New FAQs Provide Participant Fee Disclosure Guidance. Next Steps for Plan Sponsors September 2012

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1 New FAQs Provide Participant Fee Disclosure Guidance Next Steps for Plan Sponsors September 2012

2 Table of Contents New FAQs Provide Participant Fee Disclosure Guidance Next Steps for Plan Sponsors 2 Good Faith Reliance 2 Administrative Expense Information 3 Specificity of Disclosure 3 Fees Paid by Revenue Sharing 3 Fees That Reduced Participant Account Balances May Not Be Added to Total Annual Operating Expenses of Plan Investment Funds 3 Designated Investment Alternatives 4 Definition and Status of Designated Investment Manager 4 Closed Investment Alternatives 4 Brokerage Windows 5 Model Portfolios 6 Investment-Related Information 7 Supplemental Blended Benchmarks 7 Available Website Information 7 Glossary of Terms 8 Information Available Upon Request 8 Comparative Format for Investment-Related Information 8 Operating Expenses for Particular Investments 9 Next Steps for Plan Sponsors 10 Resources 11 1

3 New FAQs Provide Participant Fee Disclosure Guidance Next Steps for Plan Sponsors In October 2010, the U.S. Department of Labor (DOL) issued regulations requiring plan administrators to furnish certain information, including plan fee and expense information, to participants and beneficiaries in retirement plans that include participant-directed investment selection. In February 2012, the DOL issued regulations requiring certain covered service providers to furnish specified information to retirement plan fiduciaries. The covered service provider disclosures are structured so that plans are able to comply with their disclosure obligations under the participant-level disclosure regulations. On May 7, 2012, the DOL published additional guidance (Field Assistance Bulletin (FAB) ) addressing frequently asked questions (FAQs) concerning these new disclosure rules. This guidance was revised by the publication of FAB R on July 30, FAB R consists of a series of FAQs that address such topics as the description of administrative expenses, designated investment alternatives, and the form and content of investment-related disclosures and transition rules. By clarifying certain issues, the new guidance provides some assistance to plan sponsors as they prepare to meet their new legal obligation to furnish detailed plan fee and expense information to participants and beneficiaries in covered plans. Covered plans should review the new guidance now to determine if any changes to participant disclosures are required prior to the disclosure deadline (which for calendar year plans is August 30, 2012). Certain open issues remain, and the DOL confirmed that it intends to issue an additional set of FAQs regarding the service provider disclosure rules. Despite the uncertainty around both of the covered service provider and participant-level disclosure regulations, the DOL was not persuaded to extend the compliance deadlines. The FAB confirms that the initial compliance deadline for participant disclosure for calendar year plans remains August 30, 2012, but includes certain additional, albeit limited, relief for good faith reliance. That relief is described in this report and is followed by a summary of the FAB organized as follows: Administrative Expense Information, Designated Investment Alternatives, Investment-Related Information, and Next Steps for Plan Sponsors. Good Faith Reliance In the FAB, the DOL grants certain relief with respect to enforcement of the regulations. For enforcement purposes, the DOL will take into account whether the plan administrator and the service providers acted in good faith based upon a reasonable interpretation of the regulations. If the DOL finds that the plan administrator and the service providers acted with good faith under a reasonable interpretation of the regulations, the DOL will generally view enforcement actions as unnecessary so long as a plan for full future compliance with the regulations is established. The FAB also clarified that the extension of the participant fee disclosure deadline applies to fiduciary disclosures pursuant to ERISA Section 404(c). The 404(c) regulation was amended to require that, in order to qualify for relief, the plan fiduciary must disclose the information required by the new participant fee disclosure rules. In light of the extensions of time that have been granted for the participant fee disclosure, the DOL determined that the deadline for meeting these new requirements as part of the fiduciary s 404(c) 2

