The Value of Pragmatism How to Evaluate and Select Nonqualified Plan Providers William L. MacDonald Chairman, President, and CEO Retirement Capital Group, Inc.
Bo Lee Vice President, Consultant Retirement Capital Group, Inc.
It takes a pragmatist to pick a plan provider. Ask the average person today what they think of the business world. The answer may be shot through with expletives. One financial rogue after another has been pilloried in the public’s mind. Not surprisingly, goodwill for corporate America is at a premium today. That’s why we are going to see a welcomed rise in pragmatism—those traditional principles of common sense, hard work and feet-on-the-ground practicality. For most of us, they never left. We are, after all, a nation built by pragmatists. In the field of executive benefits, the value of pragmatism has a major impact on the decision of plan provider and in deciding whether a benefit package is too rich, too lean, or too expensive. Restrictive qualified plans gave birth to nonqualified (NQDC) plans. These arrangements strengthen a company’s ability to recruit, retain and reward executives in the most practical way possible by helping them achieve retirement security.
95 Percent Prevalence Nonqualified deferred compensation (NQDC) plans have grown in prevalence in the last 20 years. According to Clark Consulting’s 2007 Executive Benefits: A Survey of Current Trends (Clark Survey), 95 percent of respondents among the Fortune 1000 have an NQDC plan in place. Even within smaller organizations, these plans have become commonplace. Nonqualified plans provide a retirement benefit that in-demand executives seek out in their overall compensation plan. While NQDCs may not be the competitive advantage they once were, their absence in a benefits line-up is a decided disadvantage. Significant improvements in plan design have made these arrangements “tax-deferred cash management accounts”, compared to archaic thinking of simply saving for retirement. Executives can now efficiently set aside money for retirement or fund life events such as putting children through college, eldercare, purchasing a vacation home or fulfilling a long held dream of distant travel. Chart I illustrates this process. Adding to the many advantages of nonqualified plans, highly compensated executives also have the flexibility to re-defer their account balances, pushing those dollars out until later years. This freedom emerged out of new regulations under IRS §409A. Equally important, many improved plan designs also offer financial planning tools including custom risked-based asset allocation portfolios. These custom portfolios allow the executive to put his cash management accounts and retirement accounts on auto-pilot, while delegating the ongoing monitoring and reallocation responsibility to trained professionals. page 2
Chart I - Distributions for Retirement and Life Events
20%
20%
10%
25%
25%
$8,200
$8,200
$4,100
$10,250
$10,250
College
College
Boat
Retire
Retire
Payout 2012
Payout 2014
Distributions 4
Distributions 4
Distributions 1
Distributions 15
Distributions Lump Sum
Asset Allocation Conservative
Asset Allocation Conservative
Asset Allocation Aggressive
Asset Allocation Moderate
Asset Allocation Moderate
Payout 2018 Retirement
Retirement
Plan Sponsor Responsibility Rises Improved plan design, however, also requires more responsibility on the part of the plan sponsor. There is increased complexity in plan sponsor reporting, and detailed participant account management. New regulations set an expectation that plan websites will deliver more robust functionality. Penalties attached to any violations of plan administration rules have grown steeper under §409A.
Increased Reporting Requirements Plan recordkeeping systems today must take into account far more information than in the past. Various vesting schedules, compensable excess interest creating and investment earnings must be carefully tracked. This process demands a high quality plan provider. Let’s review some of these requirements. Plan sponsors are required to report the total amounts deferred for the year on the employee’s Form W-2, box 12, with a code Y. Further, the sponsor must report any deferred amounts distributed on the employee’s Form W-2, box 12, with a code Z, in the year that the amounts are includible in gross income, as well as on the employee’s Form W-2, box 1. (This reporting requirement is also applicable to any amounts that are not distributed, but includible in income under I.R.C. Section 409A) Sponsor company is also required to report the employment taxes withheld from the employee on the employee’s Form W-2, Box 4 (Social Security Tax, as wages are included in Box 3) and Box 6 (Medicare Tax, as wages are included in Box 5).
