Selecting Target Date Funds: The RFP Process

Transcription

1 Selecting Target Date Funds: The RFP Process A white paper by Fred Reish and Bruce Ashton Drinker Biddle & Reath LLP 1800 Century Park East, Suite 1500 Los Angeles, California (310) fred.reish@dbr.com / bruce.ashton@dbr.com

2 The legal research contained in this white paper was compiled by Drinker Biddle & Reath LLP. J.P. Morgan Asset Management is a subsidiary of JPMorgan Chase & Co. and is not affiliated with Drinker Biddle & Reath LLP. Drinker Biddle & Reath LLP is solely responsible for the analysis and conclusions in this white paper. J.P. Morgan is not responsible for conclusions of law set forth in this white paper. The legal research referred to in this white paper is current as of August The reader should independently determine whether the law and research set forth in this white paper are current after that date. The law and Drinker Biddle s analysis contained in this white paper are general in nature and do not constitute a legal opinion or legal advice that may be relied on by third parties. Readers should consult their own legal counsel for information on how these issues apply to their individual circumstances. Further, the law and analysis in this white paper are current as of August Changes may have occurred in the law since this paper was drafted. As a result, readers may want to consult with their legal advisors to determine if there have been any relevant developments since then. Fred Reish and Bruce Ashton are partners in the Employee Benefits & Executive Compensation Practice Group of Drinker Biddle & Reath LLP. The firm has been compensated by J.P. Morgan Asset Management for providing advice regarding the selection of target date funds (TDFs). The request for proposal (RFP) included in the Appendix is a sample and may not be appropriate for any particular plan. To determine whether the sample RFP requests the information that will help plan sponsors make a prudent decision for their plan, plans sponsors should review the RFP with their investment consultants.

3 Introduction In light of their popularity as 401(k) plan investments, 1 target date funds (TDFs) have been receiving heightened regulatory scrutiny. This means that plan sponsors 2 should be especially rigorous in the process they use to select and monitor TDFs, regardless of whether the TDF is offered as an investment option or used as a plan s qualified default investment alternative (QDIA). The sample request for proposal (RFP) included in this paper is designed to help in that process. An important factor that plan sponsors and their financial advisors have come to understand especially since the 2008 market crash is that no two TDFs are created equal. There are considerable variations in investments and their objectives, glide paths, costs and even the assumptions about participant behaviors that underlie the design of a TDF. The challenge for plan sponsors is to identify and follow a process that enables them to fulfill their fiduciary obligation to prudently select and monitor the TDFs for their plan. Despite the development of comparison aids 3 and benchmarks to help plan sponsors make a prudent choice, one of the most effective ways to handle the challenge remains the use of a properly designed RFP. The sample RFP was developed for this purpose. The questions were selected with two objectives in mind: Satisfy ERISA s prudent process requirement. Follow best practices of the investment community. Our comments in this piece address the first of these objectives. FRED REISH & BRUCE ASHTON 1