4 compliance has also been extended. To obtain relief under 404(c) the fiduciary does not have to furnish the participant fee disclosure information before the extended deadline for participant fee disclosure. Administrative Expense Information Specificity of Disclosure The regulations require that the participant fee disclosure information be written in a manner calculated to be understood by the average plan participant. The FAQs discuss a few scenarios and how fees and services might be described, including in terms of monetary amounts, formulas, percentage of assets, or a per capita charge. The DOL distinguishes between fees that are known and fees that are unknown (e.g., the amount may vary). Although the DOL indicates that the level of specificity required for the description of services and fees is a facts and circumstances determination, the scenarios described in the FAQs contain quite a bit of detail, especially where the amount of applicable fees is not set. There seems to be an implied preference for examples, estimates, and information based upon past experience in the plan. Fees Paid by Revenue Sharing To the extent that revenue sharing payments serve to reduce (or eliminate) a plan s administrative expenses, the revenue sharing mechanism must be explained in the annual disclosure to participants and beneficiaries. The disclosure must include a description of the service(s), the amount or cost of such service(s), and the applicable fee offset arrangement. For quarterly fee disclosure, the specific fees and services paid for by revenue sharing need not be identified nor itemized. However, the disclosure must include a statement that some or all of the plan s administrative expenses are paid indirectly through some or all of the plan s designated investment alternatives. Even if there are no administrative fees that must be disclosed on the quarterly statement, if revenue sharing payments are applied to offset a plan s administrative expenses, the quarterly statement must include a statement to that effect. In certain situations, a plan s administrative expenses need not be included in the disclosures to participants and beneficiaries. One such situation occurs when the plan provisions require that the administrative expenses be paid from plan forfeitures or from the general assets of the plan sponsor. In such an instance, those expenses need not be disclosed. If the plan provisions allow for payment of expenses from the individual accounts held under the plan but, in fact, the individual accounts have never been charged with expenses and the plan sponsor has made a written commitment to use its general assets to pay for any expenses that are not covered by forfeitures, then the expenses need not be disclosed. If the circumstances change and the expenses may be charged to individual accounts, then disclosure would be required. Fees That Reduced Participant Account Balances May Not Be Added to Total Annual Operating Expenses of Plan Investment Funds If an administrative fee reduces the participant s account balance, the plan sponsor (plan administrator) cannot convert such administrative fees and add them to the total annual operating expenses of a plan s investment options. The fee must actually be paid in a way that reduces the rate of return of a plan s designated investment alternatives (e.g., through revenue sharing) in order to be included in the 3

5 determination of the expense ratio for the fund. A fee that directly reduces the participant s account balance must be reflected as an administrative fee on the annual fee disclosure and the quarterly participant fee disclosure. Designated Investment Alternatives Definition and Status of Designated Investment Manager The regulations require that, among other general information that must be disclosed in the annual fee disclosure statement, the plan must identify any designated investment manager. There was initial confusion as to the meaning of the term designated investment manager. Additionally, there was a question as to whether a designated investment manager had to be treated as a designated investment alternative. The FAB clarifies that a designated investment manager is not considered a designated investment alternative for purposes of the regulations. A designated investment manager is an investment manager that is made available by a plan fiduciary to participants and beneficiaries to manage some or all of the assets held in their individual accounts under the plan. If appointed by a participant (or beneficiary), the designated investment manager becomes responsible for the investments made in the individual s account. The regulations do not limit the investment alternatives that a designated investment manager may use, and those alternatives are not necessarily subject to the disclosure rules applicable to designated investment alternatives. A plan might restrict a designated investment manager to choosing from among the designated investment alternatives offered under the plan. In that case, the designated investment alternatives are subject to the applicable designated investment alternative disclosure rules. However, the services of the designated investment manager are not themselves considered to be a separate designated investment alternative, and no separate investment-related disclosure is required for those services. The general disclosure requirements would have to be met. That is, the plan is required to identify the designated investment manager, describe the designated investment manager services and fees (if any) at the plan level, and, at least quarterly, provide a statement of the fees and expenses charged to each individual account for the designated investment manager s services. The plan must also provide a description of the services to which the charges relate to each individual who used the designated investment manager services. Closed Investment Alternatives The FAB clarifies that a plan must provide required investment-related disclosures for a designated investment alternative that has been closed to new investment. Each participant and beneficiary who has an investment in a closed designated investment alternative must continue to be furnished disclosure for that designated investment alternative. Those participants need this information to determine whether to remain in the designated investment alternative or transfer funds out of the closed investment fund. Participants and beneficiaries who do not have an investment in the designated investment alternative that is closed to new investments need not be furnished with the disclosure for that particular designated investment alternative. 4

