Pam Devling, FSA, EAVice President

Consulting Actuary

Samuel A. Henson, JDSenior Vice President,

Director of Legislative & Regulatory Affairs

Authors

Retirement Services | Fourth Quarter 2017

The LedgerSUMMARY OF LEGISLATIVE, JUDICIAL AND REGULATORY RETIREMENT NEWS

Lockton Companies

REGULATORY UPDATE

Sample 2017 Form 5500 includes important changes

For the last two years, the IRS included compliance questions on the Form 5500 but, due to regulatory challenges, told plan sponsors to ignore them. Rather than continuing this, the Department of Labor (DOL) has removed them from the 2017 Form 5500 and Schedules.

Other welcomed changes include allowing service providers to sign electronically and a new field for the plan name from the last return if the plan name has changed. Two additional changes are specific to defined benefit plans, including a requirement for plans covered under the Pension Benefit Guaranty Corporation (PBGC) program to enter the related confirmation number, and updated Schedule MB instructions to include codes for the RP-2014 mortality table variants.

Enjoy it while we can. The DOL looks to continue efforts to greatly expand the content and scope of the Form 5500 in future years, a move that will likely result in significant increased time and cost to plan sponsors.

Two percent benefit increase for 2018.

More than 66 million Americans will

receive a 2% increase in their 2018 Social

Security and Supplemental Security

Income monthly benefits, the biggest

increase since a 3.6% rise in 2011.

Lockton Companies

REGULATORY UPDATE

IRS provides guidance on RMDs for missing participants and beneficiaries

In October, the IRS issued internal guidance telling its examiners not to challenge plans for violating required minimum distribution (RMD) standards if the plan has been unable to locate missing participants or beneficiaries and cannot start or make distributions. The steps the IRS expects plans to take when looking for missing people include:

� Searching plan, related plan, employer and publicly available records/directories for alternative contact information.

� Using the following search methods:

z Commercial locator service.

z Credit reporting agency.

z Proprietary Internet search tool for locating individuals.

� Attempting contact through US Postal Service certified mail to the last known address and through appropriate means for other contact information (email addresses and telephone numbers).

Unfortunately, the DOL has not offered its own guidance on steps it would consider reasonable when investigating RMD compliance in an examination. Making matters worse, the DOL has recently taken a very hard-line stance, citing these as both a breach of a sponsor’s fiduciary duty and a prohibited transaction.

It will be critical that the two agencies come together to provide a single standard. Plan sponsors should review their RMD-eligible participants and beneficiaries and ask their service providers how plan services align with the administrative guidelines the IRS outlined.

Lockton Companies

REGULATORY UPDATE

DOL fiduciary rule update

The DOL officially delayed enforcement of the new fiduciary rule until July 1, 2019, giving it more time to review the impact of the regulation on the financial industry and retirement savers. At the end of 2017, the new leader of the DOL’s employee benefits enforcement agency was confirmed by the Senate, and his presence may eventually clear up the uncertain future of this rule. The DOL says it will use the extended time to coordinate with other regulators.

Lockton Companies

REGULATORY UPDATE

GAO’s view on retirement security

An October 2017 US Government Accountability Office (GAO) report evaluated the country’s retirement system. The report’s overarching theme suggests change is needed to protect Americans’ financial security in the coming decades. The report discusses four key areas:

1. The US’s shifting retirement landscape has changed how people will fund retirement. Participants, the report says, over-rely on Social Security, and the complexity of the system makes it difficult to understand. In addition, as employer-sponsored coverage moves from defined benefit (DB) to defined contribution (DC) plans, employees have more responsibility to manage risk and make decisions about retirement funding. This is compounded by the inability of many to save money due to societal demands such as medical costs, education costs and low wage growth.

2. The three primary retirement financing challenges individuals face include access to retirement plans, accumulating sufficient savings and preparing adequately for the income they will need throughout their retirement years.

