Defined Contribution in Review A Quarterly Briefing for Plan Sponsors: 2Q17

Transcription

1 Defined Contribution in Review A Quarterly Briefing for Plan Sponsors: 2Q17

2 What s Inside Our Defined Contribution in Review is designed to help CEOs, CFOs, Treasurers, Human Resource and Benefits Professionals and Investment Committees stay abreast of recent events that could have an impact on plans or plan participants. Inside you will find the following information: Quarterly Highlights: A summary of plans and sponsors making the news Participants Corner: Timely insights about the retirement readiness of plan participants Legislative Review: A summary of new and pending legislation Regulatory Review: News out of the Department of Labor and other regulatory bodies Legal Review: An update on high-profile ERISA cases Global Headlines: A brief synopsis regarding global retirement issues We hope you will find the information helpful and we are happy to answer any questions you may have. 2

3 Quarterly Highlights 3

4 Quarterly Updates PLANSPONSOR Announces 2017 Best in Class 401(k) Plans Ameren American Financial Group, Inc. Ansell Healthcare Airline Tariff Publishing Company BAE Systems BNY Mellon Boston Scientific CHS Inc. Citigroup Explorer Pipeline ICMA-RC Karsten Manufacturing Corporation Marshall Wace North America L.P. Molson Coors Brewing Company Johnson & Wales University Musco Corporation National Grid Noble Energy Inc. North American Stainless O.C. Tanner Company Otten Johnson Robinson Neff & Ragonetti Regency Centers Sandia National Laboratories SEMCO Energy Southwest Airlines Pilots Association Tesoro Corporation Texas Guaranteed Student Loan Corporation The Beck Group The Hershey Company The SSI Group, LLC United Technologies Corporation Veridian Credit Union Vermeer The Western Union Company For additional information, please see 4

5 Quarterly Updates Methodology Used by PLANSPONSOR for Selecting Best in Class Plans + Recipients were selected from 3, (k) plans that responded to the 2016 PLANSPONSOR Defined Contribution (DC) Survey + Plans were rated by way of a proprietary system that weighted usage/ implementation of more than 30 criteria related to plan design, oversight/ governance and participant outcomes + Examples of evaluation criteria included employee participation and deferral rates, level of employer contributions, eligibility/vesting requirements and existence of an investment committee For additional information, please see 5

6 Quarterly Updates PLANSPONSOR Best in Class: Plan Measures Best in Class Plans All Other 401(k) Plans Percentage Difference Participation rate 94% 79% +19% Deferral rate 8.9% 6.5% +37% Retirement confidence 43% 29% +48% For additional information, please see 6

7 Quarterly Updates PLANSPONSOR Best in Class: Investment Choices Best in Class Plans All Other 401(k) Plans Percentage Difference Roth provision 97% 67% +45% Index funds 97% 88% +10% Managed account 56% 32% +75% For additional information, please see 7

8 Quarterly Updates PLANSPONSOR Best in Class: Plan Design Eligibility within 3 months Best in Class Plans All Other 401(k) Plans Percentage Difference 100% 58% +72% Auto-enrollment 91% 44% +107% Auto-escalation 100% 38% +163% Default deferral rate >5% 38% 18% +111% Re-enrollment 35% 11% +218% Loan payment post-separation 66% 24% +175% For additional information, please see 8

9 Quarterly Updates PLANSPONSOR Best in Class: Employer Contributions Best in Class Plans All Other 401(k) Plans Percentage Difference Effective match >3% 74% 43% +72% Match vested within 2 years 76% 44% +73% True-up match contributions 72% 39% +85% For additional information, please see 9

10 Quarterly Updates PLANSPONSOR Best in Class: Oversight Practices Best in Class Plans All Other 401(k) Plans Percentage Difference Investment committee Investment policy statement 100% 95% +5% 100% 76% +32% Fee equalization 45% 30% +50% For additional information, please see 10

11 Quarterly Updates PLANSPONSOR Best in Class: Financial Education Offered Best in Class Plans All Other 401(k) Plans Percentage Difference Saving and budgeting 85% 32% +165% Investment basics/strategies Credit/debt management 76% 38% +100% 62% 17% +265% College savings 38% 13% +192% Home buying 12% 9% +33% No financial education 12% 54% -78% For additional information, please see 11

12 Quarterly Updates Other Plan Sponsors Making the News + Dot Foods + Government of the District of Columbia + University of Central Florida 12

