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We offer two options with Vanguard. The first is an option where there is only a $35 custodial fee per year and you are limited to being just in Vanguard funds. There is no investment advice provided and you have to view your Vanguard funds on our website. The rep for your district will not bother you or contact you after you have enrolled. The second method on our platform is our fee based account that does charge .9% per year and a $35 annual custodial platform. People can continue to use Vanguard here but now are not stuck in a box and can use 52 other, mutual fund families all with no sales loads and full liquidity at all times. I can't tell you how many Vanguard and Fidelity participants have gone this direction after seeing the magnitude of this platform. We run a portfolio analysis on their current portfolio and do a custom portfolio with reducing beta (risk) and increasing alpha (return) using 53 mutual fund families as well as some Vanguard funds. Please remember that not one mutual fund family out there has the best performing fund in each investment class. People have been decimated by the market and now see they may need some help. Then there are those who still want to do it on their own and we provide them with that option as well. We now have Janus funds on our fee based platform. The thing that we look at the most is alpha and beta. The risk you take for the return you get is what is most crucial. We like to help people reduce beta and increase alpha net of fees! I mean if you think about the low fees you pay with no help and you lose 40% of your value where is the benefit of the low fees? The majority of Vanguard participants we have seen use only one or two funds with no diversification. Happy New Year!

 

 

 

I disagree with the premise that "not receiving help" cancels out the benefit of low fees. Especially this year. Everyone lost money (and a lot of it) this year - help or not. My wife got "help" from an ING rep, and her ING portfolio is down more than her Vanguard S&P 500 fund. She had previously received "help" from an American rep, and he advised that she should put her money in the Growth Fund of America (only). How is that any different that someone putting all their money in the S&P 500? The vast majority of research specifically shows that receiveing "help" - ie. being charged more money, leads to inferior returns over long periods of time.

 

Yes, asset allocation is critical. However, it is kind of misleading to insinuate that it is necessary to "provide" all sorts of higher fee fund families in order to get "diversification." You are certainly right to say that someone who puts all their marbles in the vanguard s&p 500 index is potentially playing with fire. However, no more so (and likely less) than someone who has all their money in Growth Fund of America. The TWO most crucial factors in long term investing success, and the ONLY two with broad, sweeping, academic support are low cost and asset allocation. Low cost index funds in the S&P, total Bond fund, International index and perhaps a money market acct. can provide virtually every ounce of diversification a person needs. All can be had for virtually no fee, and can be constructed to fit a person's situation.

 

Furthermore, if you lack the confidence/knowledge, you could simply invest in a Vanguard target date fund appropriate to your risk tolerace/age and do virtually the same. Or, simply use age -10 as the percent of bonds in portfolio. Either of these two SIMPLE options, at .2% fees will (with almost 100% certainty) out pace any similar portfolio constructed of higher fee funds over the course of 30 years.

 

The problem with "providing" people with this "diversification" is that it has been PROVEN over and over and over, that NO ONE can consistently pick FUTURE winners. In fact, a relatively consistent sign of a future loser, is being a past winner. Also, virtually NO funds can outpace the avg. market return consistently. Those VERY few that do cannot be identified in advance. So, people providing advice about which high priced funds to invest in over the course of a 30 year period are wrong, and they are wrong 99% of the time over the long haul. So, as of now, it has yet to be shown that getting "help" is of any help at all. In fact, getting "help" is more likely to lead to lower returns, not higher.

 

Even 1% difference in fees can lead to 10's of thousands of dollars - even 100+ thousand - in lost returns. That is an awful lot of money to pay someone for a service that has been academically PROVEN to not work.

 

People who sell fund advice are the same as car salesman. They are selling a product (and it is not advice) in order to make money. If I walk into a ford dealership and tell them that I need a car that gets the best possible gas mileage, has a tremendous warranty and has great resale value, they are not going to suggest I look at a toyota or a honda. They are going to sell me a ford, simple as that. That is not selling good advice, that is selling a product for a profit and commission.