6 Brokerage Windows Level of Brokerage Window Disclosure The DOL confirmed that disclosure is required under the general plan information requirements of participant fee disclosure. However, the brokerage window is not a designated investment alternative. Therefore, no investment-related disclosure is required for the brokerage window, or the investments offered within the brokerage window, unless an investment option within the brokerage window is a designated investment alternative under the plan. The DOL also addressed the specificity required for any plan arrangement that enables participants and beneficiaries to select investments beyond those designated by the plan (e.g., a brokerage window or self-directed brokerage account, hereinafter a brokerage window ). At a minimum, participants should be given information to understand how the brokerage window works (e.g., how and to whom to give instructions, any account balance requirements, restrictions or limitations on trading, the difference between the brokerage window and the designated investment alternatives, and who to contact with questions). Participants also should be able to understand that individual fees may be charged to their plan accounts or the brokerage window account. The brokerage window disclosure must include a general statement that for some investments there may be start-up, ongoing, or load fees, and directions as to how the participant can obtain an explanation of fees that may be incurred by the purchase of a specific investment. Plans must also inform participants to ask the provider of the window for specific information that the plan administrator may not have. Lastly, participants and beneficiaries must be provided with a statement of the dollar amount of fees and expenses actually charged during the preceding quarter against their individual accounts in connection with the brokerage window. Disclosure of Brokerage Window to All Participants The information that must be disclosed regarding a brokerage window must be provided to all participants, and not merely those individuals who have chosen to use the brokerage window. If the use of a brokerage window is an option that is available under the plan, then the required disclosure must be furnished to all plan participants and beneficiaries. Brokerage Window Fiduciary Issues Initial Brokerage Window Position In the first version of the FAB, the DOL suggested that, in certain circumstances, plan fiduciaries may be required to provide the same investment-related information for investment funds in a brokerage window as they are required to provide for a plan s designated investment alternatives. This position raised several significant concerns for the fiduciaries of participant-directed individual account plans that include a brokerage window. The DOL s initial position (as expressed in FAB ) can be summarized as follows: The failure by plan fiduciaries to designate a manageable number of investment alternatives raises questions as to whether the fiduciaries have satisfied their general fiduciary obligations under ERISA Section 404 (referencing Hecker v. Deere, 569 F. 3d 708 (7 th Cir. 2009)). 5

7 Many plan participants (and beneficiaries) are not financially sophisticated and may need designated investment alternatives to enable them to successfully direct their retirement plan investments. Plan fiduciaries have a general duty of prudence under ERISA Section 404(a) to monitor their retirement plan s investment offerings, including those funds within a brokerage window that are most highly utilized. FAB included a brokerage window safe harbor. A platform that included more than 25 investment alternatives would not be required to treat all of the alternatives as designated investment alternatives if the following two conditions were met: Investment-related disclosures were being provided for at least three alternatives that collectively meet the broad range requirements of ERISA Section 404(c); and Investment-related disclosures would be provided for every other alternative in which at least 1% of the participants and beneficiaries were invested (if the plan has more than 500 participants and beneficiaries), or at least five participants and beneficiaries were invested (if the plan has 500 or fewer participants and beneficiaries). Revised Brokerage Window Position After discussions with the retirement plans community, the DOL issued revised guidance in FAB R, which withdrew Question 30, the particular question that included the safe harbor described above. The revised FAB instead clarified that an investment alternative is a designated investment alternative only if the investment alternative is specifically identified as an available investment under the plan. Further, the revised FAB provides that the fee disclosure regulations do not require plans to offer a specified number of designated investment alternatives. The DOL emphasized that a fiduciary s failure to designate any investment alternatives as a means to avoid compliance with the fee disclosure rules would raise questions under ERISA s general fiduciary duties of loyalty and prudence. The DOL further reminded fiduciaries that ERISA Section 404(a) obligates them (through the same general duties of prudence and loyalty) to evaluate and assess the nature and quality of services that participants receive through any brokerage window that is made available to them. Finally, the DOL stated that it would continue to review how best to assure compliance with the fiduciary obligations associated with brokerage windows, including the possibility of issuing additional future guidance. Model Portfolios The appropriate fee disclosure for a model portfolio will depend upon what that term describes under the particular plan. In some plans, a plan might use the term model portfolio to designate a separate entity that invests in the other designated investment alternatives under the plan. An individual who selects the model portfolio would obtain an equity security, unit participation, or similar interest in the model portfolio entity. In that case, the model portfolio constitutes a separate designated investment alternative for which an investment-related disclosure would be required. Alternatively, if a model portfolio is merely the means an individual can use to allocate account assets among the specific designated investment alternatives in the plan, the model portfolio does not itself constitute a designated investment alternative. The investment-related disclosure for the specific designated investment alternatives must be furnished, but no additional investment-related disclosure is required with respect to the model portfolio. The FAB acknowledges that some plans and service providers 6