13 Quarterly Updates Dot Foods Uses Online Tool to Benchmark Advisor + The Mount Sterling, Illinois, food service distribution company had been using the same advisor for its $200 million 401(k) and $3 million non-qualified deferred compensation plans for 13 years + Although satisfied with the advisor s services, the company felt it important to conduct an advisor RFP to satisfy their due diligence responsibilities + Dot partnered with InHub and learned that the incumbent advisor was not competitive on pricing while other advisors were willing to take an active role in participant communication, which the incumbent was not currently providing + The company eventually decided to switch advisors, realizing a 34% cost savings in addition to receiving general education and advice for participants plus expanded electronic communications 13

14 Quarterly Updates District of Columbia Gets Creative to Drive Employee Engagement + Employees hired after 1986 were automatically enrolled in a 401(a) plan and have access to a voluntary 457(b) plan + With a 48% participation rate in the 457(b) plan, the District was concerned that not enough employees were on track to generate sufficient retirement income + To help increase participation, the District s record-keeper provided its RealizeRetirement Tour a truck equipped with an animation application, virtual reality exhibit and other employee engagement capabilities + More than 450 government employees in nine locations participated in the tour; 68% followed up with individual meetings with the record-keeper s representatives and 14% enrolled in the 457(b) plan 14

15 Quarterly Updates 403(b) Revamp at the University of Central Florida (UCF) + UCF recently reduced the number of record-keepers for its $127 million 403(b) plan from seven to three following an RFI + The investment lineups were also overhauled and now each record-keeper offers a target-date series, a passive tier, a tier of actively managed funds and a self-directed brokerage account + Each passive tier contains six options and the actively managed funds consist of 14 options 15

16 Participants Corner 16

17 Participants Corner New Report Quantifies Employer Cost When Participants Retire Late + A new report by Prudential, Why Employers Should Care About the Cost of Delayed Retirements, found that a one-year increase in average retirement age results in: An incremental cost of over $50,000 for an individual whose retirement is delayed. This represents the cost differential between the retiring employee and a newly hired employee Incremental annual workforce costs of about 1.0% to 1.5% for an entire workforce. For an employer with 3,000 employees and workforce costs of $200 million, a one-year delay in retirement may cost about $2 million to $3 million + The report suggests best practices for employers such as plan design improvements, adopting a financial wellness approach, employee education and better use of data analytics to understand the implications to a sponsor s organization 17

18 Participants Corner Survey Suggests that Employee Financial Education Works, But When Done Correctly + The International Foundation of Employee Benefit Plans deployed an employee financial education survey to members representing corporations, multiemployer trust funds and public employers across the United States and Canada + A Closer Look: What s Working in Workplace Financial Education found: Organizations that offer financial education for longer periods of time generally have participants who are less stressed, more financially savvy and better prepared for retirement than those organizations that recently began or do not provide education Among organizations that provide financial education, those that have made a strong commitment to education, assess participant needs, provide a broad range of topics, customize their programs and have increased accessibility and inclusions experience higher levels of success 18

19 Participants Corner Pentegra Survey Identifies Millennial Saving Habits and Behaviors + In May 2017, Pentegra Retirement Services surveyed over 100 millennials and found that over 80% are currently saving for retirement and 37% are putting at least 5% of their salary into a retirement savings vehicle + The survey also found that the millennial spend now subculture cannot be ignored, as 31% spend more than $75 a week on eating out or ordering takeout, and saving for retirement ranked second to paying a mortgage when asked to rank their top five priorities + Among the recommendations offered were to improve economic education at schools, redouble efforts at educating employees and encourage conversations about saving for retirement with family, friends and peers 19

20 Participants Corner Morningstar: Target-Date Funds Continue to Experience Strong Growth + Morningstar s 2017 Target-Date Fund Landscape report found that targetdate funds added to their multiyear trend of growth in 2016, due in large part to their role as the default investment option in many DC plans. Other key takeaways include: Assets in target-date mutual funds reached an all-time high of $880 billion by the end of 2016, and roughly two of every three dollars directed to them in 2016 went into a passive series The funds boast a positive 1.4-percentage-point investor return gap over the 10 years through 2016 The average asset-weighted expense ratio fell to 0.71% by the end of 2016, a notable decrease from 0.99% just five years earlier The average equity glide path hasn t changed dramatically in recent years, particularly for the youngest and oldest investors. However, mid-career investors have seen a modest increase in equity exposure 20

