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Everything posted by mhc

  1. The school district where my spouse is employed has entered into an agreement with Gallagher Benefit Service. GBS has reviewed the district's plan document for compliance, etc. and will be acting as the TPA for the district's 403b plan. Having accessed some information regarding this company and their affiliates through the FINRA and SEC websites, I am not certain as to how to interpret and evaluate the information provided. What other pertinent information is available that will allow for an informed determination as to the integrity of GBS? Thank you, mhc
  2. mhc

    Plan Doc Language

    Tom, Thank you for your information. As I understand it then, the bottom line is: -I cannot leave the SD 403b plan unless I experience an event (separation from employment, 59 1/2, etc.). (Were this to occur I could "rollover" out of the plan to an IRA). -That leaves 3 options: 1. transfer to a plan approved vendor and continue to contribute, 2. transfer to a plan approved vendor and stop contributions, or 3. leave the funds where they are with an unapproved vendor and make no contributions. -If I choose to leave the funds where they are, I may be able to affect a transfer to an unapproved vendor if, for example, your "model" language were adopted by the SD and included in the plan document. Under this arrangement I would not be allowed to make contributions. Would this mitigate the expenses I anticipate? The plan document is in draft form, is part of a public record, and can be accessed at: http://www.billingsschools.org/staff-resources.htm mhc
  3. mhc

    Plan Doc Language

    Thank you for your response. The "hoops" part of your note has my interest. Can you explain? Is there language that could be included in the plan document that would allow current participants to get out of the system without penalty? The plan document here has not yet been approved by the board. It is a Draft Plan Document. There is a public Q&A scheduled for this week regarding that draft plan document. I do not know if the SD has signed a contract with GBS.
  4. mhc

    Plan Doc Language

    Mr. fishermh, Thank you for your response. Unfortunately TRP will not be one of the approved vendors in this plan. If my money must remain in the plan until I experience a distributable event and I choose not to select a vendor in the menu of options and I stop contributions (which I have done), what options remain? My concern is that my account will somehow be swept up in this scheme. It occurs to me that there is the possibility that the vendor(s) selected by the SD may offer TRP and that I will somehow be forced to be an active participant whether I want to or not. If a TPA and the vendor(s) offered insinuate themselves between me and my money, will I still be required to pay the anticipated (and higher) fees associated with this SD plan even if I do not make any contributions? Is this a ligitimate concern? Additionally: A review of Gallagher's SEC filing states that "GBS will typically receives up to 95% of the advisory management fee paid by the client to NFP". That appears to be something of a conflict of interest. A review of NFP's FINRA filing shows several regulatory actions resulting in fines and censures. That appears to be a violation of fiduciary duty and trust. I am not especially well informed as to how to interpret these details. These items strike me as a cause for concern. Am I correct in this view? Thank you. mhc
  5. My school district has drafted a 403(b) plan document. That document is being evaluated by Gallagher Benefit Service. I have reviewed GBS's S.E.C. filings. According to SEC Form ADV Schedule F "...GBS only acts as a solicitor for NFP...". That led me to an arrangement that GBS has with NFP Securities. That led me to NFP Securities. NFP's modus operandi is inconsistent with my standards for investment vehicles. Having been present at the SD's 403(b) committee meetings I am satisfied that this type of opaque, heavily expensed scheme will be the only option available to plan participants. With that as background, I have stopped contributions and do not anticipate participation in the SD's 403(b) plan. I would like to get out of this plan without triggering a taxable event or incurring a penalty, however, mindful of the issues attending ISA and HH Agreements this may not be an option. With this in mind, a committee member suggested to me that I provide the committee with the language necessary to affect this outcome. What can be suggested in this regard? Does IRS Bulletin 2002-2 I.R.B. (Safe Harbor Explanation) have any bearing on this circumstance? mhc
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