 

People do not need access to 50 mutual fund families at a cost of $50,000 in fees over the course of a lifetime. What they need is someone to sit down with them for $75 for an hour, 1 time a year and help them look at the asset allocation they have in their .2% fee index funds and see if any changes should be made. But, that does not result in hefty long-term commissions, and, as is human nature, people would rather lose $10,000 in fees that they never see, than hand over a $100 dollar bill from their wallet.

 

Kev

 

Seeing that you compare us to car salesman there is no way I am going to convince you of anything with that perspective. I appreciate the insult! But in the big picture most of the people need someone to help them. If everyone were like you then there would be no financial representatives out there. While I respect the many on here who are actively doing there thing the reality is that the majority of people have no desire, time or background to do it.

 

 

 

CLJ...we are looking for low cost options to use the ROTH 403b option, which Vanguard does not offer even if the school district does offer the traditional 403b arrangement. We are very comfortable with making our own decisions on diversification. Since you're in the business, any suggestions concerning a ROTH option would be appreciated. Lincoln and several other firms with fees are other options offered by the district. Thank you.

 

It truly depends on if the district has the 403(b) Roth option available. I have been a little surprised at the lack of the 403(b) Roth being a part of a districts plan. If a district has a 403(b) Roth as a part of their plan we can offer Vanguard funds as one of the investment choices even though they will not. Our custodial platform is a true 403(b) custodial platform that also accommodates a 403(b) Roth. One other thing that our platform offers that Vanguard and some other fund families do not is a loan and financial hardship withdrawal. This really has to do with having your account on a true 403(b) custodial platform. Not that I suggest this to be the reason to use us but in the event of an emergency it’s available. Hope this helps!

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CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

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CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

 

I'd be glad to. It is actually quite simple. They do not have the systems in place to do the compliance component of everything vendors now have to do. First they would need to have an actual 403(b) custodial platform. They would need systems to keep track of the approved vendors in each district that they were a vendor in. I could go on and on but for the sake of time all of this would mean more costs and the investors would see an increase in fund expenses to cover the costs. Since their 403(b) business is a mere pittance to their overall business it was purely a business decision not to take on the responsibilities. Keep in mind that VG is not the only vendor to back away.

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... The first is an option where there is only a $35 custodial fee per year and you are limited to being just in Vanguard funds. There is no investment advice provided and you have to view your Vanguard funds on our website. The rep for your district will not bother you or contact you after you have enrolled.

...

I am in charge of Illinois and Wisconsin ....

 

 

Let me ask you then, CJ, because you seem to be in the know about buying and selling Vanguard funds when in a 403b custodial account with Lincoln. As far as I can tell, the process of moving funds is going to always involve filling out forms and contacting the agent, then waiting a couple of weeks for the process to execute. Lincoln still seems to be agent-centric.

 

 

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CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

 

I'd be glad to. It is actually quite simple. They do not have the systems in place to do the compliance component of everything vendors now have to do. First they would need to have an actual 403(b) custodial platform. They would need systems to keep track of the approved vendors in each district that they were a vendor in. I could go on and on but for the sake of time all of this would mean more costs and the investors would see an increase in fund expenses to cover the costs. Since their 403(b) business is a mere pittance to their overall business it was purely a business decision not to take on the responsibilities. Keep in mind that VG is not the only vendor to back away.

 

 

CLJ:

 

So what you are saying is that VG cannot/will not deal with individual SD to offer VG products because it is not equipped to perform all of the compliance services required under the IRS regs but will offer its products to wholesalers and vendors who can offer VG on their platforms which are capable of providing all of the services necessary to comply with the regs. The only other way VG can be offered is if a SD is willing to take on the role of administering the plan and will perform all of services necessary to comply with the IRS regulations and pay for the costs, such as hiring personnel who have the expertise to set up procedures to comply with the IRS regs on the SD systems.

