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SponsorNews - August 2017
The IRS is Back with Some Brand New Corrections
Let's face it. Finding out that the IRS wants to poke around is not going to be the highlight of anyone's day. Voluntarily admitting a mistake to the IRS and asking for forgiveness is probably even lower on the wish list! So hearing about new voluntary corrections from our friends at the Service might seem like a waste of time.
Not so fast! Believe it or not, the division of the IRS responsible for qualified retirement plans actually does not want to find problems and hand out sanctions. Their goal is to help preserve tax-favored retirement benefits that exist within retirement plans. Of course, if someone doesn't play by the rules, they shouldn't then be able to claim the same benefits as someone who does satisfy the various requirements.
That is where the various voluntary correction programs come into play. The IRS recognizes that there are a lot of moving parts involved in the proper care and feeding of a retirement plan. More than 20 years ago, they created the first iteration of a program that allowed companies to voluntarily get their plans back on track, provide participants with any missed benefits and avoid most, if not all, of the penalties the IRS might otherwise assess. Over the last two decades, the IRS has continued to evolve, update and consolidate these programs to make them more accessible and meet the needs of an evolving business climate.
That evolution continued earlier this year when the IRS expanded the correction options for situations when participants are not signed up to make 401(k) deferrals when they are supposed to be. The Service also finalized a pilot program for certain single-participant plans that file their Forms 5500-EZ after the deadline. Let's take a look.
Missed 401(k) Deferrals
The "Old" Rules
For the last several years, the "standard" correction for not timely enrolling an employee in the 401(k) plan has been a five-step process:
- Determine how much the employee would have deferred—referred to as the missed deferral opportunity;
- Calculate a corrective qualified nonelective contribution equal to 50% of the missed deferral opportunity;
- Calculate the related matching contribution using 100% of the missed deferral opportunity;
- Adjust the qualified nonelective contribution and match for investment gains; and
- Deposit the sum of steps 2, 3 and 4 into the participant's account in the plan.
Prior to 2008, the qualified nonelective contribution in step #2 was required to be 100% of the missed deferral opportunity, so the reduction to 50% was a welcome change.
The IRS provides guidelines for determining how much the employee would have deferred. For example, if an employee enrolled but the enrollment was never implemented, the missed deferral opportunity is based on the actual enrollment. If the employee wasn't given the opportunity to enroll, the missed deferral opportunity is equal to the average of the employee's group (either highly compensated or non-highly compensated). There are several other parameters for different situations, but we will spare you those gory details here.
Fortunately, this correction methodology is still completely acceptable. In a Revenue Procedure published in the spring of this year, the IRS provided a couple of new options for correcting missed deferral opportunities, one for automatic enrollment plans and one for traditional 401(k) plans.
Before getting into some of the details, it is helpful to note that the new options only apply to the calculation of the qualified nonelective contribution (step #2, above). Any missed match must still be corrected as noted in step #3, i.e., applying the match formula to the full amount the participant would have deferred if timely enrolled.
It is also worth noting that unless the plan's investments suffered a loss for the time period in question, corrective contributions must always be adjusted to compensate for lost investment earnings.
New Option for Traditional Enrollment 401(k) Plans
For traditional plans that require participants to make an affirmative deferral election, the new option creates a rolling three-month correction window. In a nutshell, if the participant in question is properly enrolled and has deferrals withheld no later than three months following the initial failure, then no qualified nonelective contribution is required. If correct deferrals begin after more than three months but less than two years, the qualified nonelective contribution is reduced to 25%.
There are a couple of small strings attached. The first string is that if the missed employee catches the problem earlier than three months after the initial failure, the company must implement the correct deferrals no later than the first pay period of the month after the employee brings it to the company's attention. In other words, the company can't sit back and say, "Bummer, but we can wait up to three months before we do something about it." Seems like that would have been obvious, but they probably have to plan for that one person who tries to get snarky.
The second string is that the company must provide written notice of the failure to all affected participants. More on that later.
New Option for Automatic Enrollment 401(k) Plans
Ever since Congress passed the Pension Protection Act of 2006, automatic enrollment has become an increasingly popular concept. One of the challenges in getting it from concept to implementation has been the fact that it is easy for new hires to fall through the cracks, especially in plans that have eligibility requirements that extend beyond a month or two after date of hire. And it has been a pain in the neck to go through the corrective calculations every time it happens.
In response to that concern, the IRS also created a new correction for automatic enrollment plans. As long as the failure to automatically enroll a participant on a timely basis is caught and correct deferrals withheld no later than 9½ months after the close of the plan year of the failure, then no qualified nonelective contribution is required. In addition, if the participant did not make an investment election, the lost earnings calculation for the match can be determined using the plan's qualified default investment alternative.
The same strings are attached. Specifically, the correct deferrals must begin earlier if the participant in question brings it to the company's attention, and the company must provide written notice to the impacted participants.
The Notice
It seems like every new rule in the last 10 years has been accompanied by a notice, and this change is no exception. Fortunately, this notice is relatively straightforward. In order to take advantage of either of the new options, the sponsor must provide a notice to all impacted participants no later than 45 days following the date correct deferrals begin that provides:
- General information about the failure;
- A statement that correct deferrals are now being withheld;
- A statement that corrective matching contributions (if the plan provides for one) have been made;
- An explanation that the participant may increase deferrals to make up for those that were missed; and
- Plan contact information.
Is There a Catch?
Some may wonder why a company wouldn't take advantage of the new correction options. I mean both of them are less expensive than the standard 50% qualified nonelective contribution. There are several reasons that come to mind, both related to the notice. First, some companies may be reluctant to provide to employees a written statement of an error involving payroll and retirement accounts, especially in a case of already strained employee relations.
The second relates to the timing of the notice. If a company catches the failure and starts withholding the correct deferrals but doesn't provide the notice within 45 days, they are no longer eligible for the reduced qualified nonelective contribution and must revert to the 50% level.