8 are able to construct investment-related information for this type of model portfolio (despite the fact that the portfolio is not a separate entity). Under the regulations, additional information is permitted to be included with the required disclosures as long as the additional information is not inaccurate or misleading. The FAB notes that a plan could treat the model portfolio as if it were a designated investment alternative and include the model portfolio information in the comparative chart of investment-related information. Investment-Related Information Supplemental Blended Benchmarks The DOL indicated in the preamble to the participant fee disclosure regulations that it was acceptable to provide supplemental benchmark information for a balanced designated investment alternative using a blend of more than one broad-based securities market index funds. However, the DOL indicated that the blend of the supplemental index had to match the blend of the plan fund, or else the blended benchmark might be inaccurate or misleading. The FAB provides that the plan administrator may use the target asset allocation of the designated investment alternative if the target is representative of the actual holdings of the plan investment option. The DOL anticipates that there may be other acceptable methods of determining whether target percentages are representative of actual holdings. Available Website Information The FAB describes a number of means by which a plan can meet the requirement to provide a website address to participants and beneficiaries for investment information. The plan can use a third-party recordkeeper to establish and maintain the website for the plan. Alternatively, the plan can use the sponsor employer s website if it includes the supplemental investment information and is updated as required. Another alternative for the plan is to use the website of the issuers of the designated investment alternative(s), for instance, the website of the investment platform provider, as long as the address is sufficiently specific to direct the participants and beneficiaries to the required information. A website address does not need to take the participant directly to the supplemental information. It must, however, direct the participant to the required information. The determination of whether the address is sufficiently specific is based on the facts and circumstances. Performance data for the plan s designated investment alternatives must be included in the supplemental investment-related information available on the website and updated on at least a quarterly basis. This means that investment alternatives with variable investment returns must provide one, five, and ten calendar year performance information. For investment alternatives with fixed or stated returns, the website must provide participants with access to the current fixed or stated return and the term of the investment. The information should be updated periodically. It may be different from the information disclosed on the annual fee disclosure statement. 7

9 Additional (supplemental) information, such as the year-to-date returns and returns for the most recent calendar month or quarter, may be included. There is no specific period for which updates must be made, but the information should be accurate and reasonably current. Glossary of Terms The preamble to the final regulations indicated that the DOL was considering whether to offer a general investment glossary. The FAB mentions glossaries submitted by two industry groups, the American Bankers Association and the SPARK Institute together with the Investment Company Institute. However, the DOL does not expressly sanction any specific glossary of terms, nor does it intend to issue a model glossary of terms at this time. The DOL noted that the plans and the issuers of their investment alternatives are in the best position to determine the glossary appropriate for their plan participants in light of the particular investment alternatives offered. Information Available Upon Request Specified investment-related information (e.g., a prospectus) must be furnished, either automatically or upon the request of a participant or beneficiary. The copies furnished must be the latest information available to the plan. For registered investment alternatives (e.g., a mutual fund), a plan can furnish the full prospectus or a summary or short form prospectus. Similar information must be available for unregistered investment alternatives. The DOL states that it anticipates that materials already in existence will serve to meet this regulatory requirement. A written plan as defined under federal banking regulations is mentioned as an example of prospectus-like information for an unregistered investment alternative that is a bank collective fund. To the extent that such materials do not exist, the DOL expects the plan to use the materials that the plan fiduciary relies upon to prudently select and monitor the investment alternative. Comparative Format for Investment-Related Information Multiple Comparative Charts Some plans, particularly 403(b) plans, include investment alternatives from multiple vendors. The question is whether such a plan must combine the information received from each vendor into a single document. The FAQs state that plans can provide multiple charts from different vendors as long as the documents are furnished to participants and beneficiaries at the same time in a single mailing or transmission. It would not be compliant with the regulations to allow each vendor to furnish its own information independently of the other vendors in the plan. Annual Disclosure of Comparative Chart The FAQs confirm that a plan is not required to furnish more than one comparative chart annually for a plan s required investment-related information. To the extent that fee and expense information changes after the issuance of the annual chart, the updated information should be included in the information that is available on the website. Websites must be accurate and updated as soon as reasonably possible after a change. The website should include the date of the most recent update, so that participants and beneficiaries can see how recent the information is. However, certain changes may be so important that the obligations borne by the plan fiduciary require that participants and beneficiaries be notified about the 8