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... The first is an option where there is only a $35 custodial fee per year and you are limited to being just in Vanguard funds. There is no investment advice provided and you have to view your Vanguard funds on our website. The rep for your district will not bother you or contact you after you have enrolled.

...

I am in charge of Illinois and Wisconsin ....

 

 

Let me ask you then, CJ, because you seem to be in the know about buying and selling Vanguard funds when in a 403b custodial account with Lincoln. As far as I can tell, the process of moving funds is going to always involve filling out forms and contacting the agent, then waiting a couple of weeks for the process to execute. Lincoln still seems to be agent-centric.

 

 

Johnny I hate to disappoint you but you will be able to make changes on your account via the website once it is up and running. Lincoln is creating a website specially for VG clients. In the meantime you will call the rep and speak to him/her and they will call in the trade that day. Our reps must phone in the trade immediately. No paperwork required. You do have a choice not to use Lincoln and do something different if what we have done to make Vanguard still available for you at low cost is not to your liking. It is America! Did you ask for the custodial account agreement? Did you receive it?

 

 

 

 

CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

 

I'd be glad to. It is actually quite simple. They do not have the systems in place to do the compliance component of everything vendors now have to do. First they would need to have an actual 403(b) custodial platform. They would need systems to keep track of the approved vendors in each district that they were a vendor in. I could go on and on but for the sake of time all of this would mean more costs and the investors would see an increase in fund expenses to cover the costs. Since their 403(b) business is a mere pittance to their overall business it was purely a business decision not to take on the responsibilities. Keep in mind that VG is not the only vendor to back away.

 

 

CLJ:

 

So what you are saying is that VG cannot/will not deal with individual SD to offer VG products because it is not equipped to perform all of the compliance services required under the IRS regs but will offer its products to wholesalers and vendors who can offer VG on their platforms which are capable of providing all of the services necessary to comply with the regs. The only other way VG can be offered is if a SD is willing to take on the role of administering the plan and will perform all of services necessary to comply with the IRS regulations and pay for the costs, such as hiring personnel who have the expertise to set up procedures to comply with the IRS regs on the SD systems.

 

Correct in the first half of your post. To correct the second half the district assumes the risk if they sign Vanguards agreement for Vanguard accounts. They also are inconsistent with their other vendors because they asked all of them to sign the district agreement. The district would not hire anyone for VG.

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... The first is an option where there is only a $35 custodial fee per year and you are limited to being just in Vanguard funds. There is no investment advice provided and you have to view your Vanguard funds on our website. The rep for your district will not bother you or contact you after you have enrolled.

...

I am in charge of Illinois and Wisconsin ....

 

 

Let me ask you then, CJ, because you seem to be in the know about buying and selling Vanguard funds when in a 403b custodial account with Lincoln. As far as I can tell, the process of moving funds is going to always involve filling out forms and contacting the agent, then waiting a couple of weeks for the process to execute. Lincoln still seems to be agent-centric.

 

 

Johnny I hate to disappoint you but you will be able to make changes on your account via the website once it is up and running. Lincoln is creating a website specially for VG clients. In the meantime you will call the rep and speak to him/her and they will call in the trade that day. Our reps must phone in the trade immediately. No paperwork required. You do have a choice not to use Lincoln and do something different if what we have done to make Vanguard still available for you at low cost is not to your liking. It is America! Did you ask for the custodial account agreement? Did you receive it?

 

 

 

 

CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

 

I'd be glad to. It is actually quite simple. They do not have the systems in place to do the compliance component of everything vendors now have to do. First they would need to have an actual 403(b) custodial platform. They would need systems to keep track of the approved vendors in each district that they were a vendor in. I could go on and on but for the sake of time all of this would mean more costs and the investors would see an increase in fund expenses to cover the costs. Since their 403(b) business is a mere pittance to their overall business it was purely a business decision not to take on the responsibilities. Keep in mind that VG is not the only vendor to back away.

