Over half of all 401(k) assets are invested in Target Date Funds (TDFs), the default investment for most workers. Proposals to embed 15% allocations to private equity (PE) in these TDFs raise severe fiduciary, legal, and policy concerns.
Private equity’s opaque self-valuations, smoothed returns, and layered fees (≈600 bps) make it wholly unsuitable for retirement savers—particularly in default funds where workers have no choice. This is not innovation; it is regulatory arbitrage designed to funnel billions in hidden fees out of participant accounts.
Key Findings
1. Fees 100x higher than index funds.
PE all-in costs: ~6.0% annually (Phalippou 2020).
Index funds: 0.03%–0.05%.
A 15% sleeve adds 0.90% annual drag to the entire TDF—cutting lifetime wealth by 20–25%.
2. Fraudulent return smoothing.
PE funds self-price and delay write-downs.
Reported volatility and correlations are artificially low.
Asset allocation models therefore over-allocate to PE, embedding mispriced risk in retirement glidepaths.
3. Liquidity mismatch.
TDFs promise daily liquidity.
PE funds lock up capital for 10+ years.
Participants could face redemption delays, gates, or markdowns inconsistent with plan representations.
4. Weakest regulator wins.
SEC and OCC rules demand transparency and independent valuation.
Sponsors are instead turning to state-chartered CITs, where oversight is minimal and disclosure optional.
This is textbook regulatory arbitrage.
5. Fiduciary red flags.
ERISA requires prudence and reasonable fees.
Supreme Court precedent (Tibble; Hughes) obligates ongoing monitoring and removal of high-cost options.
Embedding PE in QDIAs (defaults) is especially egregious because workers never affirmatively opt in.
Policy Recommendations
DOL & SEC Joint Guidance: Prohibit private equity allocations in QDIAs until independent valuation and full fee disclosure are mandatory.
State CIT Oversight: Close the loophole by requiring federal standards (SEC/OCC level) for any retirement-plan CIT.
Fee Disclosure Reform: Mandate reporting of all fees, including portfolio company monitoring and transaction charges.
Participant Protections: Require opt-in consent, with plain-English disclosures, before allocating participant funds to PE.
Conclusion
Private equity in 401(k) Target Date Funds is not diversification—it is defaulting American workers into opaque, fee-rich products they cannot understand or escape. This violates fiduciary duty under ERISA and undermines retirement security. Regulators and policymakers should act now to prevent a massive transfer of wealth from retirement savers to private equity sponsors.
State Guaranty Associations are so flimsy that none are rated by S&P or Moody’s. There is no money in them, the reserves are not in the association, only in the companies themselves.
Most did not even pay out claims in the last major default, Executive Life – only Illinois and Pennsylvania associations made partial payments, only after court orders.
I asked ChatGPT about Guarantee Associations in the context of an ERISA Fiduciary and got the following response.
⚖️ ERISA Fiduciary Standards vs. State Guaranty Associations
1. Duty of Prudence and Care (§404(a)(1)(B))
ERISA requires fiduciaries to act:
“with the care, skill, prudence, and diligence under the circumstances then prevailing…”
SIGAs do not meet the “prudent expert” standard. A prudent expert would not rely on:
An entity with no prefunding or reserve capital
No federal backing
No credit rating from any recognized rating agency
A history of failure to pay during systemic defaults (e.g., Executive Life)
As you noted, only Illinois and Pennsylvania eventually made partial payouts, and only after litigation. That alone defeats the fiduciary standard of prudent selection and monitoring.
2. Duty of Loyalty (§404(a)(1)(A))
Fiduciaries must act solely in the interest of participants and beneficiaries and for the exclusive purpose of providing benefits.
If a fiduciary chooses an annuity or insurance-based structure based on a belief that the SIGA will protect beneficiaries, without disclosing its inadequacy, they may be violating their loyalty duty.