Late Filing of Form 5500-EZ
Most retirement plans are required to file a Form 5500 each year, and the deadline is the end of the 7th month following the close of the plan year (July 31st for calendar year plans). The deadline can be extended by 2½ months (to October 15th for calendar year plans) by filing Form 5558. Hefty penalties could apply ($1,100 per day to the Department of Labor and up to $15,000 to the IRS) for failure to file timely.
For many years, the Department of Labor has had a delinquent filer program that allowed late/non-filers to get caught up and pay a very reduced fee, as low as $750 in some cases. However, that program only applies to companies that must file a Form 5500-SF or Form 5500.
Plans that cover only the owner or partners of a business and their spouses do not normally file one of these forms. Instead they file Form 5500-EZ. If an EZ filer happened to be late, the only option has been to write a so-called "reasonable cause" letter to the IRS to ask them to accept the late filing and forego any fines.
In 2014, the IRS created a pilot program that formally addresses late filing of Form 5500-EZ. After running that program for a year and soliciting feedback from the community, the Service finalized the program earlier this year.
Under the permanent program an EZ filer, as described above, can submit delinquent returns for a plan and pay a reduced penalty of $500 per delinquent filing, up to a maximum of $1,500 per plan if more than three years of returns are submitted. The returns that are submitted must be the forms that applied for the year in question. There are certain limited exceptions that allow use of the current version of the Form 5500-EZ.
In addition, the submission must include a completed Form 14704, attached to the front of the oldest delinquent return in the package, along with a check payable to the United States Treasury for the reduced penalty amount.
The Revenue Procedure that described the correction program makes it clear that EZ filers still have the option to submit a reasonable cause letter in lieu of using the program. However, the IRS also makes it clear that if the reasonable cause is not accepted, the plan will no longer be eligible to use the delinquent filer program and will be assessed the otherwise applicable penalties. If past experiences with government agencies are any indication, they tend to be much less accepting of reasonable causes once there is a formal correction program available, so proceed along that route with caution.
Unfortunately, retirement plans are complicated and have many moving parts that can lead to the occasional OOPS! Fortunately, the IRS continues to provide newer and easier ways to correct many of the more common oversights that can occur without breaking the bank in the process. If you think there might be a mistake lurking in a dark corner of your plan, let your team of service providers know so that they can help you fix it voluntarily rather than after the IRS finds it.
Who gets a cut of your retirement plan fees?
By Chad Parks
August 28, 2015
"Are you paying anything for your retirement plan?"
When asked that question during an AARP survey, 71% of respondents answered no, compared to 23% who believed they do pay for their plan (6% were unsure).
The fact that seven in 10 Americans do not believe they pay anything for their plan is troubling, especially because 401(k) fees can be exorbitant and are distributed to multiple sources. The industry has done a stellar job of remaining opaque on the subject of fees, despite the Department of Labor enacting tougher fee disclosure rules in 2012.
Where do these fees go? There are a number of hands in the pot, so to speak. Here are the three entities that collect on your 401(k) fees, no matter how high or low they are.
1) Administration
For every 401(k) plan, an important legal component is the third-party administrator. Administration refers to the responsibilities of a third party to manage the intricacies of the federal regulations that govern the actual 401(k) code of retirement planning. In short, this is a group that ensures your 401(k) is compliant.
Those responsibilities include, but are not limited to, making required amendments to the documents, administering the required year-end testing and reporting the Form 5500 (think 401(k) tax forms) to the IRS.
2) Record keeping
The record keeper is the person who looks after the numbers for your business. They keep track of employees' money and the gains/losses on the funds that need to be entered each day. They are also responsible for year-end reporting, calculation of vesting, numbers reported back for IRS tax forms and compliance testing, etc. The numbers are just as important as, if not more than, the legal aspects.
3) Investments
All 401(k) plans contain asset-based fees that vary and go into three different sources. These fees can run anywhere from 1-2% of your 401(k) balance, which is like a double-edged sword; the larger your balance, the more you pay in investment fees.
First, the fees are distributed to the fund company that created the fund for you. Then, fees are paid to your adviser. While this is usually someone whose job is to meet with you and educate you on your 401(k), they're also licensed to sell these funds and get a kickback for doing all the foot work to bring the client to the table in the first place. As long as your 401(k) is running, they're getting a percentage, too.
401(k) participants should realize that while there is no free lunch.
Does Your Small Business Buy Into Bogus 401(k) Misconceptions?
by Andrew August 25, 2015 at 8:15 am
Small business owners wear quite a few hats:
Accountant, HR consultant, sales lead, recruiter and face of the company. It's no wonder why they would shirk any additional responsibilities – including offering employee benefits like a retirement plan.
Don't give into small business 401(k) misconceptions
In the past, small businesses have had few retirement plan options that were built for their needs and employees. The industry had no problem marginalizing small businesses in favor of large ones with huge plan assets.
The good news is that those days are long over! Still, many small business owners wrongfully buy into mistruths about retirement plans – especially 401(k)s – that were perpetuated a long time ago and continue to be believed today without merit.
I want to clear the air and put these common 401(k) misconceptions to rest once and for all.
- 401(k) plans are time-consuming and designed for big businesses
Unfortunately, a lot of small business owners are under the impression that 401(k) plans are a one-size-fits-all benefit that can't be customized to meet their needs without the labor and high fees. Owners envision a heap of confusing paperwork, and they want to sidestep the additional time commitment.
The good news is there are plans available to small businesses that were designed with their needs and employees in mind. No longer do small businesses have to accept plans that are built for gigantic corporations with hundreds, if not thousands of people. Nowadays, plans exist that are customized for businesses with 50 or less employees. There are even 401(k)s built specifically for sole proprietors.