3. The report emphasizes critical national programs that face insolvency within the next 20 years, including the Social Security Disability Insurance program, PBGC multiemployer plan program, Medicare Hospital Insurance Program, and Social Security Old-Age and Survivors Insurance fund. The eventual demise of any of these programs could cause a ripple effect throughout the economy and create widespread benefit inadequacy. Contributing further to the lack of benefit adequacy is the shortage of savings by employees within and outside employer-sponsored plans.

4. Lastly, the report focuses on the need for change. It indicates that piecemeal approaches in the past have failed and urges Congress to take a more comprehensive view of the issues and steps to improve the system. They identify five goals for any potential system reformation:

z Universal access.

z Ensuring greater adequacy.

z Improving retirement spend-down options.

z Reducing risk and complexity for employers and participants.

z Ensuring the Government’s fiscal sustainability.

Lockton Companies

Defined Benefit

REGULATORY UPDATE

PBGC announces 2018 premiums and limits

The Pension Benefit Guaranty Corporation (PBGC) announced the premium rates applicable for plan years beginning in 2018. Single-employer plan rates increased, as directed in the Bipartisan Budget Act of 2015 (BBA 2015), while multiemployer plan rates remained flat.

2017 2018

Single-employer plan

Per-participant flat-rate premium $69 $74

Variable-rate premium as % of unfunded vested benefits 3.4% 3.8%

Variable-rate premium per participant cap $517 $523

Multiemployer plans

Per participant flat-rate premium $28 $28

Single-employer plan rates will climb again in 2019 due to BBA 2015. Absent the required indexation, flat-rate premiums are scheduled to increase 8%, and variable-rate premiums will increase by 10%. Growing premium levels continue to put pressure on plan sponsors to evaluate pension risk transfer options.

In addition, the PBGC also announced increases in the level of maximum guaranteed benefits it provides for single-employer plan distress terminations. The guarantees vary by age and form of payment but, in general, increased 1% over 2017 levels. Multiemployer plan guarantees vary by years of service and do not increase with indexation from year to year.

Lockton Companies

Defined Benefit

REGULATORY UPDATE

2019 funding mortality revealed

Early in the quarter, the IRS announced the funding mortality assumptions to be used for 2018 plan year single-employer plan valuations. They also announced 2019 plan year assumptions late in the quarter in Notice 2018-02. The tables will impact plan funding requirements, accelerated benefit payment forms, such as lump sums, and PBGC variable-rate premiums. Since certain plan sponsors may delay implementation, for funding purposes, until 2019, the announcement helps determine the ultimate impact of the change.

The update from the 2018 table to 2019 changes the mortality improvement projection scale from MP-2016 to MP-2017. MP-2017 assumes that participants do not live quite as long as anticipated in MP-2016, generally resulting in a slight, less than 1%, reduction in liabilities.

The IRS indicated that it will not necessarily update the mortality assumptions every year, especially if the impact is minimal. However, the advance notice of forthcoming changes will help plan sponsors prepare budgets and plan for funding requirements.

Lockton Companies

Defined Benefit

REGULATORY UPDATE

PBGC 2017 annual report released

The PBGC released its fiscal 2017 annual report. As anticipated, the single employer plan program improved while the multiemployer plan program’s financial position has deteriorated.

($ billions) Single-Employer Program Multiemployer Program

2016 2017 2016 2017

Liabilities $117.9 $117.1 $61.0 $67.3

Assets $97.3 $106.2 $2.2 $2.2

Deficit $20.6 $10.9 $58.8 $65.1

Change $ 9.7 $ (6.3)

The multiemployer program will likely continue to struggle due to the number and size of the plans expected to generate future claims. Prior projections estimate that the multiemployer program will be insolvent by 2025 and the PBGC has focused on the “dire financial condition” of that program. Legislative changes would be required to change the current trajectory.