Relying on industry marketing or regulatory illusion about SIGAs—when informed sources (like the Federal Reserve, EU regulators, and academics) have raised red flags—could be seen as self-serving or negligent.
3. Duty to Monitor and Evaluate Risk
ERISA fiduciaries must continually evaluate risks and the financial condition of providers.
Given the known systemic risks, including:
Private equity ownership of insurers (Kirti & Sarin 2020)
Long-duration illiquid assets in General Accounts
Minimal real oversight by state regulators
EU regulator concern in 2017 about systemic fragility of U.S. insurance regulation
…it’s arguable that no prudent fiduciary should rely solely—or even primarily—on SIGAs as a source of security.
📚 Supporting Academic and Regulatory Warnings
Lambert & Tobe (2024) – Warn of “a possible US retirement crisis” driven by misleading safety claims of annuities.
Todd & Wallace (1992, Fed Minneapolis) – Exposed the moral hazard of undercapitalized SIGAs and deceptive perceptions of insurance safety.
Perez (2016) – Documents political interference and regulatory capture at the state level.
EU Concerns (2017) – EU regulators raised cross-border solvency concerns for U.S. insurers, especially given weak state regulation.
🚫 What This Means for Fiduciary Actions
ERISA fiduciaries should not rely on State Guaranty Associations as a primary or sufficient reason to:
Justify annuity purchases for pension risk transfers (PRTs) or 401(k) plans.
Accept insurer counterparty risk without thorough, independent due diligence.
Claim “safety” without disclosing SIGA limits, lack of reserves, and legal uncertainty.
Instead, fiduciaries should:
Require contractual provisions for downgrade protections and capital reserves.
Insist on federal-level guarantees or fully collateralized structures.
Disclose the inadequacy of SIGAs in plan documents and fiduciary reports.
🧾 Bottom Line
State Guaranty Associations offer the illusion of safety, not the substance. No fiduciary acting under the ERISA standard of prudence and loyalty should rely on them as a meaningful risk mitigator.
Annuities have always flunked but no one has ever challenged them because of their total lack of transparency. Now with SCOTUS Cornell decision, the burden of proof has shifted to the plans to defend why they think annuities are exempt from being prohibited transactions, and for the most part they are clueless.
Most annuities in most DC plans are labeled “parties in interest” because they have a relationship with the administrator/recordkeeper. This relationship creates a potential conflict of interest and labeled a Prohibited Transaction. A Prohibited Transaction Exemption (PTE) must be used to include the annuities in the plan.
PTE’s are subject to the ERISA Impartial Conduct Standards which are a set of requirements for fiduciaries providing investment advice to retirement investors, ensuring they act in the best interest of the client, receive reasonable compensation, and avoid making misleading statements.
Annuities for decades have claimed Prohibited transaction exemptions behind PTE 84-24 and more recently PTE 2020-02 with few challenges or any accountability.[1] However, the recent SCOTUS decision clearly says plans are responsible for verifying that their investments qualify for the prohibited transaction exemptions. The PTEs that apply to the insurance products they put in their plans where most are “parties in interest” must meet the Impartial Conduct Standards.[2]
Judge Lynn when ruling on Fixed Index Annuities in 2017 stated Because “insurers generally reserve rights to change participation rates, interest caps, and fees,” FIAs can “effectively transfer investment risks from insurers to investors.”[3]this control by insurers clearly violates Impartial Conduct Standards.[4]
ERISA PTE 84-24, which is based on the Restatement of Trust, states the annuities must meet the following requirements called the Impartial Conduct Standards and Written Disclosures and Policies and Procedures backing up these standards. Most annuities I have seen do not even come close.