As far as the perceived time commitment, those same plans can be up and running in less than a week and require only an hour each month to maintain.
- Matching is a must
Even though matching employee contributions is a great way to recruit and retain talent, it's not a requirement.
If a small business owner doesn't want to or can't afford to match, that's perfectly fine. As an employer, you are already offering a wonderful service to employees by implementing a plan – matching, while there are tax benefits that come along with it, is simply icing on the cake.
For your hard-working employees, at the end of the day, some savings is better than no savings.
- 401(k)s are too expensive to implement and maintain
We know the thought of extra administrative fees weighs heavy in the minds of small business owners. Though there is some relief–through a tax credit—up to 50 percent of the cost to set up and administer the plan.
Ultimately, a plan's cost depends on the bells and whistles that come with it—some basic plans can cost as little as $90 a month – that's less than what your business likely pays to fill the water cooler each month!
- High fees and poor advice are just part of the deal
Small business owners face many challenges and work way more than the average person to keep their business running efficiently. Why then do some retirement industry companies still expect you to settle for an inferior plan that charges exorbitant amounts and doesn't offer solid advice on how to invest? Just because you may have fewer employees does not mean your retirement plan should suffer.
When the right plan is selected, small businesses are able to access low cost, effective funds for their 401(k) plan. No longer will small businesses and their employees settle for poor performing, high cost funds that just absorb returns.
Likewise, employees should not feel like they're alone and in the dark when selecting the retirement plan that will hopefully lead to their dreams coming true.
Small business owners shouldn't be misled and buy into common myths that will discourage them from offering a 401(k) plan. Giving your employees a way to save for their retirement is a cheap and easy way to attract and retain talent and maintain an edge against the competition. For employees, participation in a 401(k) plan is a simple, effective way to save for retirement.
Now that you're armed with the truth, march fearlessly into the next steps of retirement planning!
Benefit Opportunity Results From Weak Markets
September 29, 2015 by Robert C. Lawton
By Robert C. Lawton, AIF, CRPS, President, Lawton Retirement Plan Consultants, LLC
The bad equity markets have one silver lining for those executives in your organization that might have large 401(k) account balances: In-plan conversions to Roth 401(k) accounts.
Why now?
Most of us have experienced significant declines in the value of our 401(k) account balances as a result of weak equity markets. For executives, these losses may have been even greater if they had a well diversified 401(k) account with a heavy allocation to equities and exposure to commodities. These executives may have unrealized losses in their accounts of as much as 20% or 30%.
Converting pre-tax 401(k) balances into after-tax Roth 401(k) balances results in taxation of the previously tax-free amounts. Converting when the account value is lower may result in a substantial tax savings. Following is an example.
In-plan Roth 401(k) conversion example
Let's assume one of your executives has a $1,000,000 account balance and is interested in converting 20% of it into a Roth 401(k) account. Prior to the recent decline in market value, assume that the existing $200,000 slice of this executive's account was worth $300,000. In other words, assume the executive has experienced a 33% decline in the value of his/her account.
Taxes are due on any amounts converted into Roth 401(k) accounts. So the executive would owe state and federal income taxes on the $200,000 of his/her account balance that was converted. However, the executive would save paying taxes on the difference between the previous value of $300,000 and the current value of $200,000. In this example, an executive subject to a combined 30% state and federal tax rate would save $30,000 in taxes, and possibly much, much more.
Additional benefits of Roth 401(k) accounts
Roth 401(k) account balances residing in the accounts for five or more years and withdrawn for permissible reasons are not subject to any state or federal taxes when distributed. We know the markets will bounce back and assuming that this executive experiences a reasonable rate of return for the next 10 years, his/her tax savings on the $200,000 that is converted and withdrawn completely tax free sometime in the future could be enormous.
What you should do
Roth 401(k) in-plan conversions can benefit almost any plan participant. In order for your 401(k) plan to permit such exchanges, it needs to allow for Roth 401(k) accounts and in-plan conversions. If your plan currently isn't structured this way, don't worry, all you need to do is amend it.
There aren't many benefits your executives can enjoy these days. Consider sharing this opportunity with them.
Delinquent Form 5500 filers find help
Late to file? You might still avoid a penalty
Sep 28, 2015 | By Nick Thornton
A joint initiative by the Internal Revenue Service and the Department of Labor is examining Form 5500 filings for the plan year ending in 2011 to smoke out those sponsors that have yet to file but were required to.
The initiative is being overseen by the Employee Plans Compliance Unit at the IRS and the Office of the Chief Accountant at the DOL, according to information released on the IRS's website earlier in September.
The IRS says the primary goal of the program is to ensure compliance.
However, the regulators would also like to know why sponsors who were required to file Form 5500s didn't, and whether or not the agencies need to do anything to remove "impediments to compliance."
Under the Employee Retirement Income Security Act, Form 5500s are due to the IRS the last day of the seventh month after the plan year ends, according to the agency's website.
So for the plan year ending in 2011, the due date would by July 31 of the next year for a calendar-year plan.
The DOL and IRS try to discourage late filers by imposing steep fines. The IRS penalty is $25 per day, up to a maximum of $15,000. That would mean 600 days worth of fines.
For the DOL, the penalty is potentially far more severe. It can run up to $1,100 per day, with no cap on a maximum penalty.
Those penalties present the potential for some massive punishment. More than 1,100 days have passed since July 31, 2012—the due date for plan year 2011 filings.
Conceivably, plans delinquent for that entire period could face fines that surpass $1.2 million.
But the IRS and DOL are not without a more merciful side.
The DOL's Delinquent Filer Voluntary Compliance Program significantly reduces delinquency penalties if late filers submit the Form, along with those reduced penalties, before the DOL notifies the plan administrator about the delinquency.
Which is to say, if a plan turns itself in before the DOL catches the delinquency, a lot of money can be saved.
