| RIAs, whether registered at the state level or SEC level, are welcome to discuss and represent their client’s interests in SummitPlan™. Denali Fiduciary Management wishes to be clear in stating that SummitPlan™ will represent a change in services historically provided to your client. Investment advisory fees charged to plans or plan sponsors reflect this fact. Note that some services you may normally be accustomed to providing to your client are now automatically included in SummitPlan™.
DFM will execute a registered investment advisory agreement with each SummitPlan™ client so that DFM can charge its fee for the delivery of the Fiduciary Audit® Protection Program, Fiduciary Assistance & Compliance Systems© components and additional consulting/support services to the client.
To review, here are some of the services/features incorporated into SummitPlan™:
Plan Design:
The SummitPlan will cover a number of defined contribution plan designs as long as the plans are qualified under Sections 401(a) and/or 401(k). SummitPlan™ is only for ERISA plans. Your client will be required to adopt our plan document. To verify that your client’s format falls within our design options, please contact one of our DFM consultants.
Operational Compliance:
SummitPlan™ contains the Fiduciary Audit® Protection Program developed by Jeffery Mamorsky of Greenberg, Traurig LLP in New York. This program is a comprehensive operational audit and compliance process already reviewed by the U.S. Department of Labor for accuracy and completeness. Denali, in conjunction with both the plan sponsor and the record keeping services provider, will both install and monitor the client’s adherence to the operational audit process to ensure the highest level of operational compliance and fiduciary protection. This level of compliance is particularly important should your client currently be subject to the internal controls requirements of the Sarbanes-Oxley Act or be using the standards as a measure for operation. Installation of the operational review system satisfies the Sarbanes-Oxley internal controls requirements of Sections 404 and 302. The Program is also designed to satisfy the internal controls requirements for auditing of all company plans (public and private) as part of the form 5500 filing. Denali professionals and Greenberg, Traurig LLP will monitor the plan sponsor’s operational compliance. Greenberg, Traurig will certify the plan as operationally compliant once the Program is fully installed. Annual re-certification is required for SOX and form 5500 requirements.
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Fiduciary Governance Process and ERISA Statutory Monitoring:
SummitPlan™ includes the Fiduciary Assistance & Compliance Systems©, a comprehensive documentation and process solution for fiduciary governance. This system includes many certifications and disclosures. Denali staff will continuously monitor the plan sponsor’s implementation and use of the documentation process to ensure comprehensive documentation, completion of statutory ERISA monitoring functions, and plan operations managed to the highest governance standards. SummitPlan™ and Denali professionals will handle the documentation and fiduciary process.
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Investment Monitoring:
Low cost indexing investing and risk managed portfolios form the backbone of the SummitPlanÔ investment menu. These portfolios are managed for both performance and risk. This, in combination with deep fiduciary processes reduces exposure to liability for plan fiduciaries and promotes the long-term interests of plan participants.
Monthly client investment reporting will be provided by Denali.
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Plan Sponsor Retirement Plan Committee Meetings:
To ensure that all fiduciary operational and governance processes are being completed by the plan sponsor, Denali professional staff will attend plan sponsor retirement plan committee meetings.
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Employee Education:
Denali, and SummitPlan™, do not anticipate providing on site employee communication or investment education services. ERISA-required communications (SPDs/SARs/investment materials/quarterly statements and the necessary enrollment forms) will be provided in written and Internet-based formats. Denali has structured and priced SummitPlan™ in this manner for a specific reason – we believe employee communications that attempt to train the average employee to manage a portfolio have failed. This education failure has now been well documented.
A number of portfolios are available in SummitPlan™. However, Denali believes that employees should only make one investment-related decision: “How much risk do I want to take?”. Aside from the decision to participate in the plan, the answer to that risk question is the only investment decision that should be made by employees. All other investment management decisions are left to the investment professionals providing SummitPlanÔ’s risk managed portfolios. Employees will essentially “outsource” their investment-related decisions to highly skilled professionals. Denali believes this process will provide employees with the best opportunities for retirement accumulation.
Should your client wish to conduct a more extensive, multi-location education campaign (e.g., one that addresses why one should participate and when participation is appropriate, etc.), we encourage you to include these services to the client and charge accordingly.
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