10 changes before the next annual chart is furnished. The FAQs did not include an example illustrating this advance disclosure requirement. The substitution of the plan s investment platform with a new platform might be such a change. In such a case, the ERISA blackout rules may be implicated as well and should be coordinated with the fee disclosure. End-Date for Performance Information Although the regulations speak in terms of investment performance being reported as of the end of a calendar year, a plan may furnish investment results as of the end of a completed calendar month or quarter, if that more recent information is available. To ensure appropriate comparability, however, the same end-date should be used for all of the designated investment alternatives and the associated benchmarks information would have to correspond to the same time period. Since Inception Performance Information A plan is not required to furnish the since inception investment performance data in every case. The goal is to disclose performance data and benchmarks for one, five, and ten calendar year periods. The since inception should be used for any alternative that has not been alive long enough to have performance data for all of those periods. If the plan has data for the one, five, and ten year periods, the since inception data need not be included, although such since inception data may be included for an older fund if that information is not inaccurate or misleading. Operating Expenses for Particular Investments Fund-of-Funds Operating Expenses Operating expenses for a fund-of-funds alternative must include its own operating expenses and proportionally reflect the operating expenses of the component funds. The DOL refers to Securities and Exchange Commission (SEC) guidance for regulated investment funds (i.e., SEC Form N-1A), as well as SEC guidance relating specifically to regulated fund-of-funds. An example of how the operating expenses should be determined is provided. Additionally, the DOL indicates that its goal is to achieve symmetry for the calculation of total annual operating expenses for registered and unregistered funds. Accordingly, the DOL anticipates that unregistered fund-of-funds (or trust-of-trusts) will calculate total annual operating expenses in a similar manner. Timing of Operating Expense Calculations The regulations require a plan to disclose the total annual operating expenses (expense ratio) of an unregistered fund as of the most recently completed fiscal year of such fund, expressed as a percentage of the fund s average net asset value for that year. This does not mean, however, that an unregistered fund should only calculate its expense ratio once per year. As noted, the DOL s goal is to achieve symmetry in the expense ratio calculation for registered and unregistered funds. Registered investment options must calculate net asset value at least monthly. Accordingly, for purposes of calculating the net asset value for an unregistered fund, the expense ratio should be calculated not less frequently than monthly in order to calculate the average net asset value for the year. Separately Managed Account Invested in Single Mutual Fund If a plan designated investment alternative is a separately managed trust account that invests solely in the shares of a registered mutual fund, in which participants acquire units of the investment alternative and not 9

11 mutual fund shares, such a fund is considered an unregistered investment alternative. Accordingly, it must report its expenses as an unregistered fund. If the value of a unit is reduced by plan expenses, with no impact on the number of units owned or the share value of the underlying mutual fund, the fund s total annual operating expenses include the operating expenses of both the unregistered alternative and the plan s general operating expenses. These expenses are reflected in the average annual total return for the unregistered alternative. The FAB also suggests that the website of the mutual fund may not suffice to provide the information required of the unregistered alternative because the rate of return and expense ratio information will differ between the fund prospectus and the plan disclosure. Stable Value Wrap Fees The cost of insurance protection for a stable value fund must be included in the operating expenses of the stable value investment alternative, if such cost reduces the rate of return. The expense calculations in the participant fee disclosure regulations are designed to capture the fees and expenses that reduce the alternative s rate of return. Next Steps for Plan Sponsors The FAB primarily addressed issues applicable to participant fee disclosure. However, the final service provider fee disclosure regulations require that service providers provide the same investment information to responsible plan fiduciaries that the plan fiduciaries must provide to their participants. The service provider fee disclosure deadline was July 1, Plan sponsors should remember that there is a good faith reliance period, and that they may have up to a year to make certain changes based upon this guidance. With that in mind, plan sponsors will want to take the following next steps in light of how the FAB requirements will impact review of service provider disclosures: Confirm receipt of service provider fee disclosures Review service provider fee disclosure for required investment-elated information. If the information is not available at the time service providers make their disclosures, work with providers to insure that the information is available for participant level fee disclosure materials. Review participant disclosure descriptions The DOL has provided a wide variation relating to the detail included in participant explanations. Ultimately, participants need to understand the fees they can pay, and utilize this understanding to manage their plan and investments to their best advantage. With this goal in mind, plan fiduciaries need to strike a balance between the need for clear disclosure and the potential for information overload. This will require consideration of the specific participant demographics of each plan. Review new service agreements Confirm that any new or renewed administrative service agreements provide for investment funds or recordkeepers to timely provide investment-related fee disclosures. Additionally, any amendment or service revision that involved a change to contractual fees or services must be reviewed for fee disclosure compliance. Understand website disclosure Know how the required website information will be provided for all designated investment alternatives (e.g., fund manager website for each fund or plan website provided by plan recordkeepers). Review plan and trust documents Review plan and trust documents to confirm that the terms and conditions relating to any reduction in participant account balances for fees are consistent with the plan practices regarding fees. 10