Just how much? For small plans with fewer than 100 participants, the fine is $10 per late day, with a $750 cap.
Large plan filers also pay a fine of $10 per day, with a cap at $2,000 per benefit plan.
There is one important "wild card" in the question of whether a sponsor, who might have been under an honest but mistaken perception that it was not required to file a Form 5500, would be eligible for relief under the Delinquent Filer Voluntary Compliance Program.
Plans that receive a late-filer letter from the IRS are still eligible for the relief under the program.
However, if a plan administrator fails to self-correct the issue before receiving DOL notice, they are not.
If a sponsor were to discover that it should have filed when it had not, why wait and take the chance of hearing from the DOL first, potentially eliminating eligibility for the fine relief under the delinquency program, asks Christopher Allesee, an attorney with Graydon Head and Ritchey.
In a blog post, Allesee says, "if you do not file a Form 5500, take a second look at your health or welfare plans to make sure they are not subject to ERISA, or that your plan meets an exception to the filing requirements."
He adds: "For any filings you have missed, consider submitting under the delinquent filer program as a proactive measure, or you may wind up explaining your actions to the IRS and might even lose out on the chance for a far cheaper resolution through the DOL's delinquent filer program."
401k Document Retention Rules Made Simple
Posted by Eric Droblyen on Oct 7, 2015
Did you know that ERISA requires all employers to retain detailed 401k documents, including testing results, transactions and employee activity – for at least 6 years? If you did not, you've got a lot of company. Nevertheless, it's important to understand and comply with these rules. While only small civil penalties are possible if required plan records are not preserved, missing records can make it more difficult for a 401k sponsor to defend plan operations or the accuracy of benefit payments if they are ever challenged by the IRS, DOL or plan participants. That can increase liability.
In general, 401k plan records must be kept for a period of not less than six years after the filing date of the IRS Form 5500 created from those records. However, records necessary to a participant's claim for plan benefits must be kept longer. These records must be kept "as long as a possibility exists that they might be relevant to a determination of the benefit entitlements of a participant or beneficiary." This can mean indefinitely.
Some of the most common plan records a 401k sponsor must retain are itemized below. To organize this information, I recommend using three files – a file to store documents that govern plan operation (a "Plan Document File"), a file for participant records (a "Participant File"), and a file for plan year information (a "Plan Year File"). This simple three file system should make it easy to access plan records if they are ever needed.
Plan Document File
This file should contain the plan's operating documents. As items in this file are replaced by new documents, it is recommended you archive each replaced item in a safe spot for historical reference.
Items to keep in the Plan Document File include:
- Plan Documents – adoption agreement, base document, IRS advisory letter, amendments, QDRO policy, and loan policy (if loans are permitted)
- Participant Disclosures – Summary Plan Description (SPD), Summary of Material Modification (SMM)
- Corporate Actions – resolutions, agendas, minutes, and documents distributed at meetings
- Service Agreements – Includes all plan service provider contracts
- 408b-2 Fee Disclosure(s) – Includes fees and services delivered by plan service providers
- Fidelity Bond – ERISA Section 412(a) requires every fiduciary of an employee benefit plan and every person who handles funds or other plan property be bonded.
Participant File
This file should contain forms provided by plan participants. Generally, these forms direct the 401k sponsor to take certain actions on the participant's behalf.
Items to keep in the Participant File include:
- Payroll Records
- Participant Deferral Election Forms
- Investment Election Change Forms
- Beneficiary Designation Forms
- Distribution Request Forms (with any supporting documentation)
- Loan Request Forms
- Rollover Requests
- QDRO Split Requests (with supporting documentation)
Plan Year File
This file should contain important records related to a plan year. A Plan Year file should exist for each plan year the plan has existed.
Items to keep in the Plan Year File include:
- Annual Valuation – Contains participant-level transaction information for the plan year, including contribution, distribution and fee activity. If received quarterly, file all four quarters.
- Annual Trustee/Custodian report – Contains trust-level transaction information for the plan year, including all purchases and sales that occurred in trust. If received quarterly, file all four quarters.
- Annual Nondiscrimination Testing – 401(k) plans have various testing requirements. Most common tests include:
- Coverage (IRC Section 410(b)) testing
- Actual Deferral Percentage (ADP) and Actual Contribution Percentage (ACP) testing (non-safe harbor 401(k) plans only)
- Excess Deferral (IRC Section 402(g)) testing
- Annual Addition (IRC Section 415(c)) testing
- Top Heavy (IRC Section 416) testing
- Rate Group (IRC Section 401(a)(4)) testing ("new comparability" plans only)
- Annual Participant Notices – Any notices provided to participants, including (as applicable):
- Participant fee disclosure (ERISA 404a-5) notice
- Safe harbor 401(k) plan notice
- Qualified Default Investment Alternative (QDIA) notice
- Automatic (negative) enrollment notice
- Form 5500 – Copy of Form 5500 with related schedules as filed with Department of Labor (DOL)
- Independent Audit Report – If required to be filed with Form 5500
- Summary Annual Report – Summary of Form 5500 provided to participants
Don't get into trouble when document retention is easy
A retirement plan, by its very nature, generates large amounts of documentation and preserving much of it is required by ERSIA. Developing a filing system can make it easy for 401k sponsors to review, update, preserve, and dispose of documents.
These systems do not need to be complex. A simple system with 3 file types can do the trick. Ready access to plan documentation can mean the difference between a quick, cost-free settlement to a 401k dispute or a drawn-out, costly battle.
Selecting 401k Service Providers: Determine the Professional Help You Need Before You Shop
Posted by Eric Droblyen on Oct 21, 2015
- Selecting competent service providers is the most important - and most confusing - fiduciary duty of a 401k sponsor. Why? Services offered by 401k providers can vary dramatically in breadth, depth and price. This variability makes it difficult for 401k sponsors to match appropriate services to plan needs. Many small business 401k plans pay for superfluous services participants do not use. These excess services are often expensive, dragging down participant investment returns and creating potential personal fiduciary liability for the 401k sponsor.
