Effective Tools and Strategies When Planning for an Individual with Special Needs

Transcription

1 1 Legal Expert R. Shawn Majette, JD ThompsonMcMullan, P.C. Financial Planning Expert H. Mark Friese Menick Friese Phillips Bock Group Private Wealth Management Merrill Lynch & Co. Effective Tools and Strategies When Planning for an Individual with Special Needs Pooled Special Needs Trust Expert Joanne Marcus, MSW Executive Director Commonwealth Community Trust Hosted by:

2 Legal Aspects of Trust Planning for Special Needs Prepared by R. Shawn Majette, VSB ThompsonMcMullan Professional Corporation 100 Shockoe Slip Richmond, Virginia / (V) 804/ (F) Copyright, All rights reserved. R. Shawn Majette No copyright is claimed as to governmental source material. Image: Mr. Pernelet and his peculiar hobby. To the average mind, the crocodile is symbolic of everything hideous, hypocritical and unmanageable. One has read so often of a pair of glittering eyes, seeing but unseen, a sudden sweep, and a human being dragged from the ken of man, that it is impossible to disassociate the crocodile from all that is revolting. Yet it happened that two directors... travelling the Continent in search of novelties, happened to hear of M. Pernelet and his peculiar hobby. E. Charles, The Windsor Magazine, 1902.

3 What are "Special" Needs In the Context of Trusts? Needs caused by physical or mental infirmities which create the need for supplemental assistance and protection for a person incapable of fending for himself. In today's presentation for trust planning, we include needs brought about by substance abuse, excessive debt, lack of employment, and just plain bad luck even when SSI and Medicaid are not in the picture.

4 Beginning at the beginning: what is a trust? Trusts have these characteristics and objectives. Characteristics. Ownership by Trustee. All trusts hold property in the name of a trustee, who owns legal title to the property. Settled, predictable body of law. Virginia Uniform Trust Act. Social Security POMS for SSI. Virginia Administrative Code and Medicaid Manual for Medicaid. Objectives. Exclusion from government programs definition of "resources." Property management (investment, sale, rental). Property protection (from some creditors). Property transfers at death to avoid probate.

5 The Characters in Trusts. Settlor. The settlor creates the trust and in some cases contributes property to a trust. Trustee. The trustee is the owner of the trust property and must use it according to the terms of a trust. Beneficiary. The beneficiary of a trust is the person who has a present or future interest in the trust property, or who has a power to direct ("appoint") the trust property to someone else.

6 Basic details. When and how created. While alive - a living trust. After death - created in a will ("testamentary trust"). Revocable or not. A living trust can be revocable or irrevocable. A testamentary trust cannot be revoked.

7 Kissing Cousins: What a trust isn't. Power of attorney. An adult "principal" appoints someone else, the "agent," to manage the adult's assets. Conservatorship. A judge appoints a conservator to manage assets of an incapacitated adult in a lawsuit. In both cases, legal title to the managed assets remains in the owner (the principal or the incapacitated adult).

8 The Special Needs Trust. A special needs trust is a trust in which the Trustee as owner of the property has virtually complete discretion whether to distribute trust property (or income generated from trust property) to the beneficiary. Since the trustee cannot be compelled to distribute from the trust, the assets are not counted for Medicaid or SSI purposes while in the trust, and distributions made from the trust can be made to supplement but not replace SSI and Medicaid.

9 General Uses. Medicaid and SSI eligibility. Medicaid and SSI are closely related but have different sources of law and policy. The trusts discussed in this presentation generally apply for each, but there are some differences in the details when both SSI and Medicaid are at issue. Protecting the beneficiary from his creditors. Preserving statutory exemptions for personal injury and Virginia Workers Compensation awards. Protecting the prodigal beneficiary from himself and his "friends." The compulsive or addicted beneficiary (think of alcohol, drugs, and credit cards) The beneficiary's significant others (think of your neighbor's son-in-law, who still has your hedge clippers).

10 Examples of Trust Expenditures. Housing (with exceptions); Transportation (car purchase, insurance, maintenance, etc.); Final expenses (burial, cremation); Communications (telephone expense); Non Medicaid covered medical and dental care; Social services case management and companion care; Entertainment and travel; and Clothing and personal care items.

