2. Business Principles
We will not “sell” the bundled 401(k) products of other parties over which we have no
quality control.
We will not compromise our objectivity as investment managers by accepting “Revenue
Sharing” payments from mutual fund or insurance company investment sponsors.
We will fully, and transparently, disclose all fees earned from our plan sponsor clients and
their plan participants.
Our incentives for compensation as an investment manager will always be aligned with
those of our clients – to grow participant account values as quickly as possible with the
least amount of designated risk.
Wellington’s 401(k) Product Was Built On Core Principals
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3. Value Proposition
Reduce the time and costs required to administer your plan.
Expand and enhance your employee investment options.
Enhance the performance of your accounts by providing investment options with lower
internal expenses eliminating excess expenses that reduce investment returns each and
every year.
Provide fully-delegated, professional and truly objective money management to plan
participants who desire it.
Greatly reduce the personal liability of the plan trustee(s) and other company fiduciaries.
What Wellington Will Do For Your Company’s 401(k) Retirement Plan
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4. Recordkeeping Services
Easy Setup and Hassle-Free Administration
Document Design, Amendments and Restatements
Annual Plan Testing and Preparation of Form 5500
Secure Web-Based Data Transmission
Plan Sponsor Hot Line (Every Business Day Until 8:00 PM EST)
Comprehensive & Reliable
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5. Investment Options
Over 8,000 Mutual Funds Supported by Schwab’s “Open Architecture” Platform
“Vanguard” and Many “Institutional-Only” Share Classes Available
A Core Group of Very Low-Cost Employee Investment Options
• “Basic” Set of Investment Options*
• “Expanded” Set of Investment Options*
Stocks, Bonds, ETF’s and CDs May Also be Enabled if Desired
(Over 100 ETF’s available with no commission costs.)
Extensive Direct Assistance Available to all Participants
The Engine of 401(k) Plan Is Its Investment Options
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6. Investor Profiles
Each participant selects the appropriate level ofinvestment assistance by selecting one
of the three Investor Profile’s:
Profile 1 – Wellington Fully-Managed Model Portfolios
Profile 2 – Participant Customized Mutual Fund Portfolios
Profile 3 – Participant Self-Managed Account
Participants may change their Investor Profile at any point intime without penalty!
SERVICE OPTIONS ARE AS IMPORTANT
AS INVESTMENT OPTIONS
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7. Conservative
(0-5 Yrs.)
Moderate
(5-10 Yrs.)
Aggressive
(10+ Yrs.)
Investment Management
Years to Retirement (increasing)
RiskLevel
(Increasing)
Three Actively Managed “Targeted Retirement” Portfolios
“Custom Target Date” Portfolios are also available for auto-
enrollment 401(k) plans
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8. Participant Support
Initial and Ongoing Enrollment Meetings
Quarterly “Plan Update” Meetings and Communication
Participant Online Portal
Sample Videos
Participant Portal Screenshots
Additional Web-Based Resources
Schwab.com
Retirement Savings Calculator
Mutual Fund Screening
Additional Participant Resources
“Live” Client Service Personnel at both Wellington and Charles Schwab & Co. – one of the largest
financial service firms in the world.
Our Commitment To Your Plan Participants Is Ongoing
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9. Fiduciary Services
ERISA Section 3(38) “Discretionary” Fiduciaries
- Plan Sponsor Delegation of Personal Fiduciary Liability
ERISA Section 3(21) Fiduciaries
- Advice Without Protection
ERISA Section 3(16) Fiduciaries
- Basic Administration by “Co-Fiduciaries” and “Directed Trustees”
There Are Important Differences Between Plan Providers Acting As “Fiduciaries”
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10. Fiduciary Services
Only One Type Of Fiduciary Reduces Plan Sponsor Personal Liability
LevelofFiduciaryServices
Provided
Type of ERISA Fiduciary
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11. Fiduciary Services
The Type of Plan Provider that the people serving your company and your employees work for determines whether or not
they are held to a fiduciary standard.