If you sponsor a 401k plan, I recommend following a two-step process to ensure your plan does not pay fees for services your participants will not use: 1) understand the services that compose a 401k plan and 2) determine which of these services require professional assistance to deliver. Once this process is complete, you'll be ready to shop for professional service providers.
Step 1 – Understand 401k services
Every 401k plan requires multiple services. These services fall into two categories, plan administration or investment management.
- Plan administration services include:
- Custody – to hold plan assets in a trust and execute trades
- Recordkeeping – to track contributions, earnings and investments on a participant-level and direct the custodian to execute trades
- Third-Party Administration (TPA) – to complete plan design and annual ERISA compliance (testing, Form 5500, plan document maintenance, participant notices)
- Investment management services include:
- Plan-level services – to select a fund lineup for participants to choose from
- Participant-level services – to assist participants in choosing investments for their account
Step 2 – Determine the 401k services for which professional assistance is needed
- Plan administration services
Virtually every 401k plan today outsources plan administration services to a professional service provider because it's rarely cost effective to do this work in-house - recordkeeping software is expensive, while securities trading and ERISA compliance requires years of specialized experience.
The question is not whether your plan needs a professional plan administration service provider, but how many it needs – it can sometimes take more than one provider to deliver plan administration services. While Employee Fiduciary provides all 3 plan administration services, many providers just offer 1) custody and recordkeeping ("recordkeeping only") services, or 2) TPA services. When a provider fails to offer all 3 plan administration services, a second provider must be found to deliver the missing service(s).
- Investment management services
While a professional service provider is required nearly 100% of the time to deliver plan administration services, the same is not true for investment management services – a professional financial advisor may not be required. To make this determination for your plan, consider:
- Your plan's investment objectives
- The type of investment advice wanted for participants
Plan investment objectives
For decades, actively-managed mutual funds were the most popular type of investment used by 401k plans. Actively-managed mutual funds employ portfolio managers to attempt to select stocks that beat market benchmarks like the Standard & Poor's 500. Recently, however, passively-managed index funds have grown increasingly popular. In contrast to actively-managed funds, Index funds try to track (not beat) the performance of a particular market benchmark—or "index"—as closely as possible.
Why are index funds growing in popularity? While it may seem counter-intuitive, a growing body of academic research has shown that index funds outperform most of their actively-managed counterparts over decades of 401k investing, particularly after all fund expenses are considered.
If you prefer index funds, a financial advisor may not be required because it's not difficult to pick funds that deliver "market returns." An example of an all index fund lineup can be found here.
If you prefer actively-managed funds, use of a financial advisor is highly recommended. It takes a lot of skill to consistently pick actively-managed funds that outperform their index fund counterparts. Using actively-managed funds also requires much more sophisticated monitoring to ensure investments outperform their index benchmark and peer group averages. Fiduciary liability can result if high-priced actively managed funds underperform their lower-priced index fund counterparts.
Participant investment advice
Participant investment advice is important. An Aon Hewitt study found that median investment returns for 401k participants using Target Date Funds (TDFs), managed accounts and personal investment advice were 3.32% greater than returns earned by participants that picked an investment portfolio themselves. In short, professional advice is proven to help participant investing success.
Generally-speaking, there are two ways 401k plans deliver participant investment advice today:
- Design-based – TDFs or Target Risk Funds (TRFs) are included in a fund lineup to give participants access to professionally-managed investment portfolios. Participants invest 100% of their account in the most applicable fund.
- Advisor-based - A financial advisor is hired to either construct custom TDFs or TRFs for participants to select or give one-on-one investment advice.
If you prefer the design-based approach, a financial advisor may not be required since participants can achieve professional portfolio management by investing 100% of their account in the fund that best matches their estimated retirement date (if TDFs are used) or risk tolerance (if TRFs are used).
If you prefer more customized investment advice, you should hire a professional financial advisor.


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Morning all! Hope everyone is having a fabulous day. I've been really MIA lately, wrapped up in my novel that I've barely left the house. But not today. Today I forced myself out of my pyjamas and as we speak, I'm sitting in a cozy little cafe, with a steaming cup of peppermint tea inContinue reading "Unleashing My Inner Child At Disneyland Paris"
Author Archives: Nerissa Templin
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McCormick Slow Cookers Beef and Red Wine Casserole Recipe Base 40 g, 40 g
- Delicious beef casserole with fall apart meat and tender vegetables
- Slow cooked in a rich red wine gravy
- A delicious side dish the whole family will love
- Easy to prepare
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Product details
- Product Dimensions : 13 x 11 x 15.5 cm; 40 Grams
- Date First Available : 4 March 2019
- Manufacturer : McCormick
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5,882 in Pantry Food & Drinks (See Top 100 in Pantry Food & Drinks)
- 162 in Spices & Seasonings
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Thickeners (1442, 415), Vegetable Powders [Garlic (7%), Onion, Tomato], Salt, Wheat Flour, Red Wine Extract Powder (10%) [Maltodextrin (Contains Wheat), Wine Extract (1%)], Dextrose, Natural Flavour, Hydrolysed Soy Protein, Black Pepper (2.5%), Herbs [Rosemary (1.5%), Thyme], Soybean Oil, Anti-Caking Agent (551).
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Product description
This elegant, comfort-food classic is now easy to prepare with McCormick Slow Cookers Beef and Red Wine Casserole Seasoning. Create a delicious beef casserole with fall apart meat and tender vegetables, slow cooked in a rich red wine gravy. A delicious side dish the whole family will love. No artificial colours and flavours. No added MSG also.