4 General fiduciary principles Under ERISA, fiduciaries are required to act prudently in the selection and monitoring of plan investments, 4 which is known as the Prudent Man rule. This requires that fiduciaries act with the care, skill, prudence and diligence that a prudent man familiar with such matters 5 would use in making decisions. In other words, the standard required of an ERISA fiduciary is not that of an ordinary prudent person, but of one who is knowledgeable about or familiar with investments, including TDFs. A Department of Labor (DOL) regulation expands on this concept by indicating that plan sponsors must gather information about the investments that they should know is relevant to the decision. 6 There are two parts to this requirement: A plan sponsor must assemble and assess the relevant information regarding the investments in order to make a prudent decision. Regardless of a plan sponsor s level of knowledge or investment sophistication, a plan sponsor must assess the information that a knowledgeable investor would consider relevant, or material, to the decision. The obligation to prudently select investments extends to TDFs, whether offered for participant selection (since they are designated investment alternatives of the plan) or as the plan s QDIA. In the latter context, the DOL points out in the preamble to the final QDIA regulation that, in selecting a particular QDIA: The selection is a fiduciary act and, therefore, ERISA obligates fiduciaries to act prudently and solely in the interest of the plan s participants and beneficiaries. A fiduciary must engage in an objective, thorough, and analytical process that involves consideration of the quality of competing providers and investment products, as appropriate. As with other investment alternatives made available under the plan, fiduciaries must carefully consider investment fees and expenses when choosing a qualified default investment alternative. 7 (Emphasis added.) The regulation goes on to add: Nothing in this section shall relieve a fiduciary from his or her duties under part 4 of title I of ERISA to prudently select and monitor any qualified default investment alternative under the plan. 8 The QDIA regulation is a safe harbor ; that is, it protects fiduciaries from liability for their decisions so long as they comply with all the requirements of the regulation. But it only provides this protection if a fiduciary prudently selects and monitors the investment used as the QDIA. Plan sponsors ought to pay particular attention to the comment in the preamble that the TDF evaluation process should involve a comparison of competing providers and investment products. The DOL is saying that plan sponsors need to do some comparison shopping to determine the appropriate suite of TDFs for their plans. Given the wide variations among TDFs and TDF providers, a plan sponsor should consider the alternatives before making the selection that is appropriate for its workforce. Properly employed, an RFP will help in the selection by aiding plan sponsors while obtaining comparable information from a number of providers. In this context, properly employed means working with the plan s financial advisor to identify potential TDF providers. One approach might be to perform an analysis of the plan sponsor s goals and objectives to develop a plan profile and then select providers whose suite of TDFs appears to fit the profile, such as conservative, moderate, aggressive and so on. The RFP would then only be sent to providers that offer TDFs aligning with the plan s financial goals and objectives. A second approach would be to work with the plan s financial advisor to identify a group of quality providers to respond to the RFP who span a range of approaches and styles. Once the responses have been received, the plan sponsor and the financial advisor can compare the results across various categories and select the most appropriate TDF for the workforce. Either approach should satisfy the reminder to compare providers and products. 2 SELECTING TARGET DATE FUNDS: THE RFP PROCESS

5 Selecting TDFs To help fiduciaries fulfill the obligation to prudently select a TDF, the DOL released its Target Date Retirement Funds Tips for ERISA Plan Fiduciaries (referred to throughout this white paper as the Tips ) in February This informal publication describes a number of items that plan sponsors should take into account in the selection process. A well-designed RFP will address each of these factors. The first item addressed by the DOL is the underlying investments of the TDFs: [I]n selecting a TDF you should consider prospectus information, such as information about performance (investment returns) and investment fees and expenses. You should consider how well the TDF s characteristics align with eligible employees ages and likely retirement dates. It also may be helpful for plan fiduciaries to discuss with their prospective TDF providers the possible significance of other characteristics of the participant population, such as participation in a traditional defined benefit pension plan offered by the employer, salary levels, turnover rates, contribution rates and withdrawal patterns. A factor addressed in this Tip is that plan sponsors need to compare different TDF designs to their plan demographics, and they also need to understand the assumptions about participant behaviors that may underlie different TDF strategies. QUESTIONS TO CONSIDER... Section III of the sample RFP is intended to obtain information about the underlying investments. The questions in Section II.2 address participant characteristics, as well as additional information about the TDF s investments. These questions should help the plan sponsor determine how well the TDF will align with the plan s participant population. The Tips then point out the importance of understanding the fund s investments, which comprise the allocation in different asset classes (stocks, bonds, cash), individual investments and how these will change the glide path over time. In addition, the DOL points out the importance of understanding participant behavior, which is relevant for the plan sponsor to consider in the selection process: Do you understand the principal strategies and risks of the fund, or of any underlying asset classes or investments that may be held by the TDF? Make sure you understand the fund s glide path, including when the fund will reach its most conservative asset allocation and whether that will occur at or after the target date. Some funds keep a sizable investment in more volatile assets, like stocks, even as they pass their target retirement dates. Since these funds continue to invest in stocks, your employees retirement savings may continue to have some investment risk after they retire. These funds are generally for employees who don t expect to withdraw all of their 401(k) account savings immediately upon retirement, but would rather make periodic withdrawals over the span of their retirement years. Other TDFs are concentrated in more conservative and less volatile investments at the target date, assuming that employees will want to cash out of the plan on the day they retire. If the employees don t understand the fund s glide path assumptions when they invest, they may be surprised later if it turns out not to be a good fit for them. QUESTIONS TO CONSIDER... Sections II and III of the sample RFP address multiple aspects of the TDF s glide path design. Among other things, the questions in these sections will elicit information about participant behavior identified in this Tip. FRED REISH & BRUCE ASHTON 3