Care Obligation This obligation reflects the care, skill, prudence, and diligence – similar to Prudent Person Fiduciary standard. Diversification is one of the most basic fiduciary duties. Under the CFA pension trustee standard for acting with prudence and reasonable care the plan should seek appropriate levels of diversification.[5]Fixed annuities flunk this diversification test with single entity credit and liquidity risk. [6]
The Federal Reserve in April 2025 said “Life insurers continued to hold a significant share of risky and illiquid assets on their balance sheets”[7] Under the CFA pension trustee standard Principle #3 to Act with skill competence and diligence it cites need for awareness of investments liquidity, and any other risks. Certain types of investments …necessitate more thorough investigation and understanding than do fundamental investments, such as straightforward and transparent equity, fixed-income, or mutual fund products Annuities call for more diligence by sponsors which needs to be fully documented by plans. Plan sponsors could mitigate this credit and liquidity risk in their annuity contracts with downgrade clauses which allow liquidity at book value if the annuity issuer is downgraded but these type clauses have not been adopted for most plans.[8]
Loyalty Obligation Annuity contracts are designed to avoid all fiduciary obligation with no loyalty to participants. Diligence is nearly impossible with misleading, nontransparent contracts, and the lack of plan/participant ownership of securities. Secret kickbacks and commissions place the financial interests of the Insurers and their affiliates over those of retirement investors. The new fiduciary rule requires the advisor to show their loyalty with a “Fiduciary Acknowledgement Disclosure.” which has been strongly opposed by the Annuity industry. Plans typically agree to Annuity contracts that avoid any fiduciary language or responsibility on the part of the issuer. [9] The Federal Reserve in 1992 exposed the varying weak state regulatory and reserve claims and most plans are not even aware of which state issued their annuity contract.[10]
Reasonable compensation limitation Annuities have a total lack of disclosure of profits, fees and compensation – effectively denying any chance for a prospective purchaser to make an “informed decision.” CFA Institute Global Investment Performance Standards (GIPS) are transparency standards on performance and fees. Annuities typically do not comply with CFA GIPS standards.[11]
Noted Morningstar analyst John Rekenthaler said in April 2022 that in selecting 401(k) investment options, “inappropriate are investments that don’t price daily.” Annuities typically do not price daily and do not provide valuation transparency.[12]
A number of lawsuits have settled with claims of excessive secret fees and spreads in annuities. An insurance executive bragged at a conference of fees over 200 basis points (2%) in 2013. [13] In a report, Morningstar acknowledges that annuities fees inside 401(k) plans are challenging to understand. ‘No insurer tells you what is in the spread.’ ‘Insurance firms collect a spread”[14] I was quoted on NBC that the TIAA Fixed Annuity made spread fees of around 120 basis points. TIAA makes $billions in undisclosed profits on their fixed annuity products. TIAA annuity has been called the company’s profit “engine” driving $46.2 in bonuses to their top five executives.[15] These IPG fixed annuity contracts have been characterized by DC plan group NAGDCA as having serious fiduciary issues with hidden fees. “Due to the fact that the plan sponsor does not own the underlying investments, the portfolio holdings, performance, risk, and management fees are generally not disclosed. This limits the ability of plan sponsors to compare returns with other SVFs [stable-value funds]. It also makes it nearly impossible for plan sponsors to know the fees (which can be increased without disclosure) paid by participants in these funds—a critical component of a fiduciary’s responsibility “[16]
The Annuity industry thrives on secret commissions.[19] The GAO and Senator Warren reported on these commissions.[20] The annuity industry has fought the so-called Biden Fiduciary rule which would expose many annuity commissions in 401(k) plans. The annuity industry trade group that coordinates weak state insurance commissioners National Association Insurance Commissioners (NAIC) best interest rule was ridiculed by a DOL Official “compensation is not considered a conflict of interest,” All 50 State Insurance Commissioners have rejected Fiduciary standards by adopting the NAIC best interest rules.[21]
Annuities claim principal protection, but some fixed annuity contracts recently have “broken the buck” and violated their contracts by forcing significant losses on participants. The written disclosures under weak state regulations omit critical information on risks and fees also prevents any opportunity for an “informed decision.”
Conclusion
Annuities clearly flunk all 4 major obligations of the Impartial Conduct Standards and are not exempt as Prohibited Transactions.