11 Types of Special Needs Trusts. The type is dependent upon whose assets fund the trust. First party. Mr. A. creates a trust and transfers Mr. A.'s assets to the trustee for the benefit (sometimes at Mr. A.'s death) of Mr. A himself. Third party. Mr. A. creates a trust and transfers Mr. A.'s assets to the trustee for the benefit (sometimes at Mr. A.'s death) of a beneficiary other than Mr. A. (often his disabled child, sibling or spouse).

12 General rules. Medicaid and SSI. Mr. A. can dispose of his property anyway he wants to if he doesn't need SSI or Medicaid for himself or his spouse. Mr. A. can only dispose of his property in highly regulated ways if he or his spouse are receiving (or will within three or five years need to receive) SSI or Medicaid payment for long term care. Creditor avoidance. First party trusts cannot generally be used to avoid paying your bills. Mr. A. cannot give his general assets to a trustee to defraud or hinder his lawful creditors. However, Mr. A. may transfer assets to a "qualified" first party trust and retain an interest which will not be available to his creditors. Virginia Code , Self-settled spendthrift trusts. Third party trusts can and usually should be used for creditor avoidance. Mr. A., father of brain injured Son, may create a trust for Son with Mr. A.'s assets that will be completely exempt from Son's creditors.

13 The Medicaid (and SSI) Third Party Trust. Mr. A.'s assets for someone other than Mr. A. or Mrs. A. who is receiving or likely to need Medicaid or SSI. Typical uses are for parents and grandparents of special needs descendants, and for disabled nephews, nieces, etc., of childless persons.

14 Third Party Trust Examples. Created During Lifetime: Mr. A. today creates & funds with his assets a trust for his benefit during his lifetime, continuing at his death for brain injured Son, with what's left at Son's death (the "remainder") passing to Son's children, or Son's widow, or Mr. A.'s widow (if then alive), or anyone / anything else. Warning for this example when Mr. A. is married: Mr. A. (or Mrs. A.) may need Medicaid long term care or SSI within 60 months (Medicaid) or 36 months (SSI) of funding such a trust. An irrevocable trust funded with Mr. or Mrs. A's assets could cause Mr. A. or Mrs. A. to lose such benefits. Mr. A. can authorize his agent under a power of attorney to create, fund, or amend the trust during his lifetime. The power of attorney cannot be used to make or change Mr. A.'s will. Created at Death: Same, except Mr. A.'s will creates the trust with assets in his estate at his death in his will. Can be for Mr. A.'s spouse (or anyone else). Mr. A. must consider Mrs. A.'s statutory "elective share" rights as Medicaid traps if she needs Medicaid (or SSI).

15 The First Party "payback" trust. Using Mr. A.'s assets for Mr. A., a Medicaid (or SSI) recipient. Elements common to successful First Party trusts. Always a living trust. Mr. A. cannot be the trustee. Mr. A. must be disabled as defined by Social Security rules. Mr. A. must be under 65 years of age when transfers are made into the trust. Medicaid penalty for long term care possible for transferor into the trust if transfer is made when Mr. A. is 65 or older. Anyone can transfer assets to the trustee for the benefit of Mr. A. BUT Mr. A. must be under 65 when the assets are transferred to avoid a penalty for the transferor of the asset. When Mr. A. dies, assets can be passed on to anyone else (or used for anything else) only after Medicaid or a designee has been reimbursed for all expenses it has paid (the "payback " or "pay-over" trusts) for Mr. A.

16 Two Types Of First Party Trusts. Individual and Pooled

17 Individual Trust Individual trust (Mr. A. transfers assets to a trustee only for Mr. A.'s benefit), 42 USC 1396p(d)(4)(A). Statutory settlors are limited to parent, grandparent, court, or guardian for beneficiary. Anyone may contribute assets to the trustee without penalty when the disabled beneficiary is under 65 at the time of the transfer. Useful for multi-generational transfers for disabled beneficiary because anyone (including parents in law, etc.) can transfer assets to achieve Medicaid eligibility while preserving eligibility for beneficiary.