6 SELECTING TDFs The DOL also notes the importance of reviewing the appropriateness of fees and investment expenses within the context of the services received: Do you understand the fees and expenses, including any sales loads, for the TDF? If the TDF invests in other funds, did you consider the fees and expenses for both the TDF and the underlying funds? If the expense ratios of the individual component funds are substantially less than the overall TDF, you should ask what services and expenses make up the difference. Added expenses may be for asset allocation, rebalancing and access to special investments that can smooth returns in uncertain markets, and may be worth it, but it is important to ask. QUESTIONS TO CONSIDER... Section V of the sample RFP is in regard to the control of rebalancing costs. This section addresses both the cost of the TDF and the expenses of the underlying funds that make up the TDF and have an impact on investment returns. The DOL also addresses employee communications and says, Just as it is important for the plan fiduciary to understand TDF basics when choosing a TDF investment option for the plan, employees who are responsible for investing their individual accounts need information too. QUESTIONS TO CONSIDER... Section IV of the sample RFP addresses participant communications and reporting. Finally, the DOL suggests that the plan sponsor asks about the availability of a custom TDF for the plan. Custom TDFs are not appropriate for all plans. In large plans, the extra cost of customization can be absorbed either by the plan sponsor or by economies of scale due to a bigger asset and participant base. In either of these cases, the cost per participant is relatively low. In the appropriate plan, the use of custom funds may be desirable. QUESTIONS TO CONSIDER... The section at the end of the sample RFP, titled Custom Target Date Fund Services, helps to determine the provider s ability, willingness, experience and expertise in providing custom TDFs. The Tips provide a helpful guide for plan sponsors to follow, but cannot be used without information. The attached sample RFP is designed to help plan sponsors gather information. The questions are structured to ask for the relevant information in a way that will help obtain the needed data in one place and in an organized way. By obtaining the information requested in the sample RFP, the plan sponsor will be better able to perform a prudent evaluation before selecting the appropriate TDF suite for its plan. The DOL has also released proposed amendments to the QDIA and participant disclosure (404a-5) regulations that specify information that must be disclosed to participants. While the focus in both proposals is on participant disclosure, a practical effect of the proposals is to suggest key factors that plan sponsors should assess in selecting a plan s TDF. 9 These regulatory changes will likely become effective in In both proposals, the DOL guidance suggests that plan sponsors consider the asset allocation among the underlying investments of the fund, as well as the glide path along which that allocation becomes more conservative over time. For example, in the proposed 404a-5 amendment, the DOL specifies that the plan sponsor must provide the following information to the participants: An explanation of the alternative s asset allocation, how the asset allocation will change over time, and the point in time when the alternative will reach its most conservative asset allocation. By indicating that this information is important enough to be given to participants, the DOL is indirectly telling plan sponsors that they must consider these factors asset allocation and glide path construction when they select a TDF suite. 4 SELECTING TARGET DATE FUNDS: THE RFP PROCESS

7 SELECTING TDFs These proposed amendments are similar to a Securities and Exchange Commission (SEC) proposal related to mutual fund disclosures. 10 In essence, both the DOL and the SEC view TDFs as asset allocation vehicles. Both agencies stress that participants (or investors) must be given information so that they can understand the investment allocation of TDFs, how the allocation changes over time (the glide path), the expenses, performance and the competency of the TDF manager. Conclusion Plan sponsors must act prudently in selecting TDFs for their plans. Fortunately, the DOL has provided helpful Tips that shed light on what information should be considered in making the selection. But gathering that information may not be as simple as it sounds. The attached sample RFP is designed to help smooth out the rough spots in that process. QUESTIONS TO CONSIDER... Section II.2. of the sample RFP asks for specific information about the underlying investments, the asset allocation among those investments and the glide path on which the asset allocation is adjusted over time. It also seeks information about situations in which the provider may adjust the asset allocation or glide path on a tactical rather than a strategic basis. This is all important information, as indicated by the proposed amendments to the QDIA and the 404a-5 regulations. FRED REISH & BRUCE ASHTON 5

