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My name is Bill Kosinski and I am a Vice President at NEBSonline.com. We are now assisting over 40 districts throughout the state of California with Retirement Application Services including Common Remitter, Compliance and Employee Education.

 

Our ultimate goal is to empower employees become more educated regarding their 403(b) choices by providing a tool that assists with centralizing and comparing district approved providers, assist in making changes to your past contributions and many other features.

 

My goal with this post is to find out what Californian's think about the services provided by NEBSonline.

 

I came to this company to help educators like myself. I wanted to help make a differance in your futures by giving you something you never had before, the ability to truely self direct your retirement plan. I believe that NEBSonline has the best solution, but I need feedback from you.

 

Please post your thoughts about NEBSonline, it's services and any suggestions that you may have.

 

Sincerely,

 

Bill Kosinski

Vice President District Sales

NEBS, Inc.

wkosinski@nebsonline.com

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I have some questions, the answers to which may help others in providing the feedback you requested:

 

1. Is Nationa Employee Benefit Services, Inc. licensed as an adminstrator with the California Department of Insurance?

 

2. In addition to the adminstrative services you describe, do you offer other financial services and/or products?

 

3. What is your relationship with the product providers in the districts in which you work?

 

4. How are your fees paid? By the district, employees, product providers, or a combination thereof?

 

Thanks, Bill, for providing this additional information.

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Michael and Ted,

It's been several days now and I guess Bill is not very enthusiastic about answering our questions. It can't be because we asked about FEES...Naw!! I don't believe it.....

Steve

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Guest Joel

My name is Bill Kosinski and I am a Vice President at NEBSonline.com. We are now assisting over 40 districts throughout the state of California with Retirement Application Services including Common Remitter, Compliance and Employee Education.

+++++++++++++++++++++++++++++++++++++++++++++++++++

 

Bill,

 

Are not "Retirement Application Services" provided by the public agency known as the CalTRS? Do they not perform their legal duties adequately? What exactly do you do? Do you sit down with a soon to be retiree and help him/her complete the retirement application properly? and then help the school district remit same to CalTRS? And all of this is in compliance...compliance with what?... I assume it is to assure that the rules and regs as promulgated by the Board of Trustees of CalTRS are followed so that the retirement papers will not be returned.

So let me get this right a tax supported public school system hires you for a fee to assure that they are in compliance with the rules and regs of another tax supported agency...the CalTRS. Great work if you can get it.

 

Now let's turn our attention to "employee education". Please describe in detail exactly what you do to "educate" employees? What areas does this cover? Place/area to live? Health and emotional wellbeing? Legal documents like a will, health care proxy, durable power of attorney and last but surely not least do you "educate" the newly retired on their retirement investments? JUST WHAT DO YOU DO?

 

Peace,

Joel

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Guest Guest_billnebs@cox.net
I have some questions, the answers to which may help others in providing the feedback you requested:

 

1. Is National Employee Benefit Services, Inc. licensed as an administrator with the California Department of Insurance?

 

2. In addition to the administrative services you describe, do you offer other financial services and/or products?

 

3. What is your relationship with the product providers in the districts in which you work?

 

4. How are your fees paid? By the district, employees, product providers, or a combination thereof?

 

Thanks, Bill, for providing this additional information.

 

 

*********

 

Sorry for the delay folks, I am on the road this week and have just had a chance to check the post. You are too funny Steve!! The Righteous fear nothing!!

 

OK,

 

1. We are fully licensed to provide our services in the state of California. NEBSonline is fully bonded, covered by errors and omissions insurance and overseen by the SEC and NASD.

 

2. In addition to the administrative services, NEBSonline offers the NEBSonline system to all employees at districts we are contracted in.

 

When we first brought this system to industry, we believed that employees would love the fact that they don't have to speak with sales reps to self direct their retirement plan. As we worked with more and more districts it became prevalent that there was a need to give financial guidance as well. This is why we have Retirement Investment Counselors (RIC) on staff. These individuals are employed by NEBS and trained on the NEBSonline system to assist employees in understanding their options, comparing their choices based on risk and expenses and help the employee find the best choice(s) based on their goals and what is available at the district. NEBSonline is not a provider, but has the ability through our broker dealer relationship to give financial guidance and represent employees to approved providers.

 

Why did we do this? As we began to show employees the benefits of the districts 403(b) plans through educational workshops and notices we found that there were a number of people that needed more guidance. There were some people that were signed up for the plan then "orphaned" by their reps. The reps either quit, changed jobs or just moved on with their career. In either event we were getting calls by the hundreds from people saying that they liked the system, but wanted someone that they could talk with, someone they could see and touch. Thus the Retirement Investment Counselor (RIC) Division was born.