12 Logistics of disclosure Plan administrators have considerable discretion in furnishing required disclosures. They may be provided as stand-alone documents or along with, or as part of, other documents. The regulations specifically acknowledge that certain disclosures may be furnished as part of the plan s summary plan description or a pension benefit statement. For example, the FAB notes that disclosures that must be made before the date on which a participant or beneficiary can first direct his or her investments may be furnished as part of a new employee s enrollment packet. Consider electronic delivery alternatives Confirm with your counsel or plan consultant what information may be provided under the DOL s electronic delivery of information rules and what information may need to be made available in a paper form. Review 404(c) compliance To the extent that the participant-directed individual account plan relies on ERISA Section 404(c) with respect to its efforts to potentially insulate plan fiduciaries with respect to participant investment elections, review the 404(c) compliance in light of the application of the new participant-level fee discourse requirements. Document self-directed brokerage window The FAB indicates that the decision to maintain a self-directed brokerage window must be prudent. This is not new; however, the FAB indicates a new DOL focus on windows, which may raise interest by litigation attorneys. Having a well-documented process in the selection and maintenance of the brokerage window may be the best defense against potential litigation. Identify designated investment alternatives Inventory all designated investment alternatives and brokerage windows to confirm obligations that may be required, and confirm that participant and investment-related data will be provided by the required investment funds. Develop communication materials/formats Develop communication materials (using DOL model forms, or develop individually designed plan-specific materials) that will provide the required information in a clear and concise manner to plan participants and beneficiaries. Aon Hewitt retirement consultants are available to assist plan sponsors in addressing the new fee disclosure obligations. Resources The DOL FAB R (released July 30, 2012) is available at: The DOL FAB (released May 7, 2012) is available at: The DOL news release on FAB is available at: Previous Aon Hewitt reports: Service Provider Fee Disclosure Rules Now Final: Next Steps for Retirement Plan Fiduciaries (March 2012) DOL Delays Application of New Fee Disclosure Rules (August 2011) Summary of Final Participant Fee Disclosure Regulations (November 2010) 11

13 Contact Information Elizabeth L. Groenewegen Aon Hewitt Legal Consulting and Compliance Thomas W. Meagher Aon Hewitt Legal Consulting and Compliance About Aon Hewitt Aon Hewitt is the global leader in human resource solutions. The company partners with organizations to solve their most complex benefits, talent and related financial challenges, and improve business performance. Aon Hewitt designs, implements, communicates and administers a wide range of human capital, retirement, investment management, health care, compensation and talent management strategies. With more than 29,000 professionals in 90 countries, Aon Hewitt makes the world a better place to work for clients and their employees. For more information on Aon Hewitt, please visit Copyright 2012 Hewitt Associates LLC. This document is intended for general information purposes only and should not be construed as advice or opinions on any specific facts or circumstances. The comments in this summary are based upon Hewitt s preliminary analysis of publicly available information. The content of this document is made available on an as is basis, without warranty of any kind. Hewitt disclaims any legal liability to any person or organization for loss or damage caused by or resulting from any reliance placed on that content. Hewitt reserves all rights to the content of this document. 12