t key - lockton · during the interview process, you should be prepared to provide detailed...

The KeyThird Quarter 2011

Issued by Lockton Retirement Services

INSIDE THIS ISSUE

L O C K T O N R E T I R E M E N T S E R V I C E S

EBSA CONFIDENTIAL:Understanding the Mystery of

Retirement Plan InvestigationsPages 1-6

At some point, every retirement and employee benefits plan sponsor

is likely to receive a notice of investigation from the United States

Department of Labor’s EBSA, let us help explain how to assess your

risk of being selected for investigation, or if needed how to navigate an

investigation.

TAX REFORM:Changes in PBGC Premiums Could Create a New Outlook for Defined

Benefit Plan SponsorsPages 7-11

The recent deficit reduction and tax reform debates in Washington

have generated many major proposals that could drastically affect the

retirement industry.

SIX STEPS TO GET YOUR EMPLOYEES

“RETIREMENT-READY” IN 2012Pages 12-15

A workforce that is financially unprepared for retirement can have a

significant impact on company profits and productivity levels, with these

six steps help create a “retirement-ready” workforce.

continued on page 2

EBSA Confidential: Understanding the Mystery of Retirement Plan Investigations

By: Steven P. Kjar and Samuel Henson, J.D.

At some point, every retirement and employee benefits plan sponsor is likely to receive a notice of investigation from the United States Department of Labor’s Employee Benefits Security Administration (EBSA). At Lockton, we are often asked by plan sponsors to assess their risk of being selected for investigation, or unfortunately for some, to assist them in navigating a current EBSA investigation. We have found that the investigative process is a mystery to many in the retirement plan and employee benefits community. This article will shed light on what gets a plan sponsor investigated, what it is likely to experience, and offer a few tips to ease the pain if you are selected.

Background

EBSA is granted authority under the Employee Retirement Income Security Act (ERISA) §504 and §506 to conduct civil and criminal investigations of employee benefit plans. An EBSA “investigation” may also be referred to as an “audit.” These terms are distinctions without a difference. The specific term used is based on the background of the EBSA enforcement official conducting the review. Historically, EBSA hired accountants, who were given

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the title “auditor” and conducted audits. In recent years, EBSA has hired a large number of attorneys who are given the title of “investigator,” and conduct investigations. Both the investigators and auditors of EBSA are trained in the same manner and given the same enforcement authority. From a practical standpoint, you would not see a noticeable difference in the scope or process of the review.

EBSA will conduct investigations on plans, plan sponsors, service providers, custodians, consultants, advisors, trustees and any other individual who it believes to be a fiduciary.

All plans subject to Title I of ERISA may be subject to an EBSA investigation including:

Retirement Plans

� Single Employer

� Multiemployer

� Defined Benefit

� Defined Contribution

� Some 403(b), 457 plans, and nonqualified plans

Welfare Benefit Plans

� Single Employer

� Multiemployer

� Fully Insured

� Self-Insured

EBSA investigations are not random. Yes, you read that correctly; no EBSA investigation is random. Other governmental agencies such as the IRS, may conduct random examinations by selecting a certain number of tax returns for review. However, EBSA investigations are triggered by an event or a discovery of specific information. The cause for most investigations is one of the following:

Annual Report “Red Flags”

The Annual Report Form 5500 is now submitted electronically to EBSA. Shortly after you submit your Annual Report, EBSA’s enforcement division will have access to its contents. EBSA uses a sophisticated software system that

Participant complaints Co-fiduciary

referrals

EBSA enforcement projects

EBSA Confidential (continued)

Third Quarter 2011 • The Key

3

can manipulate the data going as far back as a decade. Using this system, EBSA is able to target plans on a myriad of different issues. Some of the entries on the Annual Report that would be “red flags” for EBSA include:

� Excessive administrative expenses

� Certain types of plan investments including:

h Partnership and joint venture interests

h Real estate

h Employer securities

h Employer real property

h Tangible personal property

h Loans other than to participants

h Any listing investments in the category of “other”

� Failure to transmit employee contributions

� Loans or leases in default

� Nonexempt party in interest transactions

� Fraud or dishonesty losses

� Hard to value assets

� Insufficient bonding

This is not an exhaustive list of issues that will trigger EBSA interest in a plan, but this list represents the primary issues that will consistently capture the attention of EBSA and may lead to investigation of your plan.