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Director’s fees and other non-employee compensation deferrals are reportable on Form 1099MISC and must be reported in the year paid. Report these fees in box 7. Box 7 is for non-employee compensation. Generally, payments for services reported in box 7 are income from self-employment. The sponsor company is not required to withhold Social Security and Medicare taxes. The payee (Nonemployee Director) is responsible for reporting any Social Security and Medicare taxes. We understand the tedium of this detail, but it is essential to follow it to the letter or to entrust that your provider pays meticulous attention to all reporting procedures today and as they change in the future.
Greater Tax Implications In this environment, plan sponsors need to rely on plan providers with experts on staff who can advise the responsible party for payroll exactly when to withhold FICA and medicare taxes. For example, implications for the employee include specifics on: ♦♦ Assurance that creation of a NQDC plan does not cause income tax liability ♦♦ Consideration of the constructive receipt doctrine ♦♦ Consideration of the economic benefit doctrine ♦♦ Impact of IRC Section 83 and IRC Section 409A ♦♦ Deferral of Federal and state taxes until deferred compensation benefit is paid Moreover, employers cannot claim a deduction until the benefits are paid, as stipulated in IRC Section 404(a)(5). With regard to FICA and FUTA, the rules are very precise. We labor this point because tax intricacies are such that experts are necessary when selecting plan providers.
FICA and FUTA Taxes An employer is required to collect from the employee and also pay its own share of the Social Security and Medicare taxes on the employee’s wages when earned under FICA. An employer is also required to pay unemployment taxes on the employee’s wages when earned under FUTA. IRS Code Sec. 3121(v) (2) provides regulations for FICA and FUTA taxation of nonqualified deferred compensation (NQDC) plans. The Special Timing Rule states that wages deferred under a NQDC plan will be subject to FICA and FUTA taxes 1) when the services are performed or; 2) when there is no substantial risk of forfeiture of the right to such amount, as benefits become vested. Generally, the employee already has income above the wage base ($106,800 in 2009) for purpose of the Old Age, Survivors, Disability Insurance (“OASDI”) portion of the FICA tax; however, the deferred compensation will be currently subject to the hospital insurance portion of the FICA tax (referred to as the “Medicare Tax”) because the hospital insurance wage base is unlimited. Employee deferrals are immediately vested amounts so FICA and FUTA are withheld at time to deferral.
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Employer deferrals; that is, employer matches are usually tied to a vesting schedule so FICA and FUTA are withheld as they vest. Amounts deferred should be non-forfeitable; therefore, they will be subject to FICA and FUTA taxes in the year services are performed. No additional taxes will be due if the participant’s other compensation in that year exceeds the maximum taxable wage base under the Social Security provisions. Deferred amounts are subject to FICA and FUTA only once (Non-duplication Rule). For any deferrals that are 100% vested (i.e. most employee deferrals), the Non-duplication Rule provides incentive to report deferrals immediately. By reporting such deferrals right away, before any earnings are attributable to those deferrals, all earnings should accumulate FICA-free. Investment earnings are considered reasonable if it is credited in accordance with actual investments or investment indices. Any amount in excess of reasonable interest or actual investment earnings is considered compensable crediting rates or contributions and subject to FICA when it vests. [Treasury Regulation 31.3121(v)(2)-1(d)(2)].
When to Outsource With increased complexity on reporting and tax implications, as well as on design flexibility, many companies choose to outsource their nonqualified plan administration rather than invest the capital and human resources necessary to develop this capability inhouse. According to the Clark Survey, 49 percent outsource their plan administration to a third party administrator. But how do you find such an administrator and how do you know that it will be worth the added cost? Top management expects human resource personnel to use accessible and reliable systems for executives to manage their deferred compensation. Executives expect to manage their deferred compensation accounts on the internet as they do their 401(k) or brokerage accounts. Today, we work with ever larger groups of participants than in the past because companies are expanding these plans to levels below select groups at the top, adding to workloads. Typically, companies cannot add human resource personnel to handle the larger workload; therefore, systems must offer the capacity and capability to manage all aspects of the plan from funding strategy to individual participant accounts.