The report also indicates that the number of standard, single-employer plan terminations increased by over 10% to 1,480 plans in fiscal 2017, the highest level since fiscal 2013.

Defined Benefit

Lockton Companies

REGULATORY UPDATE

PBGC seeks to improve plan sponsor relationships

The PBGC presented several initiatives to improve relationships with plan sponsors this quarter. First, it proposed allowing electronic filing of plan termination filings. Secondly, it offered to consult with plan sponsors considering a plan termination prior to submitting any filings. Such a consultation could help plan sponsors determine whether they meet the distress termination criteria, answer missing participant questions or explore potential filing waivers. Final approval by the Office of Management and Budget (OMB) will be required for implementation.

In a separate effort to improve its relationships with plan sponsors, the PBGC announced the launch of a pilot program to mediate disputes regarding plan termination liability collection and Early Warning Program cases. Participation in the mediation program will be offered on a voluntary basis, and the costs of the mediation will be split evenly between the plan sponsor and the PBGC. Plan sponsors may want to consider use of the program if they are struggling with the PBGC’s financial terms. The pilot will be evaluated after one year to determine its ongoing viability.

Lockton Companies

Defined Benefit

REGULATORY UPDATE

Automatic approval for funding method changes

The IRS issued Revenue Procedure 2017-56 to address when certain valuation changes would be automatically approved. Prior guidance on this topic, in 2000, preceded 2006’s Pension Protection Act (PPA) changes. The new approvals apply for plan years beginning on or after January 1, 2018. Approvals of particular interest include:

� Asset valuation methods can be changed without IRS approval once every five years. Plan sponsors can decide whether to use fair market value when valuing assets or a “smoothed” value up to 24 months and limited to a corridor of 90% – 110% of fair value. A hybrid phase-in of these two methods can be used if the asset valuation determination date is also changing.

� When switching plan actuaries, computation approaches may differ. The IRS specifies that the new actuary must be able to calculate certain liabilities within 3% of the prior valuation amounts for automatic approval. Asset valuations must be within 2% of the prior valuation amounts.

Additional areas addressed include valuation date changes, funding plans through insurance contracts, changes in valuation software or data elements, fully funded terminating plans, and plan mergers.

Lockton Companies

LEGISLATIVE UPDATE

Oregon automatic IRA mandate update

For employers with business in Oregon, the state’s new IRA mandate is marching forward. Called OregonSaves, the plan is a payroll Roth IRA with 5% automatic enrollment and a yearly 1% automatic increase up to 10%. Employees can opt out at any time. Registration began back on October 15, 2017, for employers with 100 or more employees and continues to move forward with the following groups:

An employer that offers a retirement program can apply for an exemption by registering online, but there are deadlines for the application. Any employer with business in Oregon should determine its filing deadline or consider an exemption. The OregonSaves website has a great deal of information should you have questions. As more states like California, Illinois, Maryland and Connecticut follow, compliance with these mandates will become increasingly onerous. There are currently legal challenges to these laws based on the premise that ERISA preempts any state requirement. However, until a court issues an injunction, employers should continue to comply.

OREGONSAVES EMPLOYER REGISTRATION TIMELINE

May 15, 2018 Dec. 15, 2018 May 15, 2019 Nov. 15, 2019 May 15, 2020

WAVE 2: begins AprilEmployers with 50 – 99 employees

WAVE 3: begins Nov.Employers with 20 – 49 employees

WAVE 4:

Employers with 10 – 19 employees

WAVE 5:

Employers with 5 – 9 employees

WAVE 6:

Employers with 4 or fewer employees

Lockton Companies

LEGISLATIVE UPDATE

Five new retirement bills introduced in the House

Bill to Increase Cash-Out Limits — The Retirement Plan Modernization Act is a bipartisan measure seeking to help small businesses manage retirement plan administrative expenses by increasing the automatic IRA rollover limit. Under current law, when a participant is no longer employed and his or her balance is between $1,000 and $5,000, the plan may automatically roll that balance to an IRA. Congress has periodically adjusted the cash-out limit over the years to reflect increasing costs of administration; however, the last update was in 1997. This bill would raise the automatic IRA rollover limit, based on the rate of inflation, from $5,000 to $7,600 and allow for future increases to be indexed for inflation. The update should streamline retirement plan administration and reduce burdens, especially for small businesses.