Participant Complaints

Every summary plan description is required to advise plan participants of their ERISA rights and their ability to contact EBSA should they have questions about those rights. When participants contact EBSA, they will speak with an EBSA representative. In 2010 alone, EBSA took nearly 377,000 participant phone calls in addition to letters and e-mails. These calls are answered by EBSA’s benefits advisors, who will attempt to answer the participant’s question, or if the circumstances warrant, refer their issue for potential investigation. As a matter of practice, EBSA will not acknowledge or comment on any participant complaint they receive, thus you would likely never know if this was the source of the investigation.

continued on page 4

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Co-fiduciary Referrals

Many service providers are recognized as “co-fiduciaries” to the plans they service.

A co-fiduciary may be liable for another fiduciary’s breach under certain

circumstances, including:

�Where a fiduciary knowingly participates in or conceals the breach of another fiduciary

�Where a fiduciary has enabled another fiduciary to commit a breach

�Where a fiduciary has knowledge of a breach by another fiduciary and does not make reasonable efforts to remedy the breach

As a result, there are circumstances in which the co-fiduciary wishes to avoid or mitigate its own potential liability for the breaches of others and will contact EBSA. As with participant complaints, EBSA will not comment on or acknowledge a co-fiduciary referral.

EBSA Enforcement Projects

EBSA seeks to focus its enforcement resources on areas that have the greatest impact on the protection of plan assets and participants’ benefits. Each fiscal year, EBSA will identify certain national enforcement projects in which field offices are to place particular investigative emphasis. Past retirement-focused projects have emphasized:

� Settlor fees

� Delinquent employee contributions (civil and criminal)

� Plans affected by bankruptcy

� Abandoned plans

� Prevailing wage-funded plans

� Apprenticeship plans

� Consultant/advisors

� Nonfilers

The EBSA Investigative Process

Most EBSA investigations begin with an appointment letter which states its legal authority to conduct the investigation. The letter will announce the date and location of the investigation, and will include a list of documents that should be made available to the investigator. Failure to comply with the requested appointment and document production may result in the plan sponsor’s receipt of a federal subpoena. The document production will normally request



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information for the previous three years, but EBSA has the authority to request information for up to the prior six years. Depending on the type of plan, most appointment letters will request copies of the:

� Plan document and amendment

� Summary plan description

� Signed annual reports and schedules with auditor’s reports

� Investment policy statement

� IRS determination letter

� Fidelity bond

� Fiduciary liability

� Service provider contracts

� Lists of plan trustees/administrators

� List and minutes of the board of directors

� Administrative/investment committee minutes

� Plan financial statements

� Corporate payroll records

� Plan trust records

� Participant loan files

� Documentation of nonqualifying assets

� Participant loan files

� Plan correspondence

Plan sponsors should only provide EBSA with photocopies of these documents, document what has been shared with EBSA, and request a receipt for the documents provided. It is best to have all of the documents ready and organized when the investigator arrives in order to minimize the amount of time they will need to be at your place of business. It is also advisable to tab or index the documents to correspond to the numbers on the investigators appointment letter. If your business is unable to accommodate the investigation, you are permitted to request that the document review be conducted at the offices of one of your service providers.

Many plan sponsors ask if ERISA counsel should be present during the investigation. This is a question to be answered on your particular circumstances, but in most instances, ERISA counsel is not necessary during the on-site investigation process. In reality, not much will occur during the early stages of the investigation, as the investigator is simply looking to become familiar with the documents and how your plan operates. At this stage, service providers can assist with the document production and answering questions. However, if you are aware of significant violations prior to the investigation, then it may be beneficial to have ERISA counsel involved early.

Typically, EBSA will send one person on-site to conduct the investigation; in some cases, two will be present. EBSA has a relatively small enforcement staff and will normally only send two investigators in a training situation. However this is not always the case, and may be an indication of a criminal investigation. As a matter of practice, when EBSA conducts a criminal investigation, it will send two investigators to conduct an interview. EBSA does not inform plan officials as to the source of its investigations, but its Enforcement Manual requires that the investigator be forthright in stating that EBSA is conducting a criminal investigation. However, you should not wait for a formal announcement to determine if you are under a criminal investigation. If two investigators arrive, you should immediately ask if the case is criminal. If you get an affirmative response, immediately stop the investigation and contact an attorney.