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Chart II - Separation Wall Nonqualified Deferred Compensation
Hypothetical Investment ¾¾ Choices available in NQDC: ●● Bond Fund ●● International Fund ●● Small Cap Growth ●● Mid-Cap Growth ●● Large Cap Growth
Separation Wall
¾¾ Participant elects: ●● Deferral amount ●● Allocation of hypothetical investments ●● Time and form of payout ●● Reallocation of account balance
Rabbi Trust Trust Company receives cash and is directed by the employer to invest the cash in a funding vehicle. The employer compares the investment results of the NQDC with the Rabbi Trust and reallocates the assets of the Rabbi Trust to hedge the NQDC.
Funding Vehicle ¾¾ Trustee directs asset allocation: ●● Bond Fund ●● International Fund ●● Small Cap Growth ●● Mid-Cap Growth ●● Large Cap Growth
Complexities of Plan Administration Unlike 401(k) plans, nonqualified plans are somewhat intricate, with many moving and interlocking parts. Companies are prudent to manage the NQDC plan, which is a promise of participant benefits, cleanly and separately from whatever funding strategy is applied to plan liability (Chart II). Using Chart II as a mini-manual, let’s follow the process. The executive first elects to defer his compensation and does so through a written agreement with the company. Within this agreement, the executive or participant can select from a range of hypothetical investment funds, similar to a 401(k) deferrals, but with one major difference. In the 401(k) plan, participant deferrals are deposited into a trust, and those assets are protected by ERISA (Employee Retirement Income Security Act). Alternatively, with an NQDC plan, those assets are technically unfunded, and are subject to the claims of the company’s creditors. Even though companies “informally fund” these arrangements in a Rabbi Trust, these assets nonetheless belong to the sponsoring employer, which slightly complicates plan administration. A revealing statistic underscores the complexity of plan administration: Only 15 percent of respondents in the Clark Survey manage their NQDC plans in-house.
Identifying Major Providers Nonetheless, it will be difficult to resist the urge to locate and delegate a firm to handle all the exigencies of plan administration. Understand that no single firm specializes in pure plan administration; it is simply not a stand-alone business model. These services are provided for the sole purpose of gathering assets under management whether that is mutual funds or corporate-owned Life Insurance (COLI). By example, Fidelity Investments is not in the 401(k) recordkeeping business; however, the company must offer that tool to capture and support the assets. page 6
To learn which NQDC plan administrators suit your situation, first examine direct revenue sources. You can actually segment the entire field into two groups: those that sell mutual funds (401(k) providers); and, those that sell COLI. Many COLI-motivated firms may sell a combination of mutual funds and COLI, and there are just a handful that use both. The 401(k) providers are somewhat at a disadvantage because their systems have been designed to manage plans in a systematic box, with corresponding restrictions and limitations on plan design. We urge you to avoid the mistake of oversimplifying the selection of a provider because you desire a simpler plan. In our experience, plan participants will be dissatisfied, and your firm will be at a competitive disadvantage. If you have taken the time to evaluate the need for a nonqualified plan, do not take short cuts on design, security, funding and, especially, plan administration.
How to Evaluate Best-in-Class We recommend that you apply the following five criteria to make a best-in-class decision on the appropriate plan provider, one that can consistently meet the majority of your objectives: 1. Expertise/Experience Ever-changing tax codes are reason enough to accept nothing less than an expert in nonqualified plans. Interpretation of these codes demands a level of critical thinking, knowledge and experience typically not found in generalist firms. Look for seasoned teams with a consultative approach to help you benefit from a plan built and serviced on best practices. 2. Technology Best practices plans require state-of-the-art technology solutions that lead to robust website functionality and convenience for both plan sponsor and plan participants. A meticulous record keeping system is needed to accommodate custom plan designs, track pre- and postยง409A and ยง409A plans, handle due diligence on investment options, and produce a steady stream of customized corporate reports. Technology is not the major differentiator it once was. Most of the major firms in fact use the same platform, provided by the same firm. 3. Stability By asking these two direct questions, you can uncover real stability in a provider: 1) does the firm offer an audited administration system and has it passed the SAS 70 II Audit?; 2) is turnover of plan administrators low and the management foundation solid?