 

We do not call or contact people at home, the employees must make first contact with NEBS in order to gain access to the RIC Counselor. Our goal is to provide a complete solution for retirement benefits for 501©3 organizations. To give you an even playing field with those employees in the 401(k) industry.

 

3. Our relationship with the product providers is that we remit the funds on behalf of the district to the providers. We do this within 24 hours of the districts approval of the remittance report, and in some cases same day ACH (depending on when the approval occurs). One of the problems we found occurring in the industry was that employees deferrals would take up to 4 weeks to reach their accounts. This is money that is in transit via snail mail, or warrants sitting in bank accounts waiting to clear.

 

With NEBSonline, the district goes through a simple process by which they approve a remittance report through a secure administrative login. Once approved we will ACH the deferrals (presuming that the funds are in house) to those providers. This reduces the amount of time it takes the providers to receive the funds, thus reducing the amount of time it takes to reach the account. Also, because the funds are sent electronically, we have the ability to track the payments and let any employee know when the funds were sent, received and cleared. Electronic funds are considered cash as well so there is no wait time for a check to clear!

 

We are also a broker/dealer, so any employee that selects NEBSonline as their agent also is saying that any load associated with their investment choice will be forwarded to NEBS. Again, this is a opt-into selection by the employee. No Pressure!!

 

4. The district is giving their employees access to the NEBSonline system. If they so choose, they may utilize this award winning system to evaluate their options, make changes to their past contributions, learn about risk and much more. There is no requirement that an employee use the NEBSonline system to gain access to the districts 403(b) plan and get the same advantages of MAC calculations, IRS Compliance services and common remitter services employees using the system receive. It's just about giving the employees more choices for education, more choices for understanding and better administrative service.

 

So how are we paid:

 

1. $35.00 per year to access the NEBSonline systems

and tools.

 

2. $35.00 per year to access the No-load/low load

platform (where available)

 

3. Free access to the NEBSonline system/RIC

services by electing NEBSonline as the

agent/Broker/Dealer.

The providers will pay NEBS any load associated

with the product(s) the employee chooses. There

are no additional fees or charges added to these

transactions by NEBSonline or the provider.

 

4. ... or we don't get paid, no one goes to the

NEBSonline system or RIC services, everyone still

gets their deferrals ACH'd everyone can still go to

payroll and get their SRA processed. The

NEBSonline system is seamless. We will take all

the risk. It is our hope that employees embrace

this system as we have seen in districts across

the country. But there is no requirement that

any of them do so. Pretty good deal don't you

think?

 

Well, if you have any other questions please let me know. I hope this post helps you better understand our mission, to empower employees to make better decision about their retirement investments.

 

Sincerely,

 

Bill Kosinski

NEBSonline, Inc.

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Bill,

 

Are not "Retirement Application Services" provided by the public agency known as the CalTRS? Do they not perform their legal duties adequately? What exactly do you do? Do you sit down with a soon to be retiree and help him/her complete the retirement application properly? and then help the school district remit same to CalTRS? And all of this is in compliance...compliance with what?... I assume it is to assure that the rules and regs as promulgated by the Board of Trustees of CalTRS are followed so that the retirement papers will not be returned.

So let me get this right a tax supported public school system hires you for a fee to assure that they are in compliance with the rules and regs of another tax supported agency...the CalTRS. Great work if you can get it.

 

Now let's turn our attention to "employee education". Please describe in detail exactly what you do to "educate" employees? What areas does this cover? Place/area to live? Health and emotional wellbeing? Legal documents like a will, health care proxy, durable power of attorney and last but surely not least do you "educate" the newly retired on their retirement investments? JUST WHAT DO YOU DO?

 

Peace,

Joel

Joel,

 

The services that NEBSonline provides is regarding 403(b) not CalSTRS benefits.

 

As far as compliance, the IRS requires that the employer not allow any deferrals in excess of the Maximum Allowable Contribution Limits (MAC Calculations). This includes 402(g) and 415© limits based on IRS Publication 571. It also requires that the employer take into consideration catch up elections such as 15 years of service and over the age of 50 catch up elections. We help the employer by provided this information on all employees. We certify these calculations and back them with an indemnification clause.

 

There are many other compliance procedures that we provide for the employers we deal with, including Universal Notification (Also known as 403(b)12(ii)), employee education, workshops and unbiased guidance.

 

Please review my previous post for the rest of your questions. If you still need further details, please let me know.