Plans with annuities have huge fiduciary liabilities which grow larger each year. With the new Supreme Court Case CunninghamV.Cornell the risk of litigation, and potential damages have grown greatly. [22] Within 2 weeks of the decision a case of annuities as prohibited transactions has already been filed.
Plan sponsors should amend their Annuity contracts to at least stop the growth of fiduciary liability.
1. A Most Favored Nation (MFN) clause to make sure they have the best rate/largest payouts/ lowest spread fees of all the annuity providers similar clients
2. A downgrade clause that allows liquidity at full book value if the insurance company issuing the annuity is downgraded.
3. Annuity provider agrees to be ERISA Fiduciary
If they cannot get these 3 clauses – the plan must demand that the annuity provider let them out of the contract, and if not consider legal action against the insurance company.
The CFA Institute Pension Trustee Code of Conduct (Code) sets the standard for ethical behavior for a pension plan’s governing body. [i] It is a global standard that applies to both defined benefit (DB) and defined contribution (DC)plans, but I believe is consistent with ERISA fiduciary standards for 401(k) plans. The Code has 10 fundamental principles of ethical best practices. I am going to focus on 5 of them, the areas where we see many plans falling short of the standards.
Principle # 2. Act with prudence and reasonable care. The point regarding seeking appropriate levels of diversification[ii] is typically followed with most larger plans; but, we do see a number of mid-size and smaller plans taking single entity credit and liquidity risk in annuities and other insurance products. [iii] A particular non-diversified insurance product, lifetime income, is trying to break into even the largest plans, but with little success. [iv]
Another point is that service providers and consultants be independent and free of conflicts of interest. [v][vi] Again, most larger plans hire independent providers, but we do see a number of mid-size and smaller plans hire dually registered consultants who not only are registered investment providers, but are also registered as brokers or insurance agents, with the ability to get a commission. [vii]
Principle #3. Act with skill, competence, and diligence. Ignorance of a situation or an improper course of action on matters for which the trustee is responsible or should at least be aware is a violation of this code. “Trustee” in this case refers to each individual on the 401(k) committee plus the plan as a whole. We have seen many 401(k) committee members lacking awareness of the investment details in options of the plan.
Specifically, this principle points out the need ror awareness of how investments and securities are traded, their liquidity, and any other risks. Certain types of investments, such as hedge funds, private equity, or more sophisticated derivative instruments, necessitate more thorough investigation and understanding than do fundamental investments, such as straightforward and transparent equity, fixed-income, or mutual fund products. [viii]
With investments that have non-SEC regulated securities like illiquid contract-based products like crypto, [ix] private equity,[x] annuities and other insurance products, [xi] many times the 401(k) committees are not aware of the risks and hidden fees and have not thoroughly investigated them on such matters, especially those buried in target date funds and in brokerage windows.
Principle #5. Abide by all applicable laws Generally, trustees are not expected to master the nuances of technical, complex law or become experts in compliance with pension regulation. Effective trustees …consult with professional advisers retained by the plan to provide technical expertise on applicable law and regulation. [xii]
Principle #3 suggests that assets that are not straightforward and transparent securities, such as crypto, private equity and annuities/insurance products contracts, require additional legal scrutiny. I would assume that no crypto product would pass a good fiduciary law audit. I would claim that it would be the fiduciary duty of the plan going into any private equity or annuity contract (separate account or general account) – to have a side letter in which the manager/or insurance company agrees to take.
1. ERISA Fiduciary duty
2 Provide liquidity if the investment experiences difficulty. With insurance products, this can be done with a downgrade clause, i.e., “in the event that the insurance company’s debt is downgraded below investment grade by any major rating agency, the plan will be returned its contract value in cash within 30 days.”