8 Sample target date fund request for proposal By: Fred Reish and Bruce Ashton Drinker Biddle & Reath LLP I. Firm information 1. Organization Provide a brief overview of your firm, including a list and description of the following, and a copy of your ADV Part 2A or your firm brochure. a. Parent company b. Departments/divisions within the firm and products/services provided by each c. Affiliates d. Organizational chart 2. Internal controls and review process a. Provide a summary of your firm s internal control structure related to issues such as conflicts of interest, compensation of managers, compliance with changes in laws or regulations, etc. b. Describe your internal review process and frequency for these issues. 3. Investment management division a. What is the firm s history of providing asset allocation products or services? b. Describe how your target date funds (TDF) group and product(s) fit within your overall business plan. Do you have a dedicated TDF team? Is the management of TDFs a core business for the firm? 4. Portfolio management team a. Personnel describe in detail the team dedicated to managing your TDFs and the internal and/or external structure that supports them. Please note additions or departures to the investment team within the past five years and any plans to change the manager/team members when and why. b. Product profile list the different types of investment vehicles offered within your suite of TDF products (e.g., mutual funds, ETFs, separate accounts, commingled or collective investment trusts) and the assets under management of each type. If applicable, describe the rationale for offering multiple products. c. Product growth describe the growth rate of your TDF business over the past five years and the drivers of that growth. II. Glide path 1. Philosophy a. Describe the philosophy that supports your TDF glide path. How did you arrive at your conclusions on how to construct the glide path? Attach any research papers you feel are pertinent and appropriate. b. Do your TDFs meet the requirements to be considered a qualified default investment alternative (QDIA) under Department of Labor regulations? c. What is your approach to managing risks in your TDF? Address at least the following: i. Longevity risk ii. Inflation risk 6 SELECTING TARGET DATE FUNDS: THE RFP PROCESS

9 SAMPLE TARGET DATE FUND RFP iii. Interest rate risk iv. Market risk and volatility, including your strategy for minimizing the risk of large losses v. Stress testing d. Explain the primary objective(s) of your TDFs, and how it/they differ from the TDFs of other major providers. e. Do you assume a certain level of replacement income at retirement? 2. Process a. What are the inputs and major assumptions used in the construction of your TDF glide path? i. Explain your modeling process. ii. Describe any specific demographic or participant behavior assumptions used, such as salary raises, contribution rates, participant loans, pre-retirement distributions and the length of time participants remain in the plan after retirement. b. What asset classes do you include in your glide path? How do you assess whether an appropriate amount of diversification exists within the asset classes chosen? c. What is the rationale for the asset allocation in both the longest and shortest dated funds offered? d. When does the glide path reach its final (static) asset allocation? What is the rationale for this? 3. Results a. How has your glide path performed throughout different market environments? Please provide calendar year performance since inception. b. Under what circumstances do you make changes to your glide path (strategic allocation)? Include a description of and rationale for any changes made to your glide path over the last five years. c. How do you expect the portfolio to perform within five years of retirement under various capital market scenarios (high inflation, high volatility, etc.)? III. Glide path implementation 1. Underlying vehicle selection a. Do you implement your glide path using active underlying managers, passive underlying funds, or a combination of both? i. What is the rationale for this decision? b. What specific mutual funds or financial products are available within the TDFs? What share classes are used in the TDFs? c. What is your screening process for manager/fund selection? i. How is the manager/fund monitored and by whom? ii. What tools/metrics are used in the analysis? iii. Under what circumstances are the manager/fund removed and replaced? d. To the extent passive vehicles are employed, when are they replaced and under what circumstances? 2. Tactical asset allocation a. Do you employ tactical asset allocation? If so: i. Describe the rationale and process for the use of tactical asset allocation in adjusting the asset allocation along the giide path. Provide performance attribution for tactical decisions made over the last five years. 3. Rebalancing a. Describe your rebalancing process, including methodology, timing and who is responsible. b. Describe how cash flows are managed. FRED REISH & BRUCE ASHTON 7

10 SAMPLE TARGET DATE FUND RFP IV. Fees 1. Expense ratio a. What is the expense ratio? b. Provide details of each element of the expense ratio, including your investment management fees, trading expenses, marketing expenses, etc. 2. Rebalancing costs a. How do you minimize the impact of rebalancing costs? V. Other 1. Communications a. What materials do you provide to assist participants with understanding your TDFs? b. Can communications material be customized? c. What assistance do you provide to the plan administrator to satisfy the 404a-5 participant disclosures with respect to the TDFs? 2. Reporting a. Provide samples of reports to the plan s fiduciaries, such as performance, benchmarks, fact sheets, participant communications and the like, and indicate their frequency/timing of availability and delivery method(s). VI. Appendix 1. Include any and all changes you have made to your glide path and underlying managers and/or indices since inception, and explain why you made those changes. 2. Provide any performance or statistical data to support your strategy and philosophy. 8 SELECTING TARGET DATE FUNDS: THE RFP PROCESS