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4. Communication and Education In a society filled with constant communication, why do we urge you to educate and communicate even more? It is not enough anymore to merely give employees a way to save. They need and want a deeper understanding of how to better manage their own investments. Even smaller firms nowadays turn to outside financial consultants to deliver a higher quality stream of communication. Frankly, with the devolution of once-sacred Wall Street brands, more savers are finding solace in the objectivity and impartiality of independent advisory firms. Ensure that your prospective or present provider offers an effective system to educate and communicate with your Board, management and employees. Then, test the waters. Does the advisor possess clear and consistent communication skills? Is he empathetic in a crisis? Will he or his team be accessible and reliable during transitions or otherwise? 5. Cost Every business decision merits a cost/benefit or risk/reward analysis. It is no different with your choice in providers. Evaluate both hard and soft costs in your decision to work with a nonqualified plan provider. Here are a few cost factors to consider: ♦♦funding and security solutions ♦♦underlying fee arrangements ♦♦tax implications of deferrals and payouts As part of ongoing due diligence evaluation for our clients, Retirement Capital Group (RCG) periodically evaluates and ranks providers, investment strategies, administration systems and more. This work requires the maintenance of very detailed reports of each provider/firm’s capabilities, along with the advantages and disadvantages as applied to each client situation.
RCG Scorecard With downsizing and cutbacks, many companies do not have the time or HR staff to conduct full evaluations on benefit plan providers. By bringing in a third-party consultant to do the analysis, clients typically save money, time and learn what they need to know to make a right decision for all concerned. As a specialist in retirement planning, RCG developed a simple yet revealing four-point scoring system that measures key indexes important to clients: (4 indicates “most capable”; 1 indicates “not as capable”; please see the grid below).
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Technology Platform When you evaluate the technology platform of a given provider, you need only to investigate two major areas: 1) Participant access and experience; which is to say, how easy and convenient is it for participants to retrieve up-to-date, accurate information on their accounts 24/7? ; 2) Plan sponsor access and reporting capabilities; that is, can sponsors learn quickly what is needed to operate the system with little training; does the platform produce detailed and readable reports on demand? ; is the platform robust and reliable? To illustrate, we use our measurement system in Chart III below to evaluate four actual third-party administrators on an anonymous basis: Chart III - Third-Party Administration Evaluation Service Description Plan participant web access experience Plan sponsor web access experience Accuracy of data Online enrollment technology Reporting - Existing options - Ability to customize - Access by sponsor Ability to demonstrate plan customization Daily Asset/Liability matching services for all funding vehicles Ability to customize vesting schedules In-service account(s) tracking /customization ability Online Distribution Election Modifications Asset allocation modeling tools Ability to automate deferral file transfers Corporate Owned Life Insurance (COLI) Administration Investment fund information reporting (funds in COLI product) Investment fund information reporting (Retail Mutual Funds) Average technology score
Provider A
Provider B
Provider C
Provider D
4 4 4 4
3 3 4 4
4 4 4 4
3 3 4 4
4
3
4
4
4
3
4
4
4
4
4
4
4 4 4 3 4
4 4 1(A) 3 4
4 4 1(A) 4 4
4 4 1(A) 3 4
4
2(B)
4
2(C)
4
4
4
4
4
4
4
4
3.93
3.33
3.80
3.47
(A) The system does not support online modifications. Participant must complete a modification form or call the call center. (B) Limited to provider’s product. (C) Limited to select insurance carriers.