 

 

CLJ:

 

So what you are saying is that VG cannot/will not deal with individual SD to offer VG products because it is not equipped to perform all of the compliance services required under the IRS regs but will offer its products to wholesalers and vendors who can offer VG on their platforms which are capable of providing all of the services necessary to comply with the regs. The only other way VG can be offered is if a SD is willing to take on the role of administering the plan and will perform all of services necessary to comply with the IRS regulations and pay for the costs, such as hiring personnel who have the expertise to set up procedures to comply with the IRS regs on the SD systems.

 

Correct in the first half of your post. To correct the second half the district assumes the risk if they sign Vanguards agreement for Vanguard accounts. They also are inconsistent with their other vendors because they asked all of them to sign the district agreement. The district would not hire anyone for VG.

 

 

How will the district comply with the IRS regs such as max limits, MRD, loans, universial availability, hardship distributions, 415 limits, etc if it does not hire persons with the requisite expertise since as you stated VG is not equipped to perform compliance services required under the IRS regs? As you yourself said the diistrict assumes the risk if they sign VGs agreement. How will compliance with the regs be achieved?

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Johnny I hate to disappoint you but you will be able to make changes on your account via the website once it is up and running. Lincoln is creating a website specially for VG clients. In the meantime you will call the rep and speak to him/her and they will call in the trade that day. Our reps must phone in the trade immediately. No paperwork required. You do have a choice not to use Lincoln and do something different if what we have done to make Vanguard still available for you at low cost is not to your liking. It is America! Did you ask for the custodial account agreement? Did you receive it?

 

 

 

CLJ,

I'm sorry if I seemed too critical. Thank you for hanging out here and being a source of information.

 

I did see a custodial agreement, the same one available on the website, which confirmed the $35 fee, but didn't give any details on procedures unique to this Vanguard arrangement. In fact, I haven't seen anything official-looking specifically mentioning the arrangement.

 

I certainly wasn't disappointed by your news. The current incarnation of the website doesn't offer anything like what you've promised and my hopes had sank after my first log-on.

 

Can you answer why this deal was only available to people already contributing to VG and isn't open to new investors?

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Johnny I hate to disappoint you but you will be able to make changes on your account via the website once it is up and running. Lincoln is creating a website specially for VG clients. In the meantime you will call the rep and speak to him/her and they will call in the trade that day. Our reps must phone in the trade immediately. No paperwork required. You do have a choice not to use Lincoln and do something different if what we have done to make Vanguard still available for you at low cost is not to your liking. It is America! Did you ask for the custodial account agreement? Did you receive it?

 

 

 

CLJ,

I'm sorry if I seemed too critical. Thank you for hanging out here and being a source of information.

 

I did see a custodial agreement, the same one available on the website, which confirmed the $35 fee, but didn't give any details on procedures unique to this Vanguard arrangement. In fact, I haven't seen anything official-looking specifically mentioning the arrangement.

 

I certainly wasn't disappointed by your news. The current incarnation of the website doesn't offer anything like what you've promised and my hopes had sank after my first log-on.

 

Can you answer why this deal was only available to people already contributing to VG and isn't open to new investors?

 

Johnny,

This whole arrangement was made recently. Keep in mind that Lincoln Investment is a small privately owned broker dealer. We are not the big guys for sure and we are a specialty firm that has focused in the 403(b) market for 40 years. It takes some time for these things to be developed. I can assure you that the website is being developed for you. In the past the main reason that we did not allow exchanges on the website is that a person may buy an "A" share of one fund family and then decide to move to a different fund family and have to pay sales charges all over again which is the main reason for rep involvement to protect our clients from this. Many mutual fund families have what's called short term trading fees. Vanguard is not absent from this for sure. This means that an investor must hold that fund for a period of time. If they move out of it prior to that date then the fund family can charge the short term trading fee. So in the best interests of the client the rep has always been involved to make sure that the client is aware of everything. It all gets back to service. In this new dawn of the 403(b) world we knew there was a need to help our employer clients to keep Vanguard available to their employees who have been using Vanguard. We were the first firm to step up and make Vanguard available for those wishing to continue to do it themselves. I am positive that other firms will follow suit. Patience is a virtue as you well know and it is in call here. I hope that we can be appreciated for our looking out for people which is truly our firm’s main objective. I am glad that you have the custodial account agreement. All of our fees are transparent and easily found in our material. When it says the fee is $35 a year that is exactly what it means.