 

Bill

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Guest Joel

Bill,

 

Thank you for clarfying your business plan. The 40 school districts that have made the fiduciary decision to farm out these administrative duties to you rather than to do it in house proves to me that section 403(b) of the Code is in need of fundamental revision. There is no sound benefit to the participant to maintain the status quo. The Congressional revision of section 403(b) to basically mirror the 457(b)/401(k) may very well be a threat to your business plan.

 

Do you strongly assert to your school district clients that insofar as you will provide the important investor guidance/education that there is absolutely no reason to offer high cost 403b investment choices? And if the school district decides to offer load and no-load products you will not take them on as a client. I believe this principle is an important ethical rule to be followed by a firm like yours. In my view if you have not adopted this policy then your hands are not clean. How would you respond to a teacher who attends an education seminar conducted by you when he reminds you that one carrier on the list provides the same type of investment at 50 basis points (one half of one percent) while another carrier charges 200 basis points or 2 percent.

 

I look forward to your timely reply.

 

Peace and Hope,

Joel

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Bill,

 

Thank you for clarfying your business plan. The 40 school districts that have made the fiduciary decision to farm out these administrative duties to you rather than to do it in house proves to me that section 403(b) of the Code is in need of fundamental revision. There is no sound benefit to the participant to maintain the status quo. The Congressional revision of section 403(b) to basically mirror the 457(b)/401(k) may very well be a threat to your business plan.

 

Do you strongly assert to your school district clients that insofar as you will provide the important investor guidance/education that there is absolutely no reason to offer high cost 403b investment choices? And if the school district decides to offer load and no-load products you will not take them on as a client. I believe this principle is an important ethical rule to be followed by a firm like yours. In my view if you have not adopted this policy then your hands are not clean. How would you respond to a teacher who attends an education seminar conducted by you when he reminds you that one carrier on the list provides the same type of investment at 50 basis points (one half of one percent) while another carrier charges 200 basis points or 2 percent.

 

I look forward to your timely reply.

 

Peace and Hope,

Joel

Hi Joel,

 

Thank you for your response. One of the biggest misconseptions is that the district actually makes the decisions as to what providers get on the list. The truth of the matter is that they have only limited control over what products are offered. They can require a minimum participation or Hold Harmless agreement to be signed, but if an employee wishes to add a vendor and meets the requirements, there is nothing the employer can do put follow the employees decision. What NEBSonline does is give you the ability to find out what expenses are there so that you can choose the product with low costs over the alternative

 

The Districts are not allowed to say that one product is bad and one is good. Nor can they qualify what is "high Expense" otherwise they could be found to be out of compliance as they are not allowed to give financial guidance. Only an agent, broker/dealer or certified professional can do that.

 

As far as the districts making a fiduciary decision to farm out these administrative duties. It is their responsibilty to meet the IRS and California State regulations with regards to compliance and plan administration. If there is an organization that does not show bias to a specific product and can perform these services in a timely manner, for the benefit of the employees, then it is not a fiduciary decision. The IRS allows for this type of service to be performed without transferance of this liability. (so long as the organization providing the services meets standards set by the SEC and NASD).

 

 

I wish that there was a way to eliminate high cost products all together, but with the law written as it is today, it's up to the participants to make the tough decisions. Neither the District nor NEBS can do that for you.

 

b

 

 

 

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Guest Joel

Hi Joel,

 

Thank you for your response. One of the biggest misconseptions is that the district actually makes the decisions as to what providers get on the list. The truth of the matter is that they have only limited control over what products are offered. They can require a minimum participation or Hold Harmless agreement to be signed, but if an employee wishes to add a vendor and meets the requirements, there is nothing the employer can do put follow the employees decision. What NEBSonline does is give you the ability to find out what expenses are there so that you can choose the product with low costs over the alternative.

--------------------------------------------------------------------------------------------------

Bill: Are you saying that the thousands of employers public and private that have used TIAA-CREF exclusively for decades are in violation of some rule when they tell a participant that they will not use loaded products? Permitting every tom and harry to be on the approved list is the very reason for this website and the primary reason why the 403b is in such a mess. Such a mess, however, is in your company's best interests...the longer the approved list the more work you have which translates into a larger of fees. The bigger the mess the more you like it. So it is in your best interests to advise your school district clients that they must give an employee the product provider requested. The client could care less because they cut a single check in your favor and you charge them for being the remitter.

 

I assume the rule you refer to applies only to California school districts. Please clarify. If this is in fact California law it is bad law and I suspect that some headsup district will challenge the employee to go to court where in my opinion it will be overturned. Here is yet another reason for the replacement of 403(b) with 457(b).