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Discussion Starter • #1 •
My 98 mustang has been having problems starting. I would drive somewhere and shut the car off for a few minutes while i ran in somewhere and then when i came back out the car would take forever to start because it would just keep cranking. recently my car has just been sitting in the garage and it would just crank but would not turnover. I replaced the fuel filter and the spark plugs but it still wouldnt start. Last night i went out and just added some gas to the tank and threw in a bottle of heet and it started, but then when i started to back down the driveway it died ans would not restart. Now the car wont even crank and it just faintly clicks and makes a buzzing noise, the theft light will blink, but if i unhook the battery and reconnect it the light will go off. I really dont know what it is. I need help. any ideas?


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January 02, 2014 at 12:53pm
I could use some advice for duck hunting Manchac WMA. I have been out for multiple hunts and so far have 2 birds in the freezer. IT has gotten so bad that on the last 2 hunts I didn't see anything remotely close enough to shoot at. Is anyone having luck out there? I've tried some potholes and I even went down to the open area of the prairie on the last hunt and still nothing. Should I try mid-day hunts or is this just the year of no birds?


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If it's not broken, why fix it? Xiaomi's Mi MIX 2, a sleek, bezelless upgrade released December last year, didn't look much different from the original Mi Mix itself. With the Mi MIX 2S, a new white colourway, and an iPhone X-esque dual camera unit on the rear would be the only differences immediately noticeable to any casual observer.
Xiaomi had, in fact, narrowed both the vertical and horizontal bezels by about a millimetre for an improved screen-to-body ratio. But anyone would be too enraptured by the metal and ceramic body to notice. I've had plenty of confused faces asking if my Xiaomi Mi MIX 2 was an iPhone X, but Xiaomi's arrangement of the dual camera unit would raise some eyebrows. Both cameras sport bigger pixels for added low-light performance, while sporting OIS, something still rather rare in the industry.
The cameras are worth a second mention – DxO Mark has even awarded it a score of 97, sharing the same slot as the iPhone X and the Huawei Mate 10. The top one is a wide-angle lens with larger 1.4ɥm pixels and impressive f/1.8 aperture (the Sony IMX363 module), while the bottom one is a telephoto lens with an aperture of f/2.4 and 1ɥm pixels (Samsung S5K3M3 module). Dual Pixel autofocus technology might be a world smartphone premiere, with quick and accurate autofocus as seen on the Canon EOS DSLRs and Mirrorless cameras. To further enhance low-light performance, the Mi Mix 2s features multi-frame NR, which stacks multiple shots to reduce noise and artefacts.
The screen is still an IPS FHD+ 5.99-inch LCD, sporting its characteristic (and now rather trendy) 18:9 aspect ratio. Corning 2.5D Gorilla glass sits atop, beautifully curved at the edges. Like previous iterations, a 5-megapixel front-facing camera sits at the bottom, requiring users to flip the phone around to snap selfies without nostril-enlarging angles.
True to its flagship aspirations, Xiaomi has pumped the best chipsets into the Mi MIX 2S. The Qualcomm Snapdragon 845 chipset is a significant upgrade over the 835 sported on the Mi MIX 2, promising increased power without added battery drain. It still ships with Android 8.0, but adds Mi UI on top of that – something that users love to hate, or, in my case, hate to love.
Adding to the list of already-impressive specifications, the Xiaomi Mi MIX 2S will also feature Qi wireless charging – a no-brainer given its non-conductive ceramic back surface. It also means Xiaomi is the first in the world to implement wireless charging through a ceramic chassis. To sweeten the deal, a $16 Qi wireless charger would also be premiered.
Connectivity is bumped up with Bluetooth 5.0, particularly enticing with the immense range of high-quality wireless audio options available these days.
However, no protection against moisture and dust has been introduced, still a substantial difference from many flagship devices. Other features remain unchanged from its recently-released predecessor: its large capacity 3,400mAh battery with Qualcomm Quick Charge 3 support, USB C (but only at USB 2.0), and its impressive range of support of international mobile network bands.


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Mumbai. 2003. It was a different city. The war against the underworld had been declared. And the mandate to gun them down given to a chosen few. One of them was Pratap Pandit. The other, Arun Inaamdar. Two encounter specialists. Each with a strong informer base. Sharp strategy. And a long tally of dead gangsters.
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It seems baby mania has taken over Hollywood once again.
Chrissy Teigen and husband John Legend welcomed their baby daughter, Luna last Thursday. Blake Lively and Ryan Reynolds announced they were expecting their second child, as did equally good-looking couple Ryan Gosling and Eva Mendes. It seems all our favourite celebs have jumped on the procreating bang wagon.
Not one to miss out on a trend, our '90s crush and favourite Backstreet boy, Nick Carter, today announced the arrival of his first-born.
Odin Reign Carter was born on Tuesday after Carter's wife, veterinary technician specialist, Lauren, went through a 30-hour labour. At home. In the bath.
The water birth resulted in little Odin being brought into the world weighing 3.6kg.
Carter, who resumed the title of 'Hottest Carter' after his brother Aaron's untimely split with Hilary Duff in 2003, took to Twitter in the days leading up to the birth, using the hash tag #countdowntobabycarter.
Baby watch continues. Thank you for all your prayers and warm wishes! ????????????????????????❤❤❤????????