18 Pooled Trust Pooled trust (like the Commonwealth Community Trust), 42 USC 1396p(d)(4)(C). Mr. A. transfers assets to a trustee of a trust which pools assets of many people with separate accounts for each, including Mr. A. Requirements for the pooled trust. The trust must be established and managed by a non-profit association. A separate account is maintained for each beneficiary of the trust while the trust pools the accounts for investment and management Accounts in the trust are established solely for the benefit of disabled individuals by the parent, grandparent, or legal guardian of such individuals, by such individuals or by a court. The placement of an individual s funds into a pooled trust when the individual is age 65 years or older must be evaluated as an uncompensated transfer, if the trust is structured such that the individual irrevocably gives up ownership of funds placed in the trusts. A trust established for a disabled individual under age 65 years is exempt from the transfer of assets provisions. However, any funds placed in the trust after the individual turns 65 must be evaluated as an asset transfer. To the extent that amounts remaining in the beneficiary's account upon the death of the beneficiary are not retained by the trust, the trust pays to the State from such remaining amounts in the account an amount equal to the total amount of medical assistance paid on behalf of the beneficiary under the State Plan.

19 Ancillary / Companion Documents and Proceedings For Competent Adults. Power of Attorney. Gifting powers and trust creation, amendment and funding powers. Advance Medical Directive (Health Care Power Of Attorney). General. Protest. A protest (or "psychiatric") advance medical directive is useful when impaired person requires but refuses medical care, especially psychiatric care. Lacking a protest advance medical directive (or a complex guardianship order) may require a civil commitment proceeding in order to secure necessary treatment. Living trust(s). Revocable living trust. Include "pour back" for impaired surviving spouse. Include contingent trust for each special needs beneficiary. Authorize asset transfers to a first party trust (pooled or individual) for the benefit of the settlor and identified beneficiaries).

20 Court Proceedings for Mentally Impaired Adults. Conservatorship to manage property and create first part special needs trust. Helpful for day to day management of income and other property. Direct proceeding to create special needs trust (new, 2016, Virginia Code (B)). Guardianship to manage health care and living arrangements. Involuntary admissions for mental health care and treatment.

21 Anticipating Transitions: Minor Beneficiaries. Impaired child turning 18. A parent or guardian of a minor (or anyone when neither is living) may petition the circuit court to appoint a conservator or guardian within the six months before the minor's eighteenth birthday. However, when the impaired person is a minor and there is a living parent or guardian, anyone other than the parent or guardian may file no earlier than the respondent's eighteenth birthday. Virginia Code Aging or dying conservator or caretakers of incapacitated person. The circuit court may appoint a standby guardian or conservator of an incapacitated adult. The standby can immediately assume his duties upon the death or judicial declaration of incapacity of the last surviving parent, child, or legal guardian of the incapacitated adult. Virginia Code

22 Further Resources. See for direct links to source material regarding: Civil Commitment and Judicial Consent to Treatment (INCLUDING FORMS) Elder Law Resources, Statutes and Assorted Legal Links Guardianship SSA and SSI See for: Medicaid Mental Health Guardianship A Few Words About Making Medical Decisions For Someone Else (Behavioral Health) (2016). Reverse Mortgages (Annual Legal Aid Conference) (2014). Virginia Surrogate Medical Consent (2014). Checklist for Directives (Virginia State Bar). Standard Advance Medical Directive (Virginia Hospital & Healthcare Association Form). Psychiatric Protest Advance Directive (Virginia Hospital & Healthcare Association Form). The Taming of Crocodiles: M. Pernelet and His Strange Hobby, E. Charles, The Windsor Magazine, Volume 16, June-November, 1902, p

23 Dispensing Dainties

24 Funding a Third-Party Special Needs Trust Presenter: H. Mark Friese Menick Friese Phillips Bock Group Private Wealth Management Merrill Lynch & Co.

25 Pressing questions Who will take care of and watch over our child after we are no longer able to do so? Will there be adequate financial resources to maintain a decent quality of life for our child? What will happen when schooling ends or when our child turns 18?

26 Teamwork approach Social Services Groups Estate Planning Specialists Parents / Guardians Merrill Lynch Financial Advisor Financial Solutions Insurance Specialists Special Needs Trust Attorney Trust Specialists Trust services are offered by Merrill Lynch Trust Company, a division of Bank of America, N.A.