 

Peace,

Joel

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Hi Joel,

 

Thank you for your response. One of the biggest misconseptions is that the district actually makes the decisions as to what providers get on the list. The truth of the matter is that they have only limited control over what products are offered. They can require a minimum participation or Hold Harmless agreement to be signed, but if an employee wishes to add a vendor and meets the requirements, there is nothing the employer can do put follow the employees decision. What NEBSonline does is give you the ability to find out what expenses are there so that you can choose the product with low costs over the alternative.

--------------------------------------------------------------------------------------------------

Bill: Are you saying that the thousands of employers public and private that have used TIAA-CREF exclusively for decades are in violation of some rule when they tell a participant that they will not use loaded products? Permitting every tom and harry to be on the approved list is the very reason for this website and the primary reason why the 403b is in such a mess. Such a mess, however, is in your company's best interests...the longer the approved list the more work you have which translates into a larger of fees. The bigger the mess the more you like it. So it is in your best interests to advise your school district clients that they must give an employee the product provider requested. The client could care less because they cut a single check in your favor and you charge them for being the remitter.

 

I assume the rule you refer to applies only to California school districts. Please clarify. If this is in fact California law it is bad law and I suspect that some headsup district will challenge the employee to go to court where in my opinion it will be overturned. Here is yet another reason for the replacement of 403(b) with 457(b).

 

Peace,

Joel

Hi Joel,

 

There are some differences in regards to law and fiduciary responsibility for public and private companies. A 501©3 organization such as a district, county office of education or college that supplies a 403(b) plan for their employees is not allowed to provide financial advice. They are not a fiduciary, as the IRS considers the 403(b) a "self directed" retirement plan. This means that the employee directs which investment to defer too, fills out a "Salary Reduction Agreement" asking the district to reduce your salary and tax-defer a payment to said investment. By only offering one choice, the district would be saying that they "endorse" this provider, taking on a fiduciary liability. This is not allowed under publication 571. Now if an employer decided to only offer a 457 plan or some type of alternative with fiduciary responsibility, then they can limit the products available.

 

As far as NEBS liking that there are more providers, you are somewhat correct. We believe that employees have different goals with regards to their retirement deferral capabilities. For instance an employee with a spouse also bringing an income to the household with no children will have different goals, be more aggressive and have more to defer than an employee with no spouse and 3 children. It's in the best interest of the employee to have more options. It's about the quality of the product, the costs and fees associated with them and their ability to produce the goals stated in their prospectus. It's about being able to learn about the differences between the products available to you and taking advantage of the ones that meet your requirements.

 

When I think about the people that I have talked too who decided on choosing their investments by looking at the top of the provider list at the district and picking the first one just because they don't have time to research their options, it makes me sick! I want to see a day when we are bragging because we are more knowledgeable about the options we choose and the performance that it has provided. I hope, with the help of sites like this, that day will be soon.

 

The law AB2506 I am refering to is for California, however similar laws have been implemented in other states.

 

Bill

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Guest Joel

There are some differences in regards to law and fiduciary responsibility for public and private companies. A 501©3 organization such as a district, county office of education or college that supplies a 403(b) plan for their employees is not allowed to provide financial advice. They are not a fiduciary, as the IRS considers the 403(b) a "self directed" retirement plan. This means that the employee directs which investment to defer too, fills out a "Salary Reduction Agreement" asking the district to reduce your salary and tax-defer a payment to said investment. By only offering one choice, the district would be saying that they "endorse" this provider, taking on a fiduciary liability. This is not allowed under publication 571. Now if an employer decided to only offer a 457 plan or some type of alternative with fiduciary responsibility, then they can limit the products available.

------------------------------------------------------------------------------------------------

501©3 organizations were authorized to offer 403bs in 1958. Section 23 of PL 85-866. Public educational insitutions including colleges and universities were authorized in 1961. Section 3 of PL 87-370.

 

Bill,

 

You need to do some elementary research as far as what types of employers are permitted to sponsor 403bs. STOP WINGING IT!

 

I believe you make the same marketing presentation to unsuspecting school districts and other tax supported educational entities. Check with counsel. He or she will tell you that public school districts and county and state departments of education are not 501©3 organizations. Hasn't a local school board official corrected you on dispensing this misinformation? An example of a 501©3 organization is a private non-profit foundation. You can also check with Publ. 571.