The on-site EBSA investigation may take from one day to two weeks depending on its size and complexity. The investigation may include several interviews, including an opening interview with plan officials,

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SAMUEL HENSON, J.D.Senior ERISA CounselLockton Retirement Services816.751.2245 | [email protected]

STEVEN P. KJARVice President, ProducerLockton Retirement Services408.200.3603 | [email protected]

fiduciary interviews and a closing interview. You have the right to have counsel present, and you have the right to decline to answer any question asked by the investigator. You should be prepared to make available all parties who are fiduciaries and those employees who are involved in the day-to-day administration of the plan. In addition, your service providers should be aware of the investigation and reachable throughout the on-site review.

During the interview process, you should be prepared to provide detailed answers. The interview process can be exhausting, depending on the size and scope of the investigation. If you are unsure of the answer to a question, it is always best to refrain from answering until you have enough information to answer. Most interviews will focus on the following areas:

� Corporate governance/plan administration

� Reporting and disclosure

� Bonding

� Funding

� Investment selection/monitoring/retention/fees

� Service provider selection/monitoring

� Participant loans

� Remittance of employee contributions

If EBSA discovers a violation during the investigation, it may share the findings in a closing conference. More than likely, the investigator will leave no indication of their findings and will issue a “Voluntary Compliance Letter” at a later date. The time frame for when you can expect this letter can range from weeks to years, depending on the workload of the investigator and the complexity of the issues involved. When the letter does arrive, you will typically have ten business days to acknowledge your receipt and what action you propose to take with respect to the specific matters discussed. Depending on EBSA’s findings, you may request an extension of the time to reply in order to properly prepare a response or consult ERISA counsel. If you do not wish to negotiate the findings of the letter, you should contact the EBSA to clearly understand what steps you should to take make the corrections and what documentation they will need to see. If you ignore EBSA’s letter, you should prepare for litigation and penalties.

Best Practices

Plan sponsors should be proactive and diligent in their fiduciary processes. A positive outcome from an EBSA investigation will result from a documented process that demonstrates consistent review of your plan. An investigation will no doubt be a great test of your fiduciary and administrative processes, but it can be an opportunity to test yourself as a fiduciary. The best advice we can give you is to “investigate” your plan regularly with the scrutiny you can expect from EBSA. It is in your best interest, it is in the best interest of your participants, and will make compliance with the standards of ERISA much easier.



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Tax Reform: Changes in PBGC Premiums Could Create a New Outlook for Defined Benefit Plan Sponsors

By: Jessica Skinner, J.D.

The recent deficit reduction and tax reform debates in Washington have generated many major proposals that could drastically affect the retirement industry. Some of the most significant of these proposals will change Pension Benefit Guaranty Corporation (PBGC)’s premiums on defined benefit (DB) plans. These have garnered bipartisan support on the Hill; however, it is unclear how the increase will be applied and what vehicles will be used to assess premiums that come due. The only clarity regarding these proposals can be seen in the uncertainty they bring to the future of the defined benefit landscape. The increases have become a contention item among the business community and within retirement industry groups. This article will help you understand the background of the relationship between PBGC and DB employers, which proposal is causing the biggest uproar and arguments for and against these changes.

Background

When employers make DB pension promises to their employees, those benefits are insured (up to a statutory cap) by the PBGC. Employers are assessed premiums for that insurance. If the sponsor to the DB plan goes bankrupt, and the plan terminates, the PBGC will assume its assets and benefit obligations. If the plan lacks the assets to fund the benefits insured by the PBGC, the insurance fund takes a loss. The solvency of the fund thus depends on both the adequacy of the plan funding as well as the sufficiency of the PBGC premium assessments. Currently, funding requirements and premium assessments are established by federal law.

Three Major Proposals

Three significant proposals have surfaced affecting PBGC premiums as part of deficit reduction measures. The most contended of these is the proposal offered by President Obama and his constituents.

President’s Budget: President’s Deficit Reduction/Tax Reform Proposal; Bowles/Simpson:Starting in 2014, the PBGC Board would set an increased level of PBGC premiums and take the plan sponsor’s credit risk into account in setting those premiums. Premium increases would be phased-in, and the budget would assume $16 billion in additional premiums within the next ten years.

continued on page 8

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Domenici/Rivlin:Increase the fixed-rate premium by 15 percent (from $35 to about $40 per participant) and raise the variable-rate premium from $9 to $12 per $1,000 of underfunding. The estimated change would be an increase of about $5 billion over the course of nine years.

House (Ryan) Budget:The resolution does not specifically propose to increase PBGC premiums; however, a committee report that accompanies the resolution expresses concern about the PBGC’s financial situation and recommends reform.