Bill to Create Federal Retirement Mandate — The Automatic Retirement Plan Act would require most private employers to offer 401(k) or 403(b) plans to most employees over age 21 (including part-time employees who meet service requirements over three years,

but excluding union workers and seasonal and temporary employees). Those that don’t would pay an excise tax. Employers would not be required to contribute to the plan. New plans (those established after the date of enactment) would be required to offer automatic enrollment, starting at 6% of salary and escalating to 10%. (Employees who opt out of the default amount would be automatically enrolled again every three years.) These plans must also use qualified default investment alternatives and make at least 50% of each account’s assets available to participants in a form of distribution that provides guaranteed income for life. The bill would also legalize open multiple employer plans (MEPs) and would restrict the ability of states to mandate automatic IRAs for those employers exempt from this new federal mandate.

Bill to Simplify 401(k)s — The Retirement Plan Simplification and Enhancement Act would create several retirement provisions including:

� There would be no Required Minimum Distributions (RMDs) until an individual’s aggregate retirement balance exceeds $250,000.

� RMD age would increase in steps from age 70½ to age 73 by the year 2029, and increase thereafter.

Lockton Companies

� This would eliminate the current 10% cap on automatically increased deferral rates of employees who are automatically enrolled in a plan.

� It would cover less-than-full-time workers. Employees who work for three consecutive years, with at least 500 hours of service each year, could participate in an employer plan, but would be excluded from coverage, top-heavy and nondiscrimination testing.

� To incent early plan entry, when determining the top-heavy status of any of its plans, employers may exclude participants who do not meet the minimum age and service requirements (age 21 and 1 year of service) if the employer satisfies the top-heavy minimum contribution separately for those participants.

� The DOL, IRS and PBGC must find ways to simplify reporting and disclosure. The legislation directs these entities to study and report to Congress on opportunities to standardize and improve retirement plan reporting and disclosure requirements.

� Some 401(k) plans may delay adoption or amendment of Safe Harbor 401(k) plans. Those that provides a nonelective safe harbor contribution to participants could adopt safe harbor status for a plan year as late as the deadline for distributing excess contributions for such year and without having given a prior-year notice.

� Participants in terminating 403(b) plans could distribute accounts in-kind and still retain their 403(b) account’s tax-deferred status if the 403(b) rules continue to be followed.

� The bill creates a Secure Deferral Arrangement (SDA) that would be exempt from nondiscrimination and top-heavy testing if no other employer contributions are made. Its features include:

z Automatic enrollment beginning at a minimum of 6% — but not more than 10% — allowing opt-out at any time.

z No 10% cap on automatically increasing deferral rates.

z A graduated employer match on deferrals, equaling 4.5% for those who defer at least 10% of pay (but no match on deferrals above 10%).

Bill to Expand Electronic Disclosure of Retirement Information — The Receiving Electronic Statements to Improve Retiree Earnings (RETIRE) Act would amend ERISA and the IRC to allow electronic delivery of plan documents (i.e., reports, statements, notices and notifications) to participants or beneficiaries if the document:

� Is “designed to result in effective access to the document by the participant, beneficiary or other specified individual through electronic means.”

Lockton Companies

� Permits the individual to select the specific electronic means of delivery (or allows the individual to select a preference for paper materials).

� Protects the confidentiality of personal account information.

Electronic communication could include direct delivery by email or posting to a website or intranet with proper notice.