21 Participants Corner Case Study Illustrates the Power of Video Communications + An April 2017 Willis Towers Watson article described a recent client engagement that involved the creation of six scripted benefit videos posted on the company s intranet site and distributed by in the weeks leading up to open enrollment; this particular client had 2,200 employees who do sales and administration work + The main video announcing open enrollment was opened 1,599 times and viewed for an average of two minutes and 30 seconds, on computers (1,529), tablets (19) and smartphones (51). Additionally, 329 employees clicked a link to the online enrollment site, 432 accessed a medical plan comparison tool and 388 linked to a plan cost calculator + The cost of the project, including script assistance, graphic design, voiceover, editing and packaging, was $20,000 21

22 Participants Corner Health Savings Accounts (HSAs) Becoming an Important Employee Benefit + The Plan Sponsor Council of America surveyed 255 employers, 181 of whom sponsor an HSA-qualifying, high-deductible health plan, and found that 75% of employers view the HSA as part of their retirement benefits strategy and nearly 60% believe HSAs should replace Flexible Spending Accounts + About 60% of eligible employees participate in an HSA, with an average account balance of $3,161 + Approximately 40% of plans indicate that 25% or fewer of participants use their entire HSA balance every year and an additional 35% of plans state that 26% to 50% of their participants use their entire balance every year + More than 80% of employers contribute to the HSA, where two-thirds provide a set dollar amount based on the high-deductible health plan coverage tier 22

23 Participants Corner Working With an Advisor Found to Boost Retirement Confidence + A new LIMRA Secure Retirement Institute study finds that 43% of U.S. pre-retirees (ages 50 to 75) who work with an advisor feel well prepared for retirement, compared to just 21% of pre-retirees who do not + The study, Dear Advisor, found that of pre-retirees who work with an advisor, minimizing the risk of running out of money and protecting portfolio principal were cited as the top two most valuable services provided + Additionally, 67% of pre-retirees who have a formal written retirement plan said they felt well prepared, compared to just 34% of those who do not have a plan 23

24 Participants Corner Vanguard s How America Saves Research Finds Encouraging Trends + Analyzing data from its 8,500 plan sponsors and 4.6 million participants, Vanguard s 2016 How America Saves research provides some encouraging news including: More than half of all participants were solely invested in an automatic investment program compared to just 17% in % of plans had adopted automatic enrollment, up four percentage points from 2015 The Roth feature was adopted by 65% of plans and 13% of participants within the plans that had elected the option During 2016, only 8% of participants traded within their accounts, while 92% did not initiate any exchanges 24

25 Legislative Review 25

26 Legislative Review Trump Administration Nixes ERISA Safe Harbor for State-Run Plans + In May 2017, President Trump signed legislation that overturned the Obama administration s rule that would have exempted state-run auto-ira programs for private sector workers from ERISA + In response, officials in California have announced plans to move forward regardless and the Oregon plan is expected to be operational by July Connecticut also passed legislation in May to roll out its own auto-ira program by January 2018; a similar measure was recently defeated in the Colorado legislature + Meanwhile, Vermont passed legislation in June to introduce a voluntary Multiple Employer Plan (MEP) that will be open to any employer with fewer than 50 employees that does not currently provide a retirement plan 26

27 Legislative Review Three Bills Could Have Significant Impact on Retirement Plans + On June 8, 2017, the House of Representatives passed the CHOICE Act that would, among other things, repeal the DOL fiduciary rule + On April 6, 2017, the Life Income Disclosure Act was introduced that would require DC plan administrators to provide participants once a year with a description of the lifetime income stream equivalent of a participant s total accrued benefit + Legislation (the SEAL Act) has also been introduced in both the House and Senate that would extend the rollover period for unpaid loans in certain circumstances to the due date for filing the tax return for the year in which the plan treats the unpaid loan as a taxable distribution, and eliminating the six-month holdout rule for 401(k) hardship distributions 27

28 Legislative Review Nevada Passes Fiduciary Rule + Effective July 1, 2017, Nevada revised a current law which applies to "financial planner" by removing the exclusion for broker-dealers, registered representatives and investment advisors operating in Nevada. Now, those persons are subject to the state's fiduciary law rules applicable to both retirement and non-retirement accounts + All advisors will now be required to disclose, at the time advice is given, any gain the advisor may receive, such as profit or commission and advisors must make diligent inquiry of each client at the beginning of the relationship and on an ongoing basis, to ascertain the client s financial condition and present and future goals and obligations + Under Nevada law, investors may sue an advisor for economic loss and all costs of litigation and attorney s fees that result from following advice where the advisor violated the fiduciary duty 28

