party Fiduciaries: Separating Myth from Reality (PDF)

"These [Third Party Fiduciary] arrangements are set up by companies that provide their own money management -- typically Insurance Companies or Mutual fund companies. They do this because they want to offer a fiduciary service in their product that makes them more marketable. But they cannot and will not be acknowledged fiduciaries to the plan because they have so many conflicts of interest that they would invariably violate the Prohibited Transaction rules of ERISA for virtually every plan they serve."

Are Hospital Plans Sick And University Plans Dumb? (PDF)

"The lawsuits consistently focus on determining 'the floor' of minimum costs that they say a plan should incur. The plaintiffs typically do not discuss whether the plan costs are at the median, rather they seem to believe all plans are 'commodities' of the same basic services and results. The plaintiffs also assume all the same outcomes in terms of retirement readiness and believe any costs above the floor 'are wasted.' They seldom, if ever, mention differences in retirement readiness in their arguments."

The Real Measure of 401(k) Plan Success (PDF)

"[W]hile the other frequently used measurements provide some indication of how various aspects of the plan may be working, they don't measure what sponsors, advisors, and participants, alike, need to know. Will the plan successfully provide each participant with an adequate benefit at retirement?"

Fiduciary Discretion: A Plan for Improving Outcomes (PDF)

"[Most plan] sponsors hire an institutional trustee for their plans -- after which many breathe a sigh of relief believing that they have also delegated their fiduciary responsibility, as it relates to plan assets, to the designated trustee. Most often, this isn't true."

Retirement Income Is Best Delivered As a Process-Driven Out-of-Plan Solution (PDF)

"Today 401(k) participants face not one but two immense challenges. The first is to simply figure out how to save and invest for retirement, and remain on track throughout their working career. The second is how to take the lump sum asset value of savings at the beginning of retirement and convert it into lifetime monthly income sufficient to reliably replace their paycheck. The second challenge highlights the need for reliable retirement income solutions. This has become more evident each year."

Using the Cost Benefit Ratio to Measure 401(k) Plan Value (PDF)

"Successful small plans with good cost/benefit ratios will on average have total annual costs of $600 to $1,100 for each successful participant. Successful mid-sized plans will on average have total annual costs of $500 to $900 for each successful participant. Successful large plans will on average have total annual costs of $400 to $750 for each successful participant. In all size categories unsuccessful plans will have costs 2-5 times higher."

New 401(k) Participant Disclosure Rules Appropriately Kill Automatic Prospectus Distribution Requirement (PDF)

28 pages. Excerpt: DOL recognizes that requiring the giving of prospectuses is still sensible, just not useful and probably even counterproductive when forced out to those who do not want them. The new 404a-5 rule therefore switches the prospectus requirement from 'push' to 'pull.' Under the new rules, fiduciaries need only give prospectuses when participants request them.... [F]iduciaries of participant-directed plans have an affirmative obligation to ensure participants have enough information to make informed decisions -- with prescribed format and content -- and 404(c) protection is not available unless this basic obligation is first met. When combined with the additional transparency initiatives DOL has already completed -- the new 5500 rules and the 408b-2 contract rules -- the new participant disclosures round out a sensible array of regulations[.]

Marketing Co-Fiduciary Advisory Services to Qualified Plans: Introduction and Knowledge Base

Excerpt: This is the first part of a three-part white paper on marketing co-fiduciary advisory services to qualified plans. The marketplace is undergoing a seismic shift in how 401k services are sold and delivered, and the purpose of this paper is to help advisors become leaders under the new advisory model.