Bill to Expand Workplace Retirement Plans — The Small Businesses Add Value for Employees (SAVE) Act would:

� Permit open MEPs in which unrelated employers would be permitted to band together to share administrative costs.

� Establish a new automatic enrollment safe harbor with a default contribution of at least 6% in the first year, at least 8% in the second year, and at least 10% in the third year. Matching contributions would be required to be made in specified amounts on elective contributions up to 10%.

� Require 401(k) plans to include, on participants’ benefit statements, illustrations of the annuity income amount that they could receive in addition to showing their current account balances.

� Provide a safe harbor to satisfy fiduciary duties in selecting an insurer and a guaranteed retirement income contract (such as an annuity).

� Allow up to $250 of an employee’s unused flexible spending arrangement amounts to be transferred directly to a retirement plan.

Although most of these bills have bipartisan support, and frankly just make common sense, the political environment in Washington makes passage of any legislation, particularly through the Senate, very difficult. It is, however, very possible that some or all of these bills could make their way into a larger piece of legislation that could include a centerpiece that both parties would support such as infrastructure, immigration, or entitlements.

Lockton Companies

Defined Benefit

LEGISLATIVE UPDATE

House bill targets PBGC premiums

A bipartisan team of lawmakers in the House introduced the Rightsizing Pension Premiums Act, which makes several reforms to the PBGC’s insurance premium system including:

� Reduction of premiums for small employers and Cooperative and Small Employer Charity Act (CSEC) plans (generally multiple employer plans maintained by charities or cooperatives) to pre-2006 levels.

� Reduction of premiums for other plans based on the PBGC’s single employer plan program’s funded status. (As PBGC’s funded status improves, premium levels for all businesses — other than small businesses and CSEC plans — would be reduced.)

� Taking PBGC premium increases, and decreases, off-budget. Under current law, defined benefit pension plan insurance premiums paid by employers to the PBGC are considered “on-budget” and, for accounting purposes, the premium revenue can be used to “offset” general government spending, even though these premiums cannot be allocated to other government programs besides the PBGC. In the past six years alone, Congress has increased PBGC premiums several times to offset unrelated spending measures. Most recently, the Bipartisan Budget Act of 2015 increased premiums to raise an estimated $7.65 billion through 2025.

Lockton Companies

COURT UPDATES

Just how much do the lawyer’s get?

After more than a decade, the parties in the case of Tibble v. Edison have agreed upon a $5.8 million fee for the plaintiff’s firm of Schlichter Bogard & Denton LLP. The case involved the plan’s 17 retail mutual funds and the claim that a prudent fiduciary would have invested in the institutional-class shares. Damages exceeded $7.5 million, and the parties subsequently agreed to an additional $5.6 million in damages.

If you are counting, that means the firm received 45% of the total damages. In all, the Schlichter law firm has racked up more than $100 million in fees for its work over the past decade, with many cases still in the pipeline including a series of lawsuits focused on university 403(b) and 401(k) plans. This, of course, does not account for the defendants’ own legal fees. It emphasizes the huge costs associated with litigation, the importance for good insurance, and the need to minimize your fiduciary risk through prudent fiduciary governance.

TIAA hits The New York Times

Several legal complaints, including lawsuits filed by employees and a whistle-blower group of former workers, allege that TIAA pushes customers into potentially unsuitable products to generate higher fees. TIAA contends that its operations are untainted by conflicts because its 855 financial advisers and consultants do not receive sales commissions. However, the whistle-blower complaint to the SEC alleges that TIAA management assigned outsize sales quotas and directed sales representatives to play up customers’ fears of not having enough money in retirement in a scheme to move “unsuspecting retirement plan clients from low-fee, self-managed accounts to TIAA-CREF-managed accounts” that were more costly. The complaint states that people who questioned management’s directives were “processed out.”