The Heated Debate over the President’s Proposal

The most concerning of these three proposals, and the one that is garnering the most attention, is the proposal contained in President Obama’s deficit reduction plan. This proposal has the potential to make the offering of DB plans so unappealing for pension sponsors, many may cease to offer these benefits altogether. Essentially, it would give the PBGC increased authority to modify both the level and structure of premiums that pension sponsors are charged for pension insurance.

Tax Reform (continued)


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Industry groups and affected plan sponsors are worried this proposal could further discourage an already administratively burdensome plan option; however, some contend the President’s proposal is the only way to strengthen the PBGC system and ensure it has adequate funding. Below are some of the most contentious arguments for and against the President’s proposal on the subject:

Arguments “For” the President’s Proposal

Arguments “Against” the President’s Proposal

If the structure and funding of the PBGC is not revised, the PBGC is in danger of a taxpayer bailout.

The PBGC’s annual report states: “Since our obligations are paid out over decades, we have more than sufficient funds to pay benefits for the foreseeable future.”

PBGC has a $23 billion deficit. The $23 billion deficit is based on very aggressive interest rate and other assumptions that it uses in the context of “distress” plan terminations and in its strategy to sue employers. PBGC’s annual report states that almost 30 percent of its deficit is solely attributable to the drop in interest rates within the last 12 months. Those historically low interest rates do not suggest any failure on the part of employers to responsibly fund pension plans, nor do those rates bear any resemblance to the likely interest rates that will prevail over the forthcoming decades. It makes no more sense to evaluate PBGC’s financial condition at a current single point in time, when interest rates are low and the stock market has not fully recovered, than it was to do so when interest rates were higher and the market was booming. It is the long-term outlook that is relevant, not a one-time snapshot into its financial status. Further, if an individual or a corporation purchases an insurance policy of any type, its premium is not based on the profit or loss of the insurance company in that year. Moreover, the premiums do not rise or fall based on the insurance company’s profitability as the policy is renewed each year. PBGC deserves a premium that reflects the risk it bears that an underfunded plan may terminate, and the agency will assume the plan’s obligations to pay benefits. This is the system that exists today with the variable rate premium, and it is the proper way to determine an agency’s risk.

continued on page 10

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The proposed premium increases are modest and would not have a material effect on businesses.

It appears premiums could, by the end of a phase-in period, increase annually by more than $1,000 per participant for some companies. This calculation is based on the following assumptions derived from the PBGC’s description of a likely way the premium increase would apply: (1) the entire additional premium increase could be imposed on plans maintained by employers that are below investment grade, (2) approximately 20 percent of plan sponsors are below investment grade, (3) the premium increase will be phased-in, so to raise the full $16 billion, the premium amount will be extremely high by the end of the phase-in period, and (4) the treatment of a plan sponsor as below investment grade will also be phased-in. Companies that have been below investment grade for many years will pay comparatively higher premiums, even though they will have maintained their pension plans throughout the period they have been below investment grade. This premium increase is by no means insignificant; and is particularly unjustified if the company’s plan is well-funded but the company has, for whatever reason, received a low credit rating.

Like any other insurance company, the PBGC should be allowed to determine the premium it charges its customers.

Unlike other insurance companies that can refuse to accept a prospective customer, the PBGC is required to provide termination insurance for all DB plan sponsors. However, the same is true for employers. A DB plan sponsor cannot shop around for another agency/insurer with whom to do business. By law, it must pay PBGC premiums. In this respect, the relationship is not like the private sector’s insurance marketplace from either the agency’s or the employer’s perspective. It is therefore fundamentally unfair to vest one party to this required relationship (i.e., PBGC) with the unilateral authority to decide the amount its customers (i.e., employers) must pay.

Moreover, even private-sector insurers must get approval from state insurance regulators for the premiums they charge. Why then, with the retirement security of millions of Americans dependent upon the willingness of employers to continue sponsoring DB plans, would Congress give an agency the power to set its own premiums?

Tax Reform (continued)


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JESSICA SKINNER, J.D.Compliance AttorneyLockton Retirement Services816.960.9295 | [email protected]



The government would not be involved in rating companies under the Administration’s proposal.

By necessity, the government would have to approve the actions of the private credit rating agencies; and by implication, the government would be rating private companies and tax exempt organizations. These credit ratings could have implications well beyond PBGC premiums, potentially affecting stock prices or the company’s ability to access credit sources.

