1. FIDUCIARY RESPONSIBILITY
Many actions involved in operating an ERISA* governed tax qualified plan make the person or entity
performing them a fiduciary. Fiduciary status is based on the functions performed for the plan, not just a
person’s title.
Fiduciaries have important responsibilities and are subject to fiduciary standards of conduct because
they act upon behalf of participants in a retirement plan and their beneficiaries.
Fiduciary responsibilities include:
 Acting solely in the interest of plan participants and their beneficiaries; for the exclusive purpose of
providing their retirement benefits
 Carrying out fiduciary duties prudently;
 Following the plan documents;
 Diversifying plan investments; and
 Paying reasonable plan expenses.
The duty to act prudently is one of the fiduciary’s central responsibilities under ERISA. It requires
expertise in a variety of areas, such as investments.
With these fiduciary responsibilities there is also potential liability. One way fiduciaries demonstrate the
execution of their responsibilities is by documenting the processes used to carry out their fiduciary
responsibilities.
ERISA §3(38) – INVESTMENT MANAGEMENT
Once Bell Rock Capital, LLC is appointed by the plan sponsor or trustee of an ERISA governed tax
qualified plan, we accept discretion and assume full responsibility and liability for the fiduciary functions
concerning decisions related to the plan’s assets. As a E R I S A § 3(38) plan fiduciary, we have the
responsibility and authority to select the investment options for the plan and deciding if and when to
make necessary and prudent changes to the plan’s investments.
If selected as an ERISA § 3(38) fiduciary adviser, our services are as follows:
 Bell Rock shall be responsible for the selection of plan’s investments.
 Bell Rock shall have discretionary authority to determine the core investment options and qualified
default investment alternatives under the plan; and
 Bell Rock provides asset allocation portfolios to participants reflecting a range of risk and potential
return characteristics. These portfolios are updated by Bell Rock on a discretionary basis.
*Employee Retirement Income Security Act of 1974 as amended.
561.289.5308
www.BellRockCapital.com
Jackie@BellRockCapital.com
DELAWARE, FLORIDA, PENNSYLVANIA

2. About BELL ROCK CAPITAL, LLC
Bell Rock Capital, LLC is an SEC Registered Investment Advisor, with offices in Delaware and Florida. Our
401(K) Advisory Services include the role of acting as a financial advisor on the Company plan including
providing investment selection, monitoring and education of the plan's investment selections. We utilize
proprietary research as well as technology-driven investment tools to manage our accounts and conduct
fundamental and technical analysis on the companies we consider before investing. Our mission is to deliver
returns consistent with client goals.
Cassandra Toroian - President and Chief Investment Officer. Prior to launching the firm, she was a
founder of Cohen Bros. & Co., as well as the Managing Director of CBT Investment Management Inc., an
SEC Registered Investment Advisor, from 2001 until 2005. Ms. Toroian began her career as a buy-side
analyst at a Pennsylvania-based mutual fund company. Subsequently, she was a sell-side analyst for the
banking sector. Ms. Toroian was named one of the top five analysts in the country as a Wall Street Journal
“All Star” Analyst for her stock picking in the bank sector in 1999. It is this knowledge of the banking
sector which has made Ms. Toroian a frequently used resource about banks by national media, including
CNBC, Bloomberg Television, The Wall Street Journal, and various other printed media including The
Philadelphia Inquirer and Bulletin, Boston Globe and TheStreet.com.
Jacqueline Reeves - Managing Director of Bell Rock Capital, LLC. She heads the firm’s research and
portfolio strategy group. Prior to joining Bell Rock Capital, Ms. Reeves was Managing Director at Ryan
Beck & Co., leading the financial institutions research effort. She was responsible for a research team with
more than a hundred companies under coverage with market capitalizations ranging from $20 million to $30
billion. Her coverage universe has included regional commercial banks, trust companies, and Florida
community banks and thrifts. Prior to 2003, Ms. Reeves was Director of Research at Putnam Lovell NBF
as well as a senior publishing analyst. She has also been part of the highly regarded bank equity research
team at Salomon Smith Barney and Credit Suisse First Boston, which received high rankings from
Institutional Investor and Greenwich polls. She also has held positions as an equity analyst for both Janney
Montgomery Scott and Rothschild N.M. Ms. Reeves is a frequently used resource about banks by national
media, including CNBC, Bloomberg television and radio, The Wall Street Journal, Business Week and
various other printed media.
Jacquelyn Blue - Managing Director of Bell Rock Capital, LLC. Prior to joining Bell Rock Capital, Ms.
Blue was Director of Balance Sheet Strategies at Ryan Beck & Co., serving the middle-market banking
sector with balance sheet and risk management strategies through the use of hedging techniques, wholesale
borrowing initiatives and capital management plans. Before joining Ryan Beck, Ms. Blue held similar
positions at Janney Montgomery Scott and Milestone Partners. For the 16 years through 1999, Ms. Blue was
a senior officer at Sovereign Bank, most recently as Treasurer and Chief Investment Officer, where she
managed the $10 billion investment portfolio, as well as the derivatives and wholesale borrowing portfolios
of the institution. She was part of the team that raised $1.8 billion in capital to purchase over 300 branches
divested from the Fleet/Bank Boston merger, the largest branch divestiture in the history of banking.
During her tenure at Sovereign she was part of the team responsible for completing over 21 acquisitions of
financial service businesses. Ms. Blue is a frequent speaker by bank and thrift trade associations.