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What determines a score of 4 versus 3 in the above grid is functionality of the administration system. For example, we investigate: ♦♦ How user-friendly are web tools for asset allocation modeling and online enrollment? ♦♦ Can the system accommodate custom corporate reporting requirements of custom plan designs? ♦♦ Does the system accommodate daily asset/liability matching to minimize the mismatch? ♦♦ Can the plan sponsor print “on-demand” corporate reports from the plan website? ♦♦ Does the system provide functions to help reduce hours spent in plan sponsor administration? Accuracy of data is paramount. Fortunately, we have found this is a minor issue for most providers. However, we have found a fairly consistent lack of system capabilities by 401(k) providers when administering assets other than mutual funds. With the power of technology to do more in less time, and the urge to go green, companies do not want to get buried in paperwork. Secure and streamlined online enrollment and monitoring technology is must. But do not trust that just because a provider claims it offers a robust technology platform, that it is so. Get online and experience firsthand what the provider claims for your participants.
The Human Factor Unlike a 401(k) plan, a nonqualified plan is a complex mechanism with many moving parts. At first glance, you see a pile of puzzle pieces strewn across a card table, only halfway fitted. Then, as you draw closer, and you begin see the trees, mountains and the pastoral scene. NQDCs are similar, and they deliver best results when handled by a client service team adept in four disciplines: 1) information technology; 2) tax and law; 3) asset management, and; 4) communication and education. You can produce the best designed nonqualified plan, but it will be quickly undone if the system cannot accommodate customization, implementation and communication. Executives won’t participate, and the experience is lost to negative perceptions. A savvy client service team can keep plans on track and in compliance with the new tax laws and regulations. It can effectively manage assets and liabilities to minimize the potential for mismatch. It can manage the re-enrollment and convey the value of the plan to increase participation and utilization of the financial planning tools. page 10
When you select a truly experienced third-party administrator firm, your client service standards will rise exponentially. Chart IV evaluates some basic elements of client service. CHART IV - Plan Provider Evaluation Service Description
Provider A
Experience Level of Staff – Back-office Capabilities Ease of Implementation Communication and Education Asset Management Services Corporate Accounting and Financial Reporting Total Client Service Score
4 4 3 4 4 3.80
Provider B 3 4 3 3 3 3.20
Provider C 4 4 4 4 4 4.00
Provider D 4 4 3 3 3 3.40
What determines a score of 4 versus 3 is measurable experience of the client service team. For example: ♦♦ How many years has the client service manager worked at his firm and in nonqualified business? ♦♦ How many “high profile” plans does he or she manage? ♦♦ Does the client service team include an investment consultant to monitor the plan investment options and asset allocation models? ♦♦ Does the client service team offer a CPA to manage corporate accounting/financial reporting? ♦♦ Since no two plans are alike, does the firm provide custom communication strategies including custom enrollment guides, webcasts, and the incorporation of the plan sponsor’s brand on the communication materials?
Cost Priorities and Variables Can you put a price on the cost of hiring the best talent in the business for your company? Can you put a price on their contribution, their value, their loyalty? Then, that is the cost on your nonqualified plan because it is a catalyst to those outcomes. This statement is not meant to be glib. It is a statement of fact. Why else do the majority of Fortune 1000 corporations and a rapidly growing number of smaller firms offer NQDCs to their senior managers. One can make the argument that in this unprecedented period
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of corporate restructuring, companies cannot afford to shortchange the very people who can lead through the uncertainty ahead. What’s more, cost is not the deal breaker it once was—most third-party administrators charge comparable fees. Transparency of hard dollar fees and soft dollar costs of the funding strategy is the linchpin of cost analysis. After receiving a plan administration fee quote from the provider, determine the soft costs of the funding solutions. The option to offset the hard costs with the commissions and basis points the provider earns from the assets under management can help to manage and, possibly, reduce the overall cost of the plan. Chart V - Fees of Plan Providers Fee Description Estimated One-time Set-up Fee Estimated Recurring Annual Fixed Fee Estimated Recurring Annual Per Participant Fee (First 100) Total Hard Dollar Fees Year 1 Total Soft Dollar Costs Year 1 Total Commissions the Provider earns from Assets Under Management Fee Offset Total Plan Costs Year 1
A
B
C
D
$20,000
$30,000
$20,000
$25,000
$25,000
$50,000
$15,000
$15,000
$7,500 ($75/per) $52,500 $0.00
$25,000 ($250/per) $105,000A $60,000
$15,000 ($150/per) $45,000 $0.00
$12,500 ($125/per) $52,500B $20,000
$300,000
$900,000
$300,000
$400,000
$0.00 $52,500
($105,000) $60,000A
$0.00 $45,000
($52,500) $20,000B
(A) Fees reduced by 100% if the plan is financed with COLI. If service agreement terminates within the first 4 years, the client is retroactively charged for administration fees from service inception. (B) Fees reduced by 100% if the plan is financed with COLI. If service agreement terminates within the first 3 years, the client is retroactively charged 50% of the administration fees from service inception.