11 SAMPLE TARGET DATE FUND RFP CUSTOM TARGET DATE FUND SERVICES If a plan s size and demographics support the consideration of a custom target date solution, consider adding these questions to the RFP: 1. Services a. Describe your custom target date fund services. 2. Operations a. Provide a list of recordkeepers with whom you work. Indicate whether you have established data feeds with each. b. Provide a list of trustees/custodians with whom you work. Is the plan sponsor required to provide official direction? c. Describe the day-to-day communications and operational processes used to manage the glide path when daily cash flows are determined, including: i. Controls ii. Reconciliations iii. Automated feeds iv. Error handling v. Cash flow management 3. Project management a. Describe the typical account set-up process. i. What is the expected time frame for the account set-up process? ii. Who would the implementation project manager be, if applicable? b. What involvement is required of the client or client s vendors during implementation? c. What are the principal events that must coincide for a successful implementation? FRED REISH & BRUCE ASHTON 9

12 About the authors Recognition by 401kWire as the 401(k) Industry s Most Influential Person for 2007 (and has, for every year of that survey, been in the top 10) The IRS Director s Award and the IRS Commissioner s Award for his contributions to employee benefits education Fred Reish Fred.reish@dbr.com Fred Reish is a partner in the Drinker Biddle & Reath Employee Benefits & Executive Compensation Practice Group and Chair of the Financial Services ERISA Team. He has specialized in employee benefits law since 1973 and works with both private and public sector plans and fiduciaries; represents plans, employers and fiduciaries before the IRS and the DOL; consults with banks, trust companies, insurance companies and mutual fund management companies on 401(k) investment products and issues related to plan investments; and represents broker-dealers and registered investment advisers on compliance issues. Fred serves as a consultant and expert witness for ERISA litigation. Fred received a J.D. from the University of Arizona James E. Rogers College of Law and a B.S. from Arizona State University. Professional recognition and awards Fred has received a number of awards for his contributions to benefits education, communication and service, including: In 2011, selection by PLANADVISER magazine as one of the 5 Legends of the retirement industry and with retirement advisors The 2009 American Society of Pension Professionals & Actuaries (ASPPA)/Morningstar 401(k) Leadership Award for directly and positively influencing the ability of Americans to build successful retirements Selection by PLANSPONSOR magazine as one of the 15 Legends in the development of retirement plans The 2006 Lifetime Achievement Award from PLANSPONSOR magazine The 2006 Lifetime Achievement Award from Institutional Investor for his contributions to the benefits community The 2004 Eidson Founder s Award from ASPPA for his significant contributions to that organization and to the benefits community On behalf of ASPPA, he has co-authored amicus curiae briefs with the Supreme Court of the United States in the case of Patterson v. Shumate and with the Tax Court in the case of Citrus Valley Estates v. Commissioner of Internal Revenue Service. Publications Fred has written four books and more than 350 articles. He authors a monthly column on 401(k) fiduciary responsibility for PLANSPONSOR magazine. As an experienced lawyer on benefits matters, Fred is frequently quoted by both professional and public publications, including The Wall Street Journal, Fortune, Forbes, Inc., CFO Magazine, New York Times, Washington Post, Los Angeles Times, USA Today, Institutional Investor, PLANSPONSOR and Pensions & Investments. Speaking engagements Fred is a nationally known speaker on fiduciary responsibility. He has spoken at the annual conferences of the American Bar Association, the American Society of Pension Professionals and Actuaries, the Western Pension and Benefits Conference, the Enrolled Actuaries Conference and the International Foundation of Employee Benefit Plans. 10 SELECTING TARGET DATE FUNDS: THE RFP PROCESS