29 Legislative Review Texas Rule May Shrink 403(b) Choices + On June 16, 2017, the Teacher Retirement System of Texas Board of Trustees published a proposed rule in the Texas Register that would prohibit registered products, other than fixed annuities, from charging fees in excess of prescribed amounts for new salary reduction agreements + The proposal would also eliminate any products that charge a front- or backend load and surrender charges for fixed annuities would be capped at 5%, terminating after five years + Existing investments that do not meet the new rules would continue to be permitted under existing salary deferral agreements but not eligible for new agreements + The proposed rules would go into effect April 1,

30 Regulatory Review 30

31 Regulatory Review Reminder: Third Quarter Compliance Calendar July September 15 September 30 + July 29: Deadline for sending Summary of Material Modification + July 31: Deadline for filing Form 5500 (without extension), Form 5558 to request automatic extension, and Form 5330 Return of Excise Taxes Related to Employer Benefit Plans + Extended deadline for filing tax returns for partnerships and contribution deadline for deductibility + Deadline for distributing Summary Annual Report to participants, provided deadline for Form 5500 was not extended 31

32 Regulatory Review DOL Issues Guidance for Fiduciary Rule Transition Period + On May 22, 2017, the DOL issued Field Assistance Bulletin announcing that the DOL will not pursue claims against fiduciaries working in good faith to comply with new advice regulations before January 1, In addition, the DOL issued Conflict of Interest FAQs to provide additional guidance for the transition period of June 9, 2016, to January 1,

33 Regulatory Review IRS Offers Guidance for Computing Loan Amounts Available + In a memorandum to Employee Plan Examination employees, the IRS clarified how to determine the highest outstanding loan balance in the past year when calculating the amount of an additional loan a participant can take from a DC plan. The following example is offered: The participant borrows $30,000 in February, which is repaid in April The participant borrows $20,000 in May, which is repaid in July The plan may determine that no further loan is available because the $50,000 limit is reached or the plan may recognize the highest outstanding loan balance as $30,000, and permit a third loan of $20,000 33

34 Legal Review 34

35 Legal Review 401(k) Excessive Fee Lawsuit Updates + A number of cases have recently survived motions to dismiss including Fujitsu, Starwood Hotels and American Airlines + Chevron defeated for a second time a proposed class-action suit accusing it of breaching fiduciary duties by allowing poorly performing investments that allegedly carried high management fees in its $19 billion 401(k) plan + Northrop Grumman settled its 401(k) excessive fee case originally filed in 2006 by agreeing to pay $16.75 million for conduct occurring from 2000 to 2009; the settlement does not cover a second, similar lawsuit for conduct occurring from 2010 to the present 35

36 Legal Review Inconsistent Rulings on 403(b) Fee Cases + On May 10, 2017, a court ruled that a lawsuit involving Emory University alleging a fiduciary breach by using retail shares classes, rather than institutional share classes, may move forward The court did, however, dismiss the plaintiffs argument that offering too many investment options (111) caused harm to the participants For certain locked-in arrangements made beyond the six-year statute of limitations, the court will allow the plaintiffs to seek damages but for only those incurred during the statute of limitation period + On May 11, 2017, another court also ruled that a lawsuit involving Duke University with similar excessive fee allegations was permitted to proceed This court, however, allowed the allegation for too many investment options (400) to move forward while dismissing allegations against certain locked-in arrangements entered into prior to the six-year statute of limitation period 36

37 Legal Review Disney Avoids Lawsuit over Valeant Stock for the Second Time + On April 21, 2017, a court dismissed a lawsuit alleging that Disney s 401(k) investment committee breached its fiduciary responsibility by offering a mutual fund to 401(k) participants that had 25% of its assets invested in Valeant stock + During the period from August to November 2015, Valeant declined from $262 per share to $70 per share. Approximately 12% of the plan assets were invested in this mutual fund + According to the lawsuit allegation, the investment committee should have removed the investment because it was investing in a growth stock, but held itself out as a value investor 37

38 Legal Review New Stock Drop Case Filed, Three Dismissed + According to employee allegations in a lawsuit filed on June 7, 2017, Chicago Bridge and Iron Co. allowed artificially inflated company stock as an investment option in retirement plans, causing its employees millions of dollars in losses + Cliffs Natural Resources and Peabody Energy were cleared of fiduciary breaches in separate stock drop cases, as courts aligned themselves with recent decisions refusing to impose ERISA liability in cases involving the retirement plans of RadioShack, Whole Foods, Lehman Brothers, JPMorgan Chase, International Business Machines and British Petroleum + On April 28, 2017, the U.S. Court of Appeals upheld a ruling in favor of R.J. Reynolds in a reverse stock drop case involving the investment committee s liquidation of Nabisco following its spinoff 38