The Outlook for DB Plan Sponsors:

It is obvious these changes could cause major concern for DB plan sponsors. It will likely have a lasting effect on the future of offering this plan option to employees, and could very well have inadvertent effects on companies that currently offer these options The Joint Special Committee on Deficit Reduction (the Supercommittee) is currently reviewing these proposals in its assignment to reduce the federal deficit. If you have questions or wish to contact your congressional delegation or those members serving on the Supercommittee, you are urged to contact your Lockton Retirement service team.

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Six Steps to Get Your Employees “Retirement-Ready” in 2012

By: Rick Unser

A workforce that is financially unprepared for retirement can have a significant impact on company profits and productivity levels. Insufficient retirement savings can lead to employees working beyond their desired retirement age, resulting in a psychological blow for employees and a potentially expensive proposition for your company. Get off to a good start in 2012 by understanding trends in the retirement industry, cost saving and productivity strategies and how to create a “retirement-ready” workforce by following our six steps. This will nurture a culture of retirement readiness, helping your employees enjoy a comfortable retirement while generating short and long-term cost savings for your company.

Retirement Trends

Delayed retirement dates have become a reality after the most recent financial crisis and recession took a bite out of many retirement nest eggs. According to a recent survey by the Employee Benefits and Research Institute (EBRI), the poor economy and weak financial markets have forced roughly 24 percent of workers to postpone their expected retirement until after age 70. In addition, there has been a three-fold increase in the number of workers who are “not at all” confident they will live comfortably through retirement.

By working proactively with your employees, you can limit the numbers who have to work beyond a normal retirement age of 65, avoid increasing costs, and enhance productivity.

Cost Savings

The implications of employees who have no financial choice but to work into their late 60s and even 70s may not seem significant on the surface. However, the challenges become evident as you begin to evaluate the costs of those employees. Healthcare costs for employees over age 65 are more than double that of employees aged 45-55. The statistical rate of work-related accidents does not increase dramatically for employees over age 65. However, when accidents do take place, the severity and paid time away from work increase substantially. In addition, salaries and other compensation tend to be higher for an older employee with tenure than for a younger employee with a similar skill set. Finally, productivity for older employees (which varies greatly among each individual) can drop off substantially.

Whether measured in hard-dollar savings or productivity increases, the benefits of a retirement-ready workforce, both to employees and the company, can be substantial.


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Productivity

If you were to ask the average worker when he or she wants to retire, some would jokingly answer “tomorrow!” The point is, many people do not want to work any longer than necessary once they have the financial ability to stop. As a result, it is no surprise that eight out of ten people identify money as a significant stress in their life. For the financially unprepared, the stress of knowing they do not have enough money to retire, the worries about affording healthcare in retirement, and other financial concerns can lead to presenteeism. Simply defined, presenteeism is when an employee is physically at work, but not functioning at his or her full capacity. Also, financial stress can lead to moral hazards such as theft, fraud, exaggerated workers’ compensation claims and other issues. Fostering a more financially confident workforce may not eliminate these issues, but it can certainly reduce their frequency and severity.

Solutions

Establishing a culture of retirement readiness is a process that will provide valuable benefits to both employers and employees.

The steps listed below represent a roadmap on how to get started:

1

How many of your employees are within five,

ten, and 20 years of retirement? Based on their

current income, participation in your company’s

retirement plan, salary deferral rates and account

balances, are they on track to replace enough

of their current income to enjoy a comfortable

retirement? This evaluation can be an eye-opening

exercise. When you have an understanding of how

different segments of your population are utilizing

(or not utilizing) your retirement plan, it is easier

to strategically develop a plan to help improve the

retirement readiness of your workforce.

Are the provisions in your retirement plan conducive to helping

employees successfully accumulate enough money that can

be converted to a steady stream of income during retirement?

When can employees start contributing after they are hired?

Do you offer a Roth 401(k) to provide a tax diversification

strategy? Have you considered automatic enrollment and/or

automatic salary deferral increases? Do you offer professionally

managed funds, which target either a certain risk level or

retirement age? There are several opportunities within your

plan design to help start and keep your employees on the

right track toward retirement. The key is understanding

your workforce and then making decisions that support both

employee retirement readiness and your corporate goals.

continued on page 14

2 Evaluate Plan Design

Conduct a Company Retirement Readiness Assessment

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A 25-year-old employee is going to have very different questions and concerns

about your company retirement plan than a 55-year-old employee. However,

many companies make the mistake of communicating and educating their

employees using the same materials and messaging for everyone. When you

offer different messages about your retirement plan that purposefully target

multiple demographics in your company, both response and adoption rates

increase. In addition, when you combine a targeted message with behavior

modification enablers such as “take action” cards, e-mails that have one-button

solutions, etc., you increase the odds that your employees will voluntarily

take the actions you are trying to encourage. Many companies have been

unsuccessful in influencing participant behavior because they are focused on

providing information and then rely on participants to independently connect the

dots. Employees want to be guided. Their retirement readiness can be greatly

improved when you help them easily and painlessly arrive at the right decisions.