27 Assessing your situation SPECIAL NEEDS OF LOVED ONE FINANCIAL SECURITY FOR YOUR FAMILY FINANCIAL SOLUTIONS Basic financial strategy Lifestyle Estate planning services Portfolio management Family protection Liability management Tools and resources Special Needs Planning Workbook: Special Needs Calculator worksheet (pages 14 and 15) Special Needs Calculator ( specialneeds)

28 Do I have an appropriate retirement plan? Essential steps Have I provided for my special needs child if either I or my spouse were to die prematurely? Do my current financial strategies meet the needs of my other children? Are my beneficiary designations set up correctly? How can I calculate the future needs of my special needs child? The Special Needs Group can help you consider how to meet your own financial needs while still providing for your family s future, and may also suggest some flexible strategies for you to consider. One way that the Special Needs Group can help is by working with you and your personal tax professional to assess which strategies may be appropriate for your family s needs. For example, while tax-deferred retirement plans are designed to help put your money to work more efficiently, they also carry additional taxes for early withdrawals. This may pose a problem for the parents of a child with special needs, who may need the kind of liquidity for educational and medical expenses that only a taxable account can generally provide. The Special Needs Group can get you the right answers.

29 Funding a Trust How much will my special need family member need in financial support when I m gone? What are the options to fund this need? 5% RULE Finding additional assets. The Special Needs Group can get you the right answers.

30 Asset Protection Parents working to save enough money to guard their child s future financial security and quality of life must also put the proper protections in place to avoid endangering their son or daughter s eligibility for Medicaid, Supplemental Security Income or the U.S. Department of Housing and Urban Development (HUD) housing program. In most cases, a special needs trust can allow your child to benefit from supplemental funds placed in the trust while remaining eligible for public benefits programs. Your attorney can guide you through the process of establishing a special needs trust and can explain to you some of the nuances of the investing rules associated with these trusts. The Special Needs Group can help you to implement investment strategies for the assets placed in the trust. The Special Needs Group can help provide professional referrals for asset protection guidance.

31 Avoiding Common Mistakes If you also have children who do not have special needs, you may choose to work with your estate attorney to include them in your legacy planning. While every situation is unique, creating an estate plan that protects all your family members can present challenges that are best addressed with the help of your specially trained attorney and The Special Needs Group. In the absence of professional guidance, poorly planned estate-planning strategies may yield unintended consequences, including the loss of financial or personal support for the child with special needs. The Special Needs Group helps educate the family and extended family.

32 Possible Strategies and Solutions Knowledgeable attorneys along with the Special Needs Group can help families avoid these consequences and find strategies suitable for all their estateplanning goals. Often the solution involves a fairer and more equitable distribution of the assets between the child with special needs and his or her siblings. For example, life insurance held inside a special needs trust can be used to help provide financial security for the child with special needs, while the family s assets are passed on to the other children. With your team of professionals guiding you through the special needs planning process, you can find solutions that work for your whole family. The Special Needs Group provides practical and comprehensive solutions.

33 Holistic Family Planning Consider that some parents decide to leave all their assets to their child with special needs. This can cause resentment in the other children and lead to possible estrangement between siblings. As a result, the child with a disability may be left without an important source of emotional support. On the other hand, some parents decide to leave all their assets to a son or daughter without a disability and expect him or her to care for the child with special needs. This type of arrangement can present difficulties because it is not legally binding and may be ignored or interrupted due to lack of interest, conflicting needs or the loss of assets in a divorce or lawsuit. The Special Needs Group takes a holistic view of your specific situation.

34 Balance Your discussions with the Special Needs Group, and a specially trained attorney will address estate-planning issues related to your special needs child early on. Planning ahead can also help you build a strategy that will bring all your family s needs into balance. The Special Needs Group can coordinate your team.

35 About Us Over 50 years of experience helping families plan and reach their financial goals. World Class planning and research tools. Unparalleled dedication to client service and satisfaction. Dedication to the Special Needs Community. Personal experience. The Special Needs Group has the experience, referral sources and tools to help.

36 36 Pooled Special Needs Trusts: Preserving Assets for the Benefit of Individuals with Special Needs Presenter: Joanne Marcus, MSW Executive Director Commonwealth Community Trust (CCT) *The information provided in CCT s portion of the presentation are the property of Commonwealth Community Trust and should not be copied without its permission.

37 37 What is a Pooled Special Needs Trust (PSNT)? Administered by a nonprofit organization that is governed by a board of directors Set up for the benefit of the beneficiary who has special needs and is administered by the nonprofit so that the Beneficiary does not have control of the funds Funds (cash assets only) are grouped together / pooled for investment purposes and each Beneficiary has his/her own sub account Funds professionally managed The fiduciary for CCT is The Trust Company of Virginia (TCVA) Provides SSI and Medicaid benefits protection as funds in the PSNT are not countable assets Also for a beneficiary who does not receive SSI or Medicaid but who would benefit from the services of a trust administrator.