39 Legal Review Robo-Advice Lawsuit Tossed + In June 2017, a lawsuit alleging excessive fees for participant-level investment advisory services offered through a 401(k) record-keeper was dismissed + According to the allegation, the record-keeper for the Nestle 401(k) plan kept a substantial portion of the fee for the advice service, even though it was the robo-advisor who actually provided the service + The courts found that the record-keeper was not acting as a fiduciary and once the advice service was in place, could not control its compensation 39

40 Legal Review Supreme Court Rules in Favor of Church-Related Pensions + On June 5, 2017, the U.S. Supreme Court ruled unanimously that pension plans did not have to be established by a church to be exempt from ERISA, as long as they are controlled by or associated with one + The decision overturns conclusions reached by three federal appellate courts in 2015 and 2016 that upheld District Court rulings which ruled that health care systems affiliated with churches were not eligible for an ERISA exemption 40

41 Legal Review Participant Fails to Change Beneficiary, Despite Intentions + In Ruiz v. Publix Super Markets Inc., a plan participant wrote a letter to her employer with instructions to change her beneficiaries from her niece and nephew to her good friend, Arlene Ruiz. She attached to the letter a Beneficiary Designation Card but instead of completing it, she wrote as stated in letter + Upon the death of the plan participant, benefits were paid to the niece and nephew; Ms. Ruiz s claim was denied because the plan s Summary Plan Description (SPD) had specific instructions regarding the change of beneficiary, including the completion of a Beneficiary Designation Card + Ms. Ruiz sued the plan, claiming the letter identifying her as beneficiary was sufficient to entitle her to benefits + The courts denied Ms. Ruiz s claim, concluding that the designation will not be changed unless the plan s specific requirements are followed 41

42 Global Headlines 42

43 Global Headlines World Economic Forum Predicts $224T Pension Gap + In a new report by the World Economic Forum, the pension gap in the world s six largest markets, which include the United States, United Kingdom, Japan, the Netherlands, Canada and Australia, is expected to hit $224 trillion by Five priority actions are suggested for governments and policy including: Review normal retirement age to increase in line with life expectancies Make saving easy for everyone Support financial literacy efforts starting in schools and targeting vulnerable groups Provide clear communication on the objective of each pillar of national pension systems and the benefits that will be provided Aggregate and standardize pension data to give citizens a full picture of their financial position 43

44 Global Headlines Denmark Earns Highest Score in Pension Index + The Melbourne Mercer Global Pension Index, which measures 27 retirement income systems against more than 40 indicators, gave Denmark the highest rating for 2016, followed by the Netherlands and Australia + Each country s pension system is benchmarked against three sub-indexes: adequacy, sustainability and integrity + Argentina and Malaysia were new additions to the index in The three most-improved countries were India, Singapore and South Korea 44

45 Global Headlines New Pan-European Pension Product Proposed + The European Commission proposed a new pension product to give millions of savers in the European Union (EU) an opportunity to complement existing state and occupational pensions + One of the primary advantages of the new product would be its portability, with no need to change plans if savers move from one EU country to another + The product would also impose caps on the cost of switching between investment providers while maintaining transparency and performance requirements + The timeline to launch the product is late

46 Global Headlines EU Gender Gap on Pensions is 40%, More Than Double the Pay Gap + Mercer Consulting found that the EU gender gap for pensions was 40%, compared to 16% on pay + While there are wide variations between countries, with the gap ranging from 4% to 49%, half of the 28 EU members had a gap of 30% or more + According to Mercer, since women earn less on average than men, pensions linked to income will be lower, an effect compounded by the greater likelihood of women working part time or taking career breaks to assist with raising a family or caring for older or disabled relatives 46

47 Global Headlines Canada Will Not Adopt a Best Interests Standard + The Canadian Securities Administrators (CSA) will drop plans to introduce a country-wide legal rule that would require financial professionals to act in their clients interests rather than their employers + Instead, targeted reform proposals have been issued that would regulate the titles used by people who provide financial advice, conflicts of interest and suitability of investment products + Australia and the UK already require advisors to work in their clients best interests while the U.S. and EU are in the process of implementing similar requirements 47