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... The first is an option where there is only a $35 custodial fee per year and you are limited to being just in Vanguard funds. There is no investment advice provided and you have to view your Vanguard funds on our website. The rep for your district will not bother you or contact you after you have enrolled.

...

I am in charge of Illinois and Wisconsin ....

 

 

Let me ask you then, CJ, because you seem to be in the know about buying and selling Vanguard funds when in a 403b custodial account with Lincoln. As far as I can tell, the process of moving funds is going to always involve filling out forms and contacting the agent, then waiting a couple of weeks for the process to execute. Lincoln still seems to be agent-centric.

 

 

Johnny I hate to disappoint you but you will be able to make changes on your account via the website once it is up and running. Lincoln is creating a website specially for VG clients. In the meantime you will call the rep and speak to him/her and they will call in the trade that day. Our reps must phone in the trade immediately. No paperwork required. You do have a choice not to use Lincoln and do something different if what we have done to make Vanguard still available for you at low cost is not to your liking. It is America! Did you ask for the custodial account agreement? Did you receive it?

 

 

 

 

CLJ:

 

Perhaps you can explain to the audience the difference between VG agreeing to provide funds to a SD directly by agreeing to the terms of the SD plan and VG being offerrred through a wholsaler /vendor where VG is only an asset gatherer and the vendor assumes the responsibilities for compliance with the 403b regs. and compliance with the terms of the plan. I dont think the posters on this board understand the difference how the distribution channels affects the avialability of VG, for example the availably of VG to 300 PA SD through kades-margolis who is a 403b vendor.

 

I'd be glad to. It is actually quite simple. They do not have the systems in place to do the compliance component of everything vendors now have to do. First they would need to have an actual 403(b) custodial platform. They would need systems to keep track of the approved vendors in each district that they were a vendor in. I could go on and on but for the sake of time all of this would mean more costs and the investors would see an increase in fund expenses to cover the costs. Since their 403(b) business is a mere pittance to their overall business it was purely a business decision not to take on the responsibilities. Keep in mind that VG is not the only vendor to back away.

 

 

CLJ:

 

So what you are saying is that VG cannot/will not deal with individual SD to offer VG products because it is not equipped to perform all of the compliance services required under the IRS regs but will offer its products to wholesalers and vendors who can offer VG on their platforms which are capable of providing all of the services necessary to comply with the regs. The only other way VG can be offered is if a SD is willing to take on the role of administering the plan and will perform all of services necessary to comply with the IRS regulations and pay for the costs, such as hiring personnel who have the expertise to set up procedures to comply with the IRS regs on the SD systems.

 

Correct in the first half of your post. To correct the second half the district assumes the risk if they sign Vanguards agreement for Vanguard accounts. They also are inconsistent with their other vendors because they asked all of them to sign the district agreement. The district would not hire anyone for VG.

 

 

How will the district comply with the IRS regs such as max limits, MRD, loans, universial availability, hardship distributions, 415 limits, etc if it does not hire persons with the requisite expertise since as you stated VG is not equipped to perform compliance services required under the IRS regs? As you yourself said the diistrict assumes the risk if they sign VGs agreement. How will compliance with the regs be achieved?

 

Inruder,

 

I was stating that a district will not have to hire new employees. Most have gone the route of a TPA which covers their entire plan. I believe that the TPA still does all the work. If a district signs a vendor’s agreement from any vendor not just VG they assume the risk of that vendor which is why most school board attorneys have recommended not to sign a vendor’s agreement. In fact I believe that the TPA’s indemnification clause will be voided for that vendor. Why would a district risk that? I am not an attorney but this is what I have heard. If a vendor is serious about being in the 403(b) market place then they should be in full compliance to be able to handle the administrative duties now required. Keep in mind that insurance companies also exited the market too! If I were a school district I would realize that this is our districts plan and vendors should not dictate to me how to run my plan. If they want to be a part of it then they should sign on and do what is required.