38 38 Responsibilities of the PSNT Administrator Review and approve disbursements Income and principal is to be distributed for the Beneficiary at the sole discretion of the trust administrator Management and investment of trust funds Reports to Social Security Administration and Medicaid Financial statements provided online or by mail to Trust Advocate(s) Annually distribution of Schedule K-1 tax form for each Beneficiary s sub account Court qualification and court accounting,, when required

39 39 Best-Practices Criteria for Reviewing Disbursement Requests Whether the request is prudent Whether the request would jeopardize benefits (SSI and Medicaid) Whether the request is for the sole benefit of the Beneficiary which is most important for SSI and Medicaid recipients Whether the request is consistent with the intent of the Grantor, when appropriate

40 40 Benefits of a Pooled Special Needs Trust Professional trust administrator with expertise in Medicaid/SSI benefits protections and the rules that govern trusts Objectivity and oversight to ensure funds are properly spent and managed for the benefit of the Beneficiary Affordable, comprehensive services with low trust administration and investment fees Accounts can be small or quite large and all will benefit from having the funds pooled for investment purposes Experience working with individuals with special needs and their representatives (family members, attorneys, legal guardians, caseworkers, power of attorney, etc.)

41 41 Two Types of Pooled Special Needs Trust Third-Party PSNT* Grantor can be a parent, family member or third-party individual(s). Funds from family member(s) or friend(s) for the Benefit of the Beneficiary in Estate Plans, Life Insurance Policy, Investments, Retirement Accounts or other assets. Revocable or Irrevocable NOT subject to Medicaid payback No Age Limitation First-Party PSNT Grantor can be the Beneficiary, the Beneficiary s Guardian, parent, or grandparent, or Court. Funds belong to the Beneficiary, usually from a personal injury or workers compensation award, direct inheritance, the beneficiary s own funds or Social Security back payment. Irrevocable Subject to Medicaid payback Age Limitation: A transfer of assets penalty may apply if the Beneficiary is 65 years old or older (varies by state).

42 42 Costs / Fees PSNT have lower fees when compared to most other financial institutions and professional trustee options. Banks or financial firms often require accounts to have a minimum of $300,000- $500,000 for an individual special needs trust and may have higher ongoing administration and investment fees. THIRD-PARTY PSNT CCT Enrollment Fee $850 FIRST-PARTY PSNT $1,250 For trusts funded with >$10,000 $550 For trusts funded with <$10,000 CCT Ongoing Administration and Investment Fees 0.84% annually 0.84% annually Funding Requirements $5,000 or greater $5,000 or greater Fee Schedules Third-Party PSNT Fee Schedule First-Party PSNT Fee Schedule

43 Examples of How the Trust Can be Used Medication and Devices: The trust can provide funds for prescription and nonprescription medication not paid for by Medicaid, eye glasses, hearing aids, prosthetic devices, and expenses for maintenance of these devices. Medical Services: The trust can provide funds for services that are not paid for by Medicaid such as dental care, eye exams, and hearing exams. Assistive Technology: The trust can provide funds for technology such as ipads, computers, and Text-to-Speech (TTS) or speech synthesizers. Education: The trust can provide funds for vocational training and educational expenses such as tuition, books, supplies, computers, and software and training in their use. Vehicle: The trust can provide funds for the purchase of a car (typically titled in the name of the Beneficiary). A lien will be required by the Trust Administrator on the vehicle at the time of purchase. Housing: The trust can provide funds for the purchase of a home under certain circumstances. Home Modifications: The trust can provide funds for home modifications such as ramps and rails to accommodate the Beneficiary, and similar items or expenses. Home Repairs and Upkeep: The trust can provide funds for housecleaning services, lawn cutting, household cleaning items, and paper products.