Chart V gives us a good example. In examining the four plan providers, only provider A and D offers to offset hard dollar fees with commissions earned from the assets under management. Let’s assume for a moment that the annual deferrals were $3 million and the company decided to fund with COLI. The commission could range from $300,000 to $900,000 in year one. Shouldn’t there be some offset? However, be careful here, as each plan provider’s funding solution has generated different soft dollar costs and commissions from the assets under management. The plan provider offering to offset hard dollar fees with commissions may not always be offering the most cost effective long-term solution.
Don’t Pay Twice It is a common practice for a major brokerage firm to bring in a third-party firm to handle plan administration. Be careful with this arrangement: Many times you pay twice. The major Wall Street brokerage firm hires its thirdparty partner to do the technical work, and then splits the commission and fee revenues. To the third-party partner, your company is now less profitable and, one could predict, you may not receive the level of service you deserve. Sad but true, the major brokerage firms on average take onepage 12
half of all revenues (not profits) on your account. Make sure there is some value added being provided by both parties.
Small and Effective It is human nature to think that bigger is better. We urge you to suspend this belief. Many firms in the nonqualified space have numerous plans on their books and, yes, they continue to grow. In our experience, the larger the firm, the greater the chance exists for critical details to fall through the cracks. Technology may be the ultimate leveler of this condition; however, the human factor complicates it. Larger, impersonal firms with too many clients and too little time will find it quite challenging to handhold the CEO of a small business or the newly minted human resource manager in a large firm. Ignore the impressive presentations and groups of well-spoken presenters. Large firms have “show and tell” teams they roll out to win the business. But you may never see that team again. You want to do business with the people who have a true stake in your success. Ultimately, smaller is better because smaller independent firms now possess all the technology tools, techniques and systems employed by the behemoths, but with one serious difference—they are fully dependent your goodwill, your financial success and your complete satisfaction. After all, no one is going to bail them out. We began this article by speaking to the value of pragmatism when choosing plan providers. We then outlined a range of criteria to guide your decision-making process—from experience, stability and technology to communication, education and cost. Then, we went against conventional wisdom. We posed the argument that smaller is better in the nonqualified space for reasons of specialization, client satisfaction of commitment to success. Whether from the client side or the vendor side, pragmatists seek each other out, sometimes unwittingly. Before you make your final decision on a provider, do a common sense litmus test. Look for a culture of pragmatism. Look for people who are down-to-earth, driven by values, cost and qualityconscious. Authentic. And, do you sense a shared vision of what’s possible for now and in the future? Then, and only then, let them earn your business. page 13
William L. MacDonald Chairman, President & CEO Mr. MacDonald founded Retirement Capital Group, Inc. (RCG) in San Diego in 2003, where he serves as Chief Executive Officer, and Chairman of the Company’s Board of Directors. He also founded Compensation Resource Group (CRG) in 1978. CRG was acquired by a NYSE company in 2000; Mr. MacDonald then presided as President and Chief Executive Officer of the executive benefits division until 2003. Mr. MacDonald has consulted on executive compensation and benefit issues for more than 20 years for numerous public and privately-held firms across a variety of industries, including a large number of Fortune 500 companies. He wrote a book Retain Key Executives published by CCH , and has authored numerous articles on the subject of executive compensation and benefits. In addition, Mr. MacDonald has been quoted frequently in The Wall Street Journal, The New York Times, and Bloomberg, as well as in a number of industry trade journals. A frequent lecturer, Mr. MacDonald has spoken on the subject of compensation and benefit planning to various organizations, including The Conference Board, World-at-Work, Forbes CEO Forum, and the Young Presidents’ Organization. Mr. MacDonald serves on the Board of Directors for the San Gabriel Boy Scouts of America, National Association of Corporate Directors, and the Board of Visitors for the Graziadio School of Business at Pepperdine University. He is also a member of the World Presidents’ Organization, San Diego Harvard Alumni Club, and Financial Executives International. Mr. MacDonald graduated from Northeastern University, and The President’s Program on Leadership from Harvard Business School.