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CLU:

 

As I understand it under the 403b regs VG can be offered as an option in one of four ways:

 

1. VG administers the plan for the employer to insure compliance with the regs and assumes responsibilty for errors.

 

2. VG signs an agreement that is acceptable to the TPA who will administer the plan in compliance with the regs. TPA will assume responsibility for errors.

 

3. VG can agree to be offered through a wholesaler/vendor who has the capability to provide information to the plan administrator necessary for the TPA to comply with the 403b rules and allows VG to avoid signing an agreement with the TPA. VG has no responsibility to insure compliance of the plan with the regs.

 

4. The SD/NP as the employer self adminsters the plan to make sure that the plan complies with the 403b plan regs. Employer has to hire personnel to make sure that plan is operated in accordance with the regs.

 

As you have indicated #1 is not available and as many posters have stated VG will not sign an agreement to participate in a 403b plan drafted by the TPA hired by the employer to administer plan (and to a lesser extent neither will Fidelity or T. Row Price) which eliminates #2. VG has signed some agreements in #3 which eliminates their risk under the plan (PA public schools through kades-margolis).

 

I agree with your analysis of the risk to the SD if it elects #4, however it has been reported that some SDs are willing to assume such risk if it is necessary to retain VG as an option under the 403b plan if 2 or 3 are not available (perhaps the Wayne NJ SD but I may have misunderstood what they plan to do). I agree that a TPA will not take any responsibilty for compliance under the regs with a fund in a 403b plan that the SD self administers outside of the plan administered by the TPA and the SD will be responsbile to make sure that all of the 403b rules are complied with for both plans which negates the purpose/cost of hiring the TPA.

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Well in PA it looks like my previous post was wrong(I can't burst your bubble). Dave you are correct & I'm now getting Vanguard with only a $10.00/yr fee, which is GReat! This was after much complaining to the PSEA & congressman, etc. It's actually through another co. related to Kades Margolis, called EMPLOYER ADMIN SERVICES. see http://www.employeradmin.com/home/Home/tabid/64/Default.aspx

You can actually go to that website under employee, then state & see what school district sign on, what plans they have & even see that S.D. written plan. It took time but it's GREAT. Amazing what being vocal can do for you.

It's explained on the PSEA website post: http://www.psea.org/general.aspx?id=3848

 

 

 

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Hi Elaine,

Are you sure that EAS is only charging 10.00 fee? What about the VG fees for each fund and any other administrative fees?

Steve

As per the my S.D. written agreement, posted on EAS, "NOTE: The TPA charges no fees to employees. There may

be fees associated with your investment that your investment provider and/or investment fund may

charge as indicated in the previous section.)". Therfore, the fee is whatever the investment co. charges. In this case just Vanguard's $10.00 fee.

You can view the documents at: http://www.employeradmin.com/home/Employee...61/Default.aspx

Then click on the state,( most in PA), then the S.D., where you can read the plan document. IT'S AMAZING HOW THEY POSTED THIS TO THE PUBLIC!!

E

 

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Elaine,

Is IAS doing this pro bono? Who is paying their fees, if not the employees? District, union or the taxpayers, who?

I looked at a plan document and found nothing about the $10 or a costs or fees.

I am sure you have been reading all of the posts about the sour state of 403bs not just under these new regs, but for decades.

No disrespect, but your story has a slight ring of "too good to be true." It took a commitee of good folks to learn about our fee structure for our 457b plan over several months, in the wake of a VP of our TPA saying to the board of education and the world that the fee is 15 basis points. Well, that was not the case at all, most of the fees are over 1%. Those fees are sometimes hard to discern (revenue sharing). Remember we are dealing with a 403b system, powerful, very clever and secretive.

Steve

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