44 Examples of How the Trust Can be Used Clothing: The trust can provide funds for the Beneficiary s clothing, including for work or school. Household Bills: The trust can provide funds for phone, cable, and internet service bills; car and renters insurance; and storage units. Care Providers: The trust can provide funds for skilled nursing care providers, companion services, and travel companions if the Beneficiary requires assistance due to a medical condition or disability. Vacations: The trust can provide funds for travelling, including food and shelter expenses, if the Beneficiary will be away from home temporarily. It can also pay for a caregiver to accompany the Beneficiary with a doctor s recommendation. Family Travel: The trust can also provide funds for a family member or Advocate to visit a Beneficiary in a long-term care facility for the purpose of supervising their medical care and living arrangements. Mileage: The trust can reimburse for mileage to medical visits, school, and work while the Beneficiary is in the car. Pre-Need Burial and Funeral Expenses: The trust can provide funds for a prepaid burial or funerary arrangement as long as payment is made before the death of the Beneficiary. Case Manager: The Trust can provide for an assessment of the Beneficiary s needs and living conditions.

45 45 Disbursement Procedure Payment Request Form Payable to: Vendors Advocate for approved reimbursements No cash payments to a Beneficiary who receives SSI/Medicaid as it would jeopardize benefits. Required signatures by Trust Advocate Commonwealth Community Trust Turnaround time for disbursements is 2 weeks or less No limit on the number of disbursement requests in a given time period Credit Card option

46 46 Burial Arrangements It is important that burial arrangements be made and paid for before the Trust Beneficiary s death. These arrangement must meet certain requirements, including that the funds must be paid irrevocably to the funeral director. A burial reserve account (no funds actually paid) does not meet this requirement and is a countable resource for SSI purposes.

47 47 Remainder Policy for Third-Party PSNT: How are funds distributed upon the death of the Trust Beneficiary? Remember: A Third-Party Pooled Special Needs Trust is NOT subject to Medicaid payback. Some PSNT nonprofit organizations maintain all of the remainder or a percentage. CCT s Remainder Policy for the Third-Party Pooled Special Needs Trust CCT does not retain any portion of remainder funds from a Third-Party PSNT after normal administrative fees are deducted in the closing of the trust account. CCT distributes remaining funds from a Third-Party PSNT to the designated successor beneficiaries who are named on the Joinder Agreement according to the stated percentages.

48 48 Remainder Policy for First-Party PSNT: How are funds distributed upon the death of the Trust Beneficiary? Remember: Funds remaining in a First-Party PSNT after the death of a Beneficiary are subject to Medicaid payback in the amount of Medicaid benefits received. The rules may vary by state, but in general, the trust will reimburse Medicaid in each state where the Beneficiary has received services. Some PSNT nonprofit organizations keep the remainder or retain a percentage of the remainder, and do not make a repayment to Medicaid. CCT s Remainder Policy for the First-Party Pooled Special Needs Trust CCT does not retain any funds prior to Medicaid Payback. Remainder after Medicaid Payback is distributed to the designated successor beneficiaries who are named on the Joinder Agreement according to the stated percentages. If the Grantor chooses on the Joinder, or if Medicaid Payback is greater than the remaining funds in the trust, the remainder is held by the CCT to use for other people with disabilities.

49 49 Documents to Establish a Pooled Special Needs Trust 1. Joinder Agreement Legal document required to join 2. Fee Schedule Includes the enrollment, ongoing administration/investment and other fees 3. Family and Beneficiary Information (Letter of Intent) Though not required, this can be helpful to the PSNT administrator. All Enrollment Documents (Joinder Agreements, Fee Schedules, Attorney Checklists) and the CCT Master Trust Agreements are available on the CCT website.

50 50 About Commonwealth Community Trust (CCT) 26+ years experience 1,200+ Trust Beneficiaries served Nationwide Administers $42.5 Million in funded trusts The majority of Third-Party PSNTs with CCT are a part of Grantors estate plans and wills and therefore, unfunded at this time. Affordable Fees Collaborates with attorneys, families, financial planners, beneficiaries, and other stakeholders Active and involved Board of Directors Comprised of parents who have a son or daughter with a disability, estate planning, elder law, personal injury and workers compensation attorneys, physicians, accountants, financial planners, and leaders in for-profit, non-profit and government sectors. Informative and user-friendly website

51 51 Questions? R. Shawn Majette, JD ThompsonMcMullan, P.C (V) H. Mark Friese Menick Friese Phillips Bock Group Private Wealth Management Merrill Lynch & Co. T Toll Free Mark_Friese@ml.com Joanne Marcus, MSW Executive Director Commonwealth Community Trust (CCT) (804) jmarcus@trustcct.org