Well and Good LLC
Most Well and Good LLC engagements start with an intensive, hands-on Transition Program.
In two to three hours, you complete a due diligence review and emerge with specific recommended action steps. We consider the program--including an 80-page Fiduciary Resource, all time and materials--an excellent value.
After the Transition Program, some plans feel they can move forward on their own. We have capability to furnish ongoing advisory services at a level that matches your and your plan's needs. You do not have to decide whether to use our ongoing services, nor the intensity level, until after the Transition Program.
We concentrate on sponsors of 403(b) plans. These plans have always been subject to fiduciary standards. However, for many years regulatory enforcement was lax because 403(b) plans could be viewed as a responsibility of each individual participant.
Then the Internal Revenue Service issued its first set of regulations for 403(b) plans in almost fifty years. Employers had to complete a written document by a 12/31/09 IRS deadline.
In 2010, sponsors of 403(b) plans subject to Title 1 of ERISA had to complete a new, longer version Department of Labor Form 5500. Large plans needed to obtain an auditor's opinion on their Form 5500.
These developments signal regulators' intent to hold 403(b) plans to the same fiduciary standards as 401(k) plans. Even plans not subject to ERISA Title 1 -- such as plans of church organizations -- are subject to fiduciary law. Based upon our professional observation and extensive experience, few sponsors of 403(b) plans have in place the kinds of controls or business practices to deal with their plan investment fiduciary responsibility.
The Internal Revenue Service's annual priorities for its Employee Plans sector include "enhance the 403(b) compliance initiative guidance, education and outreach, voluntary compliance and enforcement activities."
- Fiduciary decisions must be made in the best interest of the plan and the participants. Your investment provider (i.e., TIAA-CREF, Fidelity, VALIC) runs a business with its own "bottom line" goals and will not accept decision-making responsibility for your plan.
- The fiduciary must act for the exclusive purpose of providing retirement benefits. Clear, well-written policy statements are almost universally endorsed as a means to meet this responsibility. Relatively few 403(b) plan sponsors have such statements in effect.
- Engage in a prudent process. Ignorance is never an excuse. Fiduciaries who follow a reasoned due diligence monitoring and selection process almost inevitably fulfill their duties.
We take on a fiduciary role to provide a hands-on Transition Program. This quickly gets you "up-to-speed" on plan fiduciary responsibilities, generally, and the investment fiduciary role in particular. The Program includes organizing a plan committee, building policy documents, an initial prudent process and completing a due diligence file. We work with your schedule to complete the Training Program in less than one-half day.
We also provide ongoing plan fiduciary packages. These include investment lineup selection and monitoring, meetings of the plan investment committee, thorough documentation, regular and occasional research reports. We complete a wide range of special projects.
We teach you the same fiduciary best practices used by very large plans. We draw upon experience, industry-leading data and research to generate recommendations for you. We aim to make it simpler for you to be an effective plan fiduciary than "do-it-yourself."
Well and Good does not guarantee principal or investment performance. Plan and participant rates of return will fluctuate based upon the underlying investment portfolios of plan accounts. Client experiences using Well and Good LLC services may vary. This web-site does not furnish investment or any other advice. Before we provide any advisory services to you or your plan, we will furnish you with a Form ADV 2 disclosure statement and we will each need to sign an Investment Advisory Agreement specifying the agreed-upon services and terms.