— Nick Carter (@nickcarter) April 16, 2016
Still no baby yet. Days away ???????????? #excited#baby #daddy — Nick Carter (@nickcarter) April 13, 2016


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Many have written about the millennial generation and whether or not they, as a whole, believe in homeownership as part of attaining the American Dream. Millennials have taken longer to obtain traditional milestones than the generations before them, such as getting married, having kids, and buying a home. However,… Read More
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How to Trade Options: A Beginners Introduction to Trading
It really is the best way to learn how to trade binary options. More Ways To Trade Binaries While we describe binary trading as an 'up or down' choice, there are other types of …
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Learn to trade options. Disclaimer: This site discusses exchange-traded options issued by the Options Clearing Corporation.No statement on this site is to be construed as a recommendation to
The Best Ways to Trade Stocks - wikiHow
From stock trading to options trading we have helped over 423,000 traders worldwide. For over 13 years, Rockwell Trading has simplified day trading to help you achieve your trading goals. From stock trading to options trading we have helped over 423,000 traders worldwide Learn How Markus Trades In Only 15 Minutes a Day With The Secret
Any good place to learn Options Trading ? : investing - reddit
Covered Calls: Learn How to Trade Stock and Options the Right Way. Covered Calls are one of the simplest and most effective strategies in options trading. The art and science of selling calls against stock involves understanding the true risks of the trade, as well as knowing what kind of outcomes you can have in the trade.
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Asked to Answer. Options Trading requires 10 times the effort of learning stocks and futures. They are altogether a different universe. To learn to trade options, you may follow the below steps: 1.) What Options are exactly and what the heck are t
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Beginners who are starting to learn options trading can write covered calls, buy leap calls or sell put options to help develop their options strategy. buying out-of-the-money short-term calls is probably not the best way to start trading options. Let's look at an example of why.
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Discover the best Options Trading in Best Sellers. Find the top 100 most popular items in Amazon Books Best Sellers. Swing Trading with Options: How to Trade Big Trends for Big Profits Ivaylo Ivanov. 4.8 out of 5 stars 6. Kindle Edition. Learn How to Profit Fast Through Proven Methods Marcus Baumann. 4.2 out of 5 stars 54.
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Learn option trading and you can profit from any market condition. Understand how to trade the options market using the wide range of option strategies.. Discover new trading opportunities and the various ways of diversifying your investment portfolio with commodity and financial futures.
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1/30/2018 · Day trading options for income is a great way to make money in the stock market. The video below gives an overview on day trading options. We do a lot of day trading options in our trade rooms, so feel free to come and join our community to see us day trade them real-time on our live daily streams.
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Learn How to Trade Options : Step-by-Step Options Trading Tutorial. Over 5 lectures and 1 hour of video content. What does it take to become an Options Trading expert ? and you will be well on your way to making Options trading a reliable second income for life. Who this course is for:
How I Successfully Trade Weekly Options for Income
For example, a new options trader needs to learn about options Greeks, which help determine the price of an option. Those interested in futures trading need to learn about ticks, points, and the various specifications for each futures contract they may want to trade.
Covered Calls: Learn How to Trade Stock and Options the
Introduction to Options Trading. Dayana Yochim. Nov. 2, 2016 In order to trade options, you'll need a broker. Check out our detailed roundup of the best brokers for options traders,
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You will learn how to trade options for monthly income. These strategies will make anywhere between 3-7% per month. Ans – The best way to start learning any new strategy is to start with 1 lot only even if you are a crorepati. Remember whether its one lot or hundreds or lots, your first job is to understand the logic behind the strategies
Learn the Best Way to Trade & Trading Strategies
Binary options trading has grown over the years. Where it goes from here is still in question. Binary options trading is a way for you to potentially make money or lose everything you put into it. In the past, the stock market has been seen as a haven for people looking for big gains.
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Whether you are new to investing or are a seasoned professional, using options can be an efficient and easy way to protect the profits you have made, limit your loss, gain additional income or secure a specific stock price. The Options Institute's online courses are designed to help every level of investor gain a fuller understanding of the
The Best Options Trading Simulators in 2018 (Get Started
There are a variety of ways to learn about trading that provide different guidance on how best to turn a profit. The Balance Take Lessons in Trading to Learn How to Play the Market Trading seminars can be an expensive way to learn about trading, depending on the entrance fee. However, attending an in-person session does offer the novice
Introduction to Options Trading: How to Get Started
The best way for an absolute beginner to learn options trading in India is to go through a certification course of Option Trading Strategies Module offered by NSE India under NCFM umbrella. Please visit Page on nseindia.com for more details.
10 Great Ways to Learn Stock Trading - StockTrader.com
Binary Options are a way to see the movement in value of a large and dynamic range of commodities, assets, stocks and shares or even Forex. of food for thought in regards to which Binary Options you should be looking to trade and when is the best time to trade them! Binary Options Trading Tips & Strategies We have We only present to you
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Discover how to trade options in a speculative market Learn the basics and explore potential new opportunities on how to trade options The options market provides a wide array of choices for the trader.
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A huge list of the best books on investing; Any good place to learn Options Trading ? (self.investing) Thinkorswim has a paper trading module that will let you trade options or futures or whatever, but the software is a little complex to navigate. I also like Tradeking's P&L modeling tool for designing spreads.
Options Trading Explained - Free Online Guide to Trading
What is the best way to learn how to trade options ? August 16, 2017 wcadmin. Option are the contract that gives you a right but not the obligation to buy or sell an underlying asset at fix future date and on specified predecided price.
What does it take to become an Options Trading expert
The way you approach and think about money, in general, will have a direct impact on how you trade options. The best thing you can do before you fund your account and start trading is to clearly define your investing goals. Learn More About Ally Options Trading
Options Playbook - Learn To Trade Options - The Options
Learn on the forums. Another good way to learn options is trading is through trading forums. A couple that you can consider are Trade2Win, Investopedia and EliteTrader. These forums will give you a venue where you can ask questions. Also, some traders post trading journals you can follow along with.