When TIAA is a plan’s recordkeeper, its in-house funds are typically among the investments offered. The company earns a recordkeeping fee from these institutions, but it can also receive additional revenues when investors buy its mutual funds and annuities. Therein lies the potential conflict for TIAA. TIAA will have its day in court and before the SEC to defend itself, and the retirement industry, which depends on revenue from rollover and retail sales, will be watching closely.

Lockton Companies

COURT UPDATES

Financial Engines suit dismissed

Recordkeeper Xerox HR Solutions escaped a lawsuit by participants in three Ford Motor Co. 401(k) plans challenging the allegedly excessive fees charged for investment advice provided by robo-adviser Financial Engines. The court found that Xerox had no discretion over the amount of its own compensation as it relates to the participants and thus wasn’t acting as a fiduciary when collecting fees from Financial Engines. The outcome is consistent with similar cases against Voya Financial, Aon Hewitt Financial Advisors and Fidelity Management Trust. Despite being at the center of these cases, Financial Engines hasn’t been named a defendant in any of them. In these cases, the courts have said that the plan sponsors ultimately appointed Financial Engines, not the recordkeeper. To be clear, plan sponsors have also not been named in these cases, but that doesn’t mean they should ignore the cases.

When adding a participant advice solution, the

plan sponsor should understand the fee structure

and, if revenue is shared with the recordkeeper, it

may be wise to consider those dollars as part of

the recordkeeper’s compensation and determine

what services are performed to substantiate

the compensation.

Lockton Companies

COURT UPDATES

Plans should leverage buying power

Retail giant Nordstrom is the latest 401(k) plan sponsor to get hit with a breach of fiduciary duty lawsuit. The allegation claims Nordstrom failed to use its bargaining power as one of the largest plans in the country to negotiate more reasonable fees for plan participants. Nordstrom had annual revenues in excess of $14 billion and employed more than 72,000 people. Its plan had $2.8 billion in assets and 74,304 active participants. The lawsuit alleges that the failure to bargain for reduced fees cost “$177,622 per participant, or over $12 billion collectively, as compared to the highest ranking peer plan.” The peer plan here was alleged to include a recordkeeping fee per person of $30, where Nordstrom paid between $55.60 and $68.72.

Plans of all sizes should properly benchmark their fees and expenses to determine the market on an annual basis and negotiate on behalf of their participants. The fiduciary requirement is not the cheapest, but where a premium is paid, there should be evidence that the services received justify the premium.

Fraud scheme targets 401(k) plans

A scheme targeting individual 401(k) accounts, potentially at multiple recordkeepers, has resulted in a lawsuit by the US Attorney’s office in Colorado to recover as much as $2 million in losses.

Great-West Financial notified the FBI of the scheme where unauthorized individual(s) had fraudulently used the recordkeeper’s distribution request process to access retirement account funds and transfer them to other bank accounts without the knowledge or consent of the actual participant. The requestor was able to provide the plan participant’s biographical data, e.g., name, Social Security number, date of birth and employment data. Since the requests were authenticated with the plan participants’ identifiers, the perpetrator was able to make changes to the accounts and facilitate the withdrawals. Additional entities recently targeted by similar financial fraud schemes include Voya Financial and Nationwide, according to the lawsuit.

Lockton Companies

THE BEACON , YEAR TO DATETrump Nominees Take Aim at Tax Reform and the Fiduciary Rule — January 30, 2017: Though the Fiduciary Rule is on everybody’s mind, tax reform may be Trump’s more significant retirement legacy. This look at his nominees for the departments of Treasury and Labor ponders what their agendas may mean for retirement plans.

The President’s Fiduciary Rule Memorandum Leaves More Questions Than Answers — February 8, 2017: The Trump Administration asked the DOL to take a second look at the new Fiduciary Rule, set to become effective in April, though, with a short window of time and most of the industry already on board, options were limited.

DOL Faces Regulatory Rollback—March 3, 2017: The new administration and the GOP-controlled Congress have begun the rollback of many Obama-era labor regulations opposed by the private sector, including delays to the Fiduciary Rule and a plan to block state-run retirement mandates.