13 ABOUT THE AUTHORS Professional recognition and awards Bruce has received a number of awards for his contributions to the employee benefits community, including: Bruce Ashton Bruce.ashton@dbr.com Bruce Ashton is a partner in the Drinker Biddle & Reath Employee Benefits & Executive Compensation Practice Group. He has specialized in employee benefits law since 1986 and works with private and public sector plans; advises and represents plans, employers and fiduciaries before the IRS and DOL; consults with financial institutions, including banks, trust companies and insurance companies on 401(k) compliance issues; and represents registered investment advisers on issues related to fiduciary status, compliance, prohibited transactions and internal procedures. Prior to focusing on employee benefits, Bruce practiced as a corporate and securities lawyer. Bruce received a J.D. from the Southern Methodist University School of Law, where he was selected to the Order of the Coif, and his B.A. from Rice University. The 2011 Eidson Founder s Award from ASPPA for his significant contributions to that organization and to the benefits community Recognition by 401kWire as one of the 401(k) Industry s Most Influential People Recognition as an outstanding lawyer in The Best Lawyers in America Publications Bruce has co-authored four books (with Fred Reish) and more than 150 articles on employee benefits issues, including fiduciary issues, prohibited transactions, IRS and DOL correction programs, audits and investigations and plan design. He has also been widely quoted in various benefits publications. Speaking engagements Bruce is a frequent speaker on various employee benefits issues and has spoken at the annual conferences of the American Society of Pension Professionals and Actuaries, the Western Pension and Benefits Conference, the Enrolled Actuaries Conference, the International Foundation of Employee Benefit Plans and the National Institute of Pension Administrators. FRED REISH & BRUCE ASHTON 11

14 Endnotes 1 See, for example, Holden, Sarah, Jack VanDerhei, Luis Alonso and Steven Bass, 401(k) Plan Asset Allocation, Account Balances, and Loan Activity in 2012, ICI Research Perspective 19, no. 12 (December 2013), available at www. ici.org/pdf/per19-12.pdf. 2 We use the term plan sponsor to refer to the fiduciary responsible for the prudent selection and monitoring of a plan s suite of TDFs. 3 J.P. Morgan Target Date Compass SM. 4 ERISA Section 404(a)(1)(c). 5 ERISA Section 404(a)(1)(B). 6 ERISA Regulation Section a-1(b). 7 Preamble to final QDIA regulation, 72 Fed. Reg. No 205 (October 24, 2007), page ERISA Regulation Section c-5(b)(2). 9 Target Date Disclosure, Federal Register, Volume 75, Number 229 (November 30, 2010), pages Securities Act Release No (June 16, 2010) [75 FR (June 23, 2010)], comment period re-opened April SELECTING TARGET DATE FUNDS: THE RFP PROCESS

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16 TARGET DATE FUNDS: Target date funds are funds with the target date being the approximate date when investors plan to start withdrawing their money. Generally, the asset allocation of each fund will change on an annual basis, with the asset allocation becoming more conservative as the fund nears the target retirement date. The principal value of the fund(s) is not guaranteed at any time, including at the target date. Certain underlying funds of target date funds may have unique risks associated with investments in foreign/emerging market securities and/or fixed income instruments. International investing involves increased risk and volatility due to currency exchange rate changes; political, social or economic instability; and accounting or other financial standards differences. Fixed income securities generally decline in price when interest rates rise. Real estate funds may be subject to a higher degree of market risk because of concentration in a specific industry, sector or geographical sector, including, but not limited to, declines in the value of real estate, risk related to general and economic conditions, changes in the value of the underlying property owned by the trust and defaults by the borrower. The fund may invest in futures contracts and other derivatives. This may make the fund more volatile. The gross expense ratio of the fund includes the estimated fees and expenses of the underlying funds. There may be additional fees associated with investing in a Fund of Funds strategy. Fred Reish and Bruce Ashton are partners in the Employee Benefits & Executive Compensation Practice Group of Drinker Biddle & Reath LLP. They have been compensated by J.P. Morgan Asset Management to provide advice and to give an opinion regarding the topic of target date fund RFPs. IRS Circular 230 Disclosure: JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties. Opinions and estimates offered constitute Fred Reish and Bruce Ashton s judgment and are subject to change without notice. They believe the information provided here is reliable, but do not warrant its accuracy or completeness. This material is not intended as an offer or solicitation for the purchase or sale of any financial instrument. The views and strategies described may not be suitable for all investors. This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, accounting, legal or tax advice. J.P. Morgan Asset Management is the marketing name for the asset management businesses of JPMorgan Chase & Co. Those businesses include, but are not limited to, J.P. Morgan Investment Management Inc., Security Capital Research & Management Incorporated and J.P. Morgan Alternative Asset Management, Inc. JPMorgan Chase & Co., All rights reserved. INST-PDD-WP-P1 RI-SA-TDFRFP August FOR INSTITUTIONAL 2014 AND PROFESSIONAL USE ONLY NOT FOR PUBLIC DISTRIBUTION J.P. MORGAN ASSET MANAGEMENT 270 Park Avenue I New York, NY 10017