How to Trade Options - Learn Trading Basics from Pros
1/6/2008 · The easiest way to trade stocks will be to pay someone else to trade stocks. There are a number of well known stock brokers, and you should not have trouble finding someone who can place trades for you and give you advice. To trade at the best possible price. Correct! Using a market order to trade stocks ensures you get the best
The Best Stocks for Options Trading
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Artificial Intelligence is mainly a systemic procedure that deals with the procedure of manufacturing machines or systems to do several tasks which generally require human intelligence to complete the tasks. It is the replication of human intelligence by machines and it incorporates learning, self-correction, reasoning, speech recognition, and machine vision. Artificial Intelligence Training program is uniquely designed to help you learn the concept of artificial intelligence such as Deep Networks, Structured Knowledge, Hacking, Machine Learning, Natural Language Processing, Recurrent Neural Network, Artificial and Conventional Neural Network, Self-Organizing Maps, LDA, Dimensionality Reduction, Model Selection and Boosting. In addition to this, the training program will help you to get the best jobs in the industry and not only this you can certainly improve your chances of employability by gaining more knowledge on the associated technologies such as IoT and Robotics. Learning Modules of Artificial Intelligence Training are as follows:
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I made everyone laugh, I was the nicest( and maybe weirdest) of the group, I was invited to all the parties for the, and I went around with seven different companies, but who was it that really remained attached to me? NOBODY. I realized I did not appreciate anyone's life, the two girls I had had before then had left me after not even two weeks of laughing and kissing, I was alone in the Stettler Alberta casual sex mn of the multitude, obsessed with being the centre of attention, masking my despair with an idiotic smile on my face and a fake dumb joy that I did not feel. I asked myself: Why not I have a minumum of one correct relationship? Why do I have a lot of things that are fantastic to give but no one sees them? Why is this happening to me? Why do" popular" , stupid, and shallow backpage escorts deserve to be happy and I am here like an asshole that does not even know which path to follow? I stopped to inquire: " What made me reach the limitation? What was what destroyed me" In such years the replies have been many, but I have come to a very simple decision: the causes of my isolation within myself happen to be Is backpage safe for escorts Stettler Alberta condition: I grew up in a hidden fuck buddy Stettler AB not absolutely open- minded that has never left me overlook anything, had always protected me and informed me exactly what I needed to do to be a fantastic boy. Ipersonally, as a kid, was following everything they taught me. I'll never stop thanking my parents for what they did, since I consider myself a person having a wonderful women escorts backpage Stettler Alberta and equipped to respect people, but the simple fact is that every Stettler AB real street hookers influence is not totally favorable since, as imperfect humans, we additionally transmit negative aspects. From my father in particular I have sadly learned to backpage escorts that a trick was ready to Stettler Alberta american online dating free on me and to be afraid of this world.
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The target is likely to only react to your comment, which leaves you the rest to keep it moving. If you go in without a back up conversation points you might find yourself.


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Mondays, Wednesdays, and Fridays from 8:00 am - 9:00 am
We are starting a walking group for active members! Meet out by our Soccer Field to walk with the group while social distancing around the Ball Field Complex. You can choose to walk 1 or 2 miles. This is a COMPLIMENTARY PROGRAM but registration is required.
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MPCL arranges financing of Rs. 9.0 billion from Habib Bank Limited for Exploration and Development Projects
Mari Petroleum Company Limited has signed a Six Years' Term Finance Agreement with Habib Bank Limited for an amount of Rs. 9.0 billion for exploration and developmental projects to be carried out in various fields/blocks. The loan agreement was signed in a ceremony held at Serena Hotel on September 21, 2016.
Mari Petroleum Company Limited is managing and operating Country's largest gas reservoir (in term of balance reserves) at Mari Field, District Ghotki, Sindh. Besides Mari Field, the Company is an Operator/Joint Venture partner in sixteen other blocks in all the four provinces of Pakistan.
The Company was previously operating under a cost-plus formula which placed a cap of USD 40 million on its exploration and development activities resulting in a major impediment to achieving its desired expansion potential and plans. Effective July 01, 2014, the cost-plus formula was replaced with a market related formula which has removed the cap on exploration expenditure allowing the Company to operate on commercial lines. This strategic change is sure to boost MPCL's exploration and production programs leading to its becoming a principal E&P company in the Country.
Long term financing of Rs. 9.0 billion from Habib Bank Limited will help in enhancing the reserve base of the Company and ensuring continuity of its operations for a longer period which will also significantly help in overcoming the energy crisis of the Country.
MPCL has an excellent exploration success rate which will help it to draw maximum benefits from this loan facility. The Company now seeks to take advantage of this window of opportunity by investing aggressively in exploration and development activities which will result in more discoveries and enhanced production.
MPCL's gross revenues for FY 2015-16 were Rs 96 billion, out of which Rs 77 billion (81%) were contributed to the national exchequer on account of Government levies. The Company leads the industry in its share value of Rs 940 at Pakistan Stock Exchange.


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"Mystery Christmas" is the Christmas-themed episode of Magic America USA's YouTube show Avengers Land Mystery, produced and aired as the sixth episode of its duration.
In Plotagon animation, It's Christmastime in the city when everyone loves the snow in the grass. After the show's theme song, using the now-defaunt dirty.it, it goes into the living room where a man, sitting with his wife in a cotch, have decided to go to the location where the next YouTube video "Frosty's Christmas Cabin" will be filmed at in a couple of days. The woman agrees with the name of the video as she declared Frosty as a legned, the man hugs her for a bit before settling.
After the short promo break, we go into the office space, as another man and woman is excited for "Frosty's Christmas Cabin", because they love Magic America USA and this show, Avengers Land Mystery. Outside in a bench, Mr. Yush and Queen Bunnie is also excited for "F'sXmasCabin", hense Mr. Yush is narrating the program. He also mentions that Jarrett Blandin and LaNeeda Hudson will be in the program as well. Mr. Yush turns out to be Santa Claus himself as they love Magic America USA. In the North Pole, one of Santa's male elves is talking to Mr. Yush about packaging one present while talking to Bunnie. The program ends with girl and a female at the top of the moon, also excited for the program.
- Beethoven's "Ode to Joy"