The biggest threats to retirement savings are employees

making ill timed changes to their investment selections and/

or stopping the contributions. Many times, people make these

choices out of fear, panic and other emotional reactions.

While they might feel good at the time, in hindsight, they are

generally poor decisions. Retirement income solutions are a

recent entrant to the 401(k) market place. While the specifics

vary by provider, they generally offer an in-plan solution to

help protect a participant’s account from losses, while allowing

participation in the gains, and a guaranteed stream of income

at retirement. These participant elected options are quickly

gaining acceptance from employers and should, at a minimum,

be discussed by plan fiduciaries. While one can argue about the

financial benefits, the psychological benefits of the downside

protection for their 401(k) balances can help your employees

stay on track instead of making emotional decisions which will

dramatically affect their retirement readiness.

4 Retirement Income Solutions

3 Develop Targeted Employee Communications Focused on Changing Behaviors

Six Steps (continued)


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In Summary

With no income provided by defined benefit pension plans to count on, employees today are faced with the challenging task of proactively saving and managing enough money to provide a steady stream of income in retirement. Challenges in the economy, financial and job markets only make that task more difficult. As an employer, you are not responsible for the finances of your employees. However, you can help them become more financially confident, resulting in a less stressed and more productive workforce. In addition to cost savings, supporting employees in their transition to retirement may help you earn a reputation as a caring employer of choice in your industry and region. Retirement readiness is a win-win proposition for all parties.

If you are making matching contributions, you should

evaluate your formula. Studies have shown that

many employees will contribute only enough to get

the full company match that your formula allows. If

your match is based on the first two or three percent

of contributions, it should be no surprise if a large

percentage of your employees are only contributing two

or three percent to your retirement plan. To encourage

your employees to save more money each year, consider

raising the target matching percentage. For example, if

you were matching 50 percent of the first 3 percent of

contributions, consider changing that to 25 percent of the

first 6 percent. There is no increase in the out of pocket

contribution for the company, but it will produce higher

contribution levels which will foster increased retirement

readiness amongst your employees.

You can not manage what you don’t measure. How true

this saying is when it comes to tracking improvements

and progress of your employees in your retirement plan.

Every employer is different; every workforce has its

own unique characteristics and challenges. As you go

about trying to help your employees get on track for a

comfortable retirement, you must check your progress.

Some campaigns or ideas will be very successful, others

will not. You must measure your results as you go along

so successes can be replicated and failures can become

lessons. At a minimum, you should track participation

rates, average salary deferrals, average account balances

and investment diversification by age group. Tracking and

measuring your progress will only help your employees

and your company chart a more successful path toward

retirement readiness.

RICK UNSERProducerLockton Retirement Services213.689.2392 | [email protected]

6 Ongoing Measurement

5 Be Strategic With Company-Matching Dollars

Our Mission

To be the worldwide value and service leader in insurance brokerage, employee benefits, and risk management

Our Goal

To be the best place to do business and to work

www.lockton.com

© 2011 Lockton, Inc. All rights reserved. Images © 2011 Thinkstock. All rights reserved.

The communication is offered solely for discussion purposes. Lockton does not provide legal or tax advice. The services referenced are not a comprehensive list of all necessary components for consideration. You are encouraged to seek qualified legal and tax counsel to assist in considering all the unique facts and circumstances. Additionally, this communication is not intended to constitute U.S. federal tax advice,

and is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending any transaction or matter addressed herein to another party.

This document contains the proprietary work product of Lockton Financial Advisors, LLC, and Lockton Investment Advisors, LLC, and is provided on a confidential basis. Any reproduction, disclosure, or distribution to any third party without first securing written permission is expressly prohibited.

Securities offered through Lockton Financial Advisors, LLC, a registered broker-dealer and member of FINRA, SIPC. Investment advisory services offered through Lockton Investment Advisors, LLC, an SEC-registered investment advisor. For California, Lockton Financial Advisors, LLC, d.b.a. Lockton Insurance Services, LLC, license number 0G13569.

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