Bo Lee Vice President, Consultant Bo Lee serves as Vice President, Consultant in RCG’s Western Region. He works closely with large public and private companies to design and implement executive compensation and benefits programs used to attract, reward, and retain key executives. His extensive consulting expertise includes nonqualified benefit plan design, benefit security, informal funding, and administration. Prior to his current position, Mr. Lee was Vice President of Client Services. His responsibilities included strategic planning in the areas of client relationship management, plan administration outsourcing, and trust services outsourcing. He managed client relationship managers and oversaw all activities relating to plan implementation and ongoing client service activities. This included overseeing the selection of the third party administrator and trustee, development of the plan communication materials, integration of takeover plans and conducting enrollment meetings. He was instrumental in building a key differentiator in the RCG consulting model of delivering plan administration solutions through an open architecture solution approach. Mr. Lee is the architect of RCG’s Plan Administration Solutions (PAS) database, which includes the best-of-class plan administration firms in the industry. He has conducted a due-diligence evaluation on firms which include mutual fund companies, trust companies, life insurance companies, retirement plan administrators, and a software company. Prior to joining RCG, Mr. Lee was associated with Compensation Resource Group (CRG), which is now Clark Consulting’s Executive Benefits Practice. He is a graduate from the University of California, Los Angeles with a Bachelors of Arts degree in Economics and is licensed through the National Association of Securities Dealers (NASD).
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Based in San Diego, California, Retirement Capital Group is a full-service executive benefits firm structured and committed to enable companies to attract, retain and appropriately compensate and reward their talented executives. For more information, please contact RCG at: Main: 858.677.5900 Toll Free: 866.724.4877 Fax: 858.677.5915
Investors should consider the investment objectives, risks and charges and expenses of the contract and underlying investment options, risks carefully before investing, The prospectus contains this and other information about the investment company and must precede or accompany this material. Please be sure to read it carefully. The opinions, estimates, charts and/or projections contained hereafter are as of the date of this presentation/material(s) and may be subject to change without notice. RCG endeavors to ensure that the contents have been compiled or derived from sources RCG believes to be reliable and contain information and opinions that RCG believes to be accurate and complete. However, RCG makes no representation or warranty, expressed or implied, in respect thereof, takes no responsibility for any errors and omissions contained therein and accepts no liability whatsoever for any loss arising from any use of, or reliance on, this presentation/material(s) or it contents. Information may be available to RCG or its affiliates that are not reflected in its presentation/material(s). Nothing contained in this presentation constitutes a solicitation, recommendation, endorsement, or offer to buy or sell any investment product. Investing entails the risk of loss of principal and the investor alone assumes the sole responsibility of evaluating the merits and risks associated with investing or making any investment decisions. This report contains proprietary and confidential information belonging to RCG (www.retirementcapital.com). Acceptance of this report constitutes acknowledgement of the confidential nature of the information contained within. Securities Offered Through Retirement Capital Group Securities, a Registered Broker/Dealer, Member NASD/SIPC William L. MacDonald, Registered Representative – California Insurance License #0556980 Bo Lee, Registered Representative – California Insurance License # 0C50408
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Retirement Capital Group, Inc. 12340 El Camino Real, Suite 400 San Diego, California 92130 Phone: (858) 677.5900 Fax: (858) 677.5915 Toll-Free: (866) 724.4877 www.retirementcapital.com