Train Remains on Track for DOL’s Fiduciary Rule — May 31, 2017: In a surprise move, the Trump administration agrees not to fight the implementation of the impending Fiduciary Rule.

Highest Court Recognizes Highest Power: Church-Owned Businesses Secure Supreme Court Win — June 8, 2017: The Supreme Court makes a unanimous decision that church and church-affiliated plans are exempt from ERISA, though they are not absolved of fiduciary duty.

Lockton Companies

As the Fiduciary Rule Turns: More Guidance, More Delays — August 14, 2017: The DOL’s new guidance helpfully excludes retirement savings encouragement from the definition of advice, but then delays implementation of the new rule, yet again.

GOP Unveils Tax Reform Plan: Summary of the Impact On You and Your Business — November 6, 2017: House Republicans released their long-awaited proposed tax-reform legislation in a 429-page bill containing broad-reaching changes including reduced tax rates for corporations and most individuals.

Tax Reform Update: The Senate Gets in the Game — November 10, 2017: Senate Republicans respond to the House bill with a version that incorporates public sentiment, including the preservation of tax deferral for qualified retirement plan contributions.

Lockton Companies

RETIREMENT SERVICES GUIDANCE , YEAR TO DATE

IRS Proposal Would Grant More Flexibility When Using Forfeitures — January 30, 2017: Regulatory amendments allow employers to use forfeitures as qualified nonelective and qualified matching contributions to help pass nondiscrimination tests and fund safe harbor contributions.

New IRS Guidance Makes Substantiating Hardship Withdrawals Easier — March 10, 2017: A new memorandum from the IRS simplifies the process for plan sponsors approving hardship withdrawals, but it may leave the door open to some potential risk for employers.

Retirement Plans Get Regulatory Relief From Hurricane Harvey — September 5, 2017: Retirement regulators are waiving penalties and extending deadlines for hurricane disaster victims.

DOL Disability Regulations May Require Nonqualified Deferred Compensation Plan Changes — September 22, 2017: New DOL regulations for disability claims could affect executive nonqualified plans, depending on who makes the disability determination.

IRS Finally Answers Pension Plan Mortality Questions — November 6, 2017: The Internal Revenue Service finalized rules for using updated mortality tables in single employer pension plan calculations creating several decisions for plan sponsors to make about implementation.

Lockton Companies

DOL Delays Implementation of Author Disability Claim Rules Impacting NQDC Plans — December 7, 2017: Although the Department of Labor delayed final regulations on deferred compensation plan responses to disability claims, employers should still review their procedures.

RISK MANAGEMENT • EMPLOYEE BENEFITS • RETIREMENT SERVICES

Our Mission | To be the worldwide value and service leader in insurance brokerage, risk management, employee benefits, and retirement services

Our Goal | To be the best place to do business and to work

© 2018 Lockton, Inc. All rights reserved. KC: 38778

LOCKTON.COM

The communication is offered solely for discussion purposes. Lockton does not provide legal or tax advice. The services referenced are not a comprehensive list of all necessary components for consideration. You are encouraged to seek qualified legal and tax counsel to assist in considering all the unique facts and circumstances. Additionally, this communication is not intended to constitute US federal tax advice, and is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending any transaction or matter addressed herein to another party.

This document contains the proprietary work product of Lockton Financial Advisors, LLC, and Lockton Investment Advisors, LLC, and is provided on a confidential basis. Any reproduction, disclosure, or distribution to any third party without first securing written permission is expressly prohibited.

Investment advisory services offered through Lockton Investment Advisors, LLC, an SEC-registered investment advisor. For California, Lockton Financial Advisors, LLC, d.b.a. Lockton Insurance Services, LLC, license number 0G13569.

PROTECTION FOR CLIENTS’ BUSINESSES. SECURITY FOR THEIR EMPLOYEES.