There Are Also Important Differences Between The People Serving You And Your
Employees
Plan Provider Type Industry “Title(s)” Standard of Care
“Registered Investment Adviser”
Registered Investment Adviser
Representative
Fiduciary Standard
Broker/Dealer
“Broker” ”Adviser” “Consultant”
“Salesman”
No Fiduciary Standard (“Suitability”
Only)
Insurance Company
“Consultant” “Adviser” “Agent”
“Salesman”
No Fiduciary Standard
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12. Plan Recordkeeping Costs
Plan Information
Annual Administration
Other Fees & Services
Number of Active Plan Participants
(NOT based on “Employees” or “Eligible Employees”)
Base Fee (One base fee applicable for both companies)
Per Participant Fee ($25 x 25)
TOTAL
(A Federal Tax Credit May Apply for New Plans)
25
$1,200
$625
$1,825
Distributions (charged to participant)
Loans (charged to participant)
Loan Fee (invoiced to company)
$65 (Per Event)
$65 (Per Event)
$65 (Annual)
One-time Plan Setup
Base Fee
Per Participant Fee ($20 x 25)
TOTAL
$700
$500
$1,200
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13. Participant Management Fees
Apples-to-Apples Cost Comparison
Wellington includes ERISA Section 3(38) advisory services NOT included in competitor basic pricing and usually NOT
available from competitors.
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14. The Wellington Difference
Superior Investment Options and Selection
Personal 401(k) Account Management Services (Not just “Advice”.)
Unbiased Investment Advice - No “Revenue Sharing” !
Investment Services
Employer & Administrative Services
Employee Support Services
ERISA Section 3(38) Fiduciary Services
Low “ALL-IN” Plan Costs (All asset-based fees plus administrative costs)
Single Point of Contact and Simple to Administer
Flexibility in Plan Design and No-Cost “Brokerage-Window”{ Accounts
Direct Access to “Live” and Highly Qualified Representatives at Both Wellington &
Charles Schwab & Co.
Perfect401(k)™
Current/
Competitor’s
Program
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15. Contact Us
Perfect401(k)™
14325 Willard Rd. Ste. 104
Chantilly, VA 20151
info@perfect401k.com
(800) 203-2670 ext.3338
www.perfect401k.com
Plan Provider Summary
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Editor's Notes
Plan Sponsor “Hot Line” from 9:00AM – 8:00 PM EST
Plan provider Organizations act as differing levels of “fiduciaries” to the plan.
Fiduciary services are “Cumulative”.
Plan provider Personnel act with differing levels of “fiduciaries” responsibility to you and your plan participants.
Brokers have only a “Suitability” standard of Care
Congress and regulatory authorities are addressing this confusing but important issue. They are considering requiring broker to adhere to the higher fiduciary standard of care – which the brokerage industry is fighting tooth and nail.
Credentials and Experience count too!
Wellington Services:
“Core” Advisory Services
ERISA Section 3(38) Fiduciary Services for the Plan Sponsor
Basic Advisory Services for all plan participants (and company employees)
“Optional: Advisory Services
Order execution and account rebalancing for participants selecting Customized Portfolios
Fully discretionary account management for participants selecting Fully Managed “Targeted Retirement” Portfolios
“Wellington’s Services = Fiduciary Protection for You as the Plan Sponsor - Plus Customizable and Continuous Investment Assistance for your Plan Participants” .
“Low Administrative Costs with No Hidden Fees” has become increasingly important as participant class-action lawsuit attack plan sponsors using high-cost funds with built-in Revenue-Sharing expenses.
In Tussey v. ABB, Inc.
Judgment required paying a combined $36.9 million in damages for breaching their fiduciary duty to ABB's 401(k) retirement savings plan.
The judge also found that classes of investments with higher expenses were selected for the plan and that the record-keeper was paid for plan services at rates higher than market rates in order to subsidize ABB's other corporate services.
he court also found that ABB failed to monitor record-keeping costs and negotiate rebates, and that the 401(k) plan fiduciaries failed to meet the requirements of the Employee Retirement Income Security Act of 1974 (ERISA) for investigating and determining "reasonableness."
In Tussey v. ABB, the judge found that the defendants, before entering into the revenue-sharing arrangement, did not prudently investigate the market pricing for similar record-keeping services, nor benchmark the cost of record-keeping fees.
Revenue sharing was not found to be a fiduciary violation by itself. Nevertheless, it is clear that if a plan sponsor adopts revenue sharing as its method of paying for record-keeping and administrative services, it must also develop a prudent process for determining why the plan's revenue-sharing arrangements are reasonable and solely in the interest of the plan participants.
Other fiduciary failures included selecting and retaining more costly classes of investments for the plans when less-expensive classes of the same investments were available.
Fidelity Lawsuit
Other Excessive Fee Lawsuits:
In 2011, for example, Wells Fargo (WFC) agreed to pay $17.5 million to settle a class action lawsuit that alleged it had engaged in self-dealing when choosing investments for its 401(k) plan.
In the same year, Wal-Mart (WMT) and Merrill Lynch settled a multimillion dollar lawsuit that alleged the Wal-Mart 401(k) plan had subjected its workers to excessively high fees.