 

Guys like you really muddy the waters because you go into business and by so doing the unsuspecting trust that you know the law. Your behavior is particularly unethical because you use the complexity of the law to grow your business. Is this how you build your book of business by telling a school district official that the district is a 501© 3 entity and, therefore, you can be sued if you limit investment choices? On the contrary it is you AND YOUR NEBSONLINE that is legally culpable by telling school district officials that school districts are 501©3 organizations. You better get some very high professional liability insurance...or is it called "errors and omissions"

 

Now let's get real. I challenge you to give us the law/rule where it says that a 403b employer anywhere in this great land of ours may not furnish investment advice/guidance/or couseling and because it is forbidden from doing same must offer any 403b investment to any employee that requests it. Stop winging it ...you are being watched by professionals who know much, much more than I do about this complex section of the Code.

 

Additionally I challenge you tell us the page in Publ. 571 where it states that an employer may not offer just one investment option or provider?

 

And last but not least your evasion of Michael's questions has not gone unnoticed. You are apparently ashamed of how you make a living otherwise you would have been much more responsive. Tell me, are you a Broker Dealer so you can advocate no-load funds? Give us a break!!

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Hi Joel,

 

Thank you for your response. One of the biggest misconseptions is that the district actually makes the decisions as to what providers get on the list. The truth of the matter is that they have only limited control over what products are offered. They can require a minimum participation or Hold Harmless agreement to be signed, but if an employee wishes to add a vendor and meets the requirements, there is nothing the employer can do put follow the employees decision. What NEBSonline does is give you the ability to find out what expenses are there so that you can choose the product with low costs over the alternative.

--------------------------------------------------------------------------------------------------

Bill: Are you saying that the thousands of employers public and private that have used TIAA-CREF exclusively for decades are in violation of some rule when they tell a participant that they will not use loaded products? Permitting every tom and harry to be on the approved list is the very reason for this website and the primary reason why the 403b is in such a mess. Such a mess, however, is in your company's best interests...the longer the approved list the more work you have which translates into a larger of fees. The bigger the mess the more you like it. So it is in your best interests to advise your school district clients that they must give an employee the product provider requested. The client could care less because they cut a single check in your favor and you charge them for being the remitter.

 

I assume the rule you refer to applies only to California school districts. Please clarify. If this is in fact California law it is bad law and I suspect that some headsup district will challenge the employee to go to court where in my opinion it will be overturned. Here is yet another reason for the replacement of 403(b) with 457(b).

 

Peace,

Joel

Joel,

 

I appreciate your candor and passion regarding these issues. I too feel the same way you do regarding companies that are trying to take advantage of employees by misleading and misguiding them to bad investment choices.

 

When I stated the prior information, I did make a typo, it was meant to say 501©3 organizations AND school districts, COEs, etc.... I apologize for this mistake and admit it openly.

 

I will find the information that you have "challenged" me to find for you. Please don't take this thread as a personal attack on you Joel. I am merely trying to get a feel for what people think about the NEBSonline website, it's ability to help manage self directed retirement plans and if it's useful to employees.

 

You are right Joel, there are a lot of people that are viewing this post that are much more knowledgeable than you or I, but isn't that the reason we post? I want to know more about the views of these experts out there. I want to know your views and concepts. I was a teacher before I moved careers to this industry. I was taken advantage of by a sales agent with only their commissions in mind. This is why I am so passionate about what I do. I don't want to see anyone have the negative experience that I had when looking into investing.

 

I hope that we all can have a healthy and wealthy retirement, all I am saying is that it is important that the individual must become more effective in choosing their investments.

 

I will reply soon with the information you requested.

 

Peace,

 

Bill

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Guest Joel

Bill,

 

Rather than spend your time with your self serving bs response to me why didn't you use the same time to give us the "rule" you say exists?

 

How can I possibly take your posts as a personal attack on me. It was you not I that has initiated this thread. So far, I am of the opinion that you are simply using the 403b apparatus to invent work for you and your employer that really does not exist.

 

Your purposeful unresponsiveness is simply the nature of the beast. Are you also going to get back to us about being a Broker Dealer and how such a license lends itself to you being impartial when you give your "investment advice"seminars.

 

You as a "VP" should not have to get back to me about the "rule" that says 403b employers may not offer just one family of funds or a limited number of funds because that means the employer is giving its endorsement of investing in those funds and thereby opening itself up to fiduciary liability. So the rule, you assert, requires the employer to offer any and all funds that any and all employees request. The rule, according to you, also says that the 403b employer may not provide investment education/advice/counseling. Only, according to this rule, for-profit companies may furnish investment education/advice/counseling.

 

C'mon Bill this is the line you give in all your presentations and logic dictates you would have the "rule" at your finger tips. What do you do when a member of a board of education asks you to cite the rule...do you simply say "I'll get back to you"?... when sealing the deal depends on you producing the "rule". Is this the level of preparation you exert prior to your presentation?

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