48 Defined Contribution Capabilities 48

49 Janus Henderson Defined Contribution Capabilities years of industry experience + Retirement excellence and leadership + Three highly specialized investment managers: Janus Henderson, INTECH and Perkins + Experience in: Fiduciary responsibility Industry trends Legislative and regulatory updates + $25.9 billion in DC Assets Under Management as of 3/31/17 + Products utilized by the top 25 DC recordkeepers in the industry + Availability on over 200 recordkeeping platforms Janus Capital Management LLC, INTECH Investment Management LLC and Perkins Investment Management LLC are subsidiaries of Janus Henderson Group plc and serve as sub-advisers on certain products. 49

50 Janus Henderson Continuing Education + Janus Henderson offers accredited continuing education seminars for financial advisors, CPAs, human resources professionals and other retirement and financial industry participants + Each seminar qualifies for one credit hour of continuing education (CE) credit + Live, in-person, on-demand and webcast options available + Available for CFP, CIMA, CPWA, CRPC, CRPS, CRC, AIF, CPA, HR and CEBS designations 50

51 Janus Henderson Additional Support Experience in: + Fiduciary Responsibility + Wealth Management + Industry Trends + Legislative and Regulatory Updates DEFINED CONTRIBUTION & WEALTH ADVISOR GROUP WESTERN U.S. CENTRAL U.S. EASTERN U.S. SOUTHERN U.S. Taylor Pluss, APMA SM, CRPS, CDFA Retirement Director taylor.pluss@janushenderson.com (303) Eric Magyar, AIF Retirement Director eric.magyar@janushenderson.com (312) Ruben Gonzalez Senior Retirement Director ruben.gonzalez@janushenderson.com (917) Mike Malinsky, CRPS, CRPC Senior Retirement Director mike.malinsky@janushenderson.com (303) NATIONAL SUPPORT INTERNAL SUPPORT INTERNAL SUPPORT Matthew Sommer, CFP, CPWA, CFA Vice President and Director matthew.sommer@janushenderson.com (303) Benjamin Rizzuto, CFS Retirement Director benjamin.rizzuto@janushenderson.com (303) Marquette Payton Assistant Retirement Director marquette.payton@janushenderson.com (303)

52 Janus Henderson About the Author Matt Sommer, CFP, CPWA, CFA Vice President, Retirement Strategy Group Matt Sommer is Vice President and leads the Defined Contribution and Wealth Advisor Services team at Janus Henderson. In this role, he provides advice and consultation to financial advisors surrounding some of today s most complex retirement issues. His expertise covers a number of areas including regulatory and legislative trends, practitioner best practices, and financial and retirement planning strategies for HNW clients. Prior to joining Janus Henderson, Matt spent 17 years at Morgan Stanley and its predecessors. Matt held a number of senior management positions including Director of Financial Planning at Citi Global Wealth Management and Director of Retirement Planning at Smith Barney. Mr. Sommer received his undergraduate degree in Finance from the University of Rhode Island and received a Masters of Business Administration with a specialization in Finance from the Lubin School of Business at Pace University. Mr. Sommer currently serves on the CPWA examination task force, is an adjunct professor at the College for Financial Planning of CFP and CRPS programs, and teaches graduate level advanced finance classes. He is also a PhD candidate at Kansas State. 52

53 For more information, please contact your financial advisor or visit janushenderson.com. The information contained herein is for educational purposes only and should not be construed as financial, legal or tax advice. Circumstances may change over time so it may be appropriate to evaluate strategy with the assistance of a professional advisor. Federal and state laws and regulations are complex and subject to change. Laws of a particular state or laws that may be applicable to a particular situation may have an impact on the applicability, accuracy, or completeness of the information provided. Janus Henderson does not have information related to and does not review or verify particular financial or tax situations, and is not liable for use of, or any position taken in reliance on, such information. A retirement account should be considered a long-term investment. Retirement accounts generally have expenses and account fees, which may impact the value of the account. Non-qualified withdrawals may be subject to taxes and penalties. For more detailed information about taxes, consult a tax attorney or accountant for advice. In preparing this document, Janus Henderson has relied upon and assumed, without independent verification, the accuracy and completeness of all information available from public sources. Janus Henderson is a trademark of Janus Henderson Investors. Janus Henderson Investors. The name Janus Henderson Investors includes HGI Group Limited, Henderson Global Investors (Brand Management) Sarl and Janus International Holding LLC. C