3. “Most Favored Nation Clause, guaranteeing that the manager /insurance company does not provide a lower fee or higher rate to any other plans
Ownership of underlying securities is key to a plan’s risk exposure, especially liquidity risk, and when complex instruments are involved, it is the duty of the plan committee to get competent legal advice on these investment contracts.
Principle #7. Take actions that are consistent with policies Effective trustees develop and implement comprehensive written investment policies that guide the investment decisions of the plan (the “policies”). Most of the largest plans have Investment Policy Statements (IPS). The Code expects any plan to have them.
I believe any plan without an IPS is in fiduciary breach. I believe many conflicted consultants, as discussed in Principle #2, recommend that plans do not draft an IPS since it would expose their own conflicts. Most of the riskier assets in Principles #3 and #5, like crypto, private equity and annuities, would not be allowed under a well written IPS due to the excessive risks and hidden fees involved.
Trustees should … draft written policies that include a discussion of risk tolerances, return objectives, liquidityrequirements, liabilities, tax considerations, and any legal, regulatory, or other unique circumstances. Review and approve the plan’s investment policiesas necessary, but at least annually, to ensure that the policies remain current.[xiii]Some plans may have an Investment Policy Statement (IPS), but do not regularly review it or apply it rigorously to their investments.
Select investment options within the context of the stated mandates or strategies and appropriate asset allocation. Establish policy frameworks within which to allocate risk for both asset allocation policy risk and active riskas well as frameworks within which to monitor performance of the asset allocation policies and the risk of the overall pension plan.[xiv]
While asset allocation is a major component of DB plans – US DC plans now have over 50% of their assets in asset allocated investments, primarily target date funds.[xv] In most plans, the target date funds are the Qualified Default Investment Alternative (QDIA), which makes it essential that each target date sleave be addressed in the Investment Policy Statement.
Principle #10. Communicate with participants in a transparent manner. While the DOL forces some fee disclosure on each plan investment, it is not complete with non-securities like crypto, private equity and annuities as standalone options[xvi], in brokerage windows or inside target date funds. [xvii]
Revenue sharing is a shady non-transparent way some plans make their own participants pay for administrative costs; it does not hold up under these CFA standards in my opinion. [xviii]
Given the similarity between ERISA’s fiduciary requirements and the CFA Institute Pension Trustee Code of Conduct, 401(k) plan sponsors could greatly mitigate their litigation risk by looking at the Code. Furthermore, it is just the prudent and the right thing to do as a fiduciary.
Chris Tobe, CFA, CAIA is the Chief Investment Officer with Hackett Robertson Tobe (HRT) a minority owned SEC registered investment advisor and recently was awarded the CFA certificate in ESG investing. At HRT Tobe is leading up the institutional investment consulting practice for both DB and DC Pension plans. He also does legal expert work on pension investment cases.
Past industry experience includes consulting stints at New England Pension Consultants (NEPC) and Fund Evaluation Group. Tobe served on investment committee of the Delta Tau Delta Foundation for over 20 years served as a Trustee and on the Investment Committee for the $13 billion Kentucky Retirement Systems from 2008-12. Chris has published articles on pension investing in the Financial Analysts Journal, Journal of Investment Consulting and Plan Sponsor Magazine. Chris has been quoted in numerous publications including Forbes, Bloomberg, Reuters, Pensions & Investments and the Wall Street Journal.
Chris earned an MBA in Finance and Accounting from Indiana University Bloomington and his undergraduate degree in Economics from Tulane University. He has the taught the MBA investment course at the University of Louisville and has served as President of the CFA Society of Louisville. As a public pension trustee in, he completed both the Program for Advanced Trustee Studies at Harvard Law School and the Fiduciary College at Stanford University.
Republican Attorney Generals across the US have declared that ESG investing is a fiduciary breach because it underperforms typical historic investments, even though they offer no proof. While there can be bad ESG funds with poor performance, high fees and low transparency, that generally has little to do with the ESG part. There have been over 2000 studies on the investment performance of ESG funds, with over 50% showing that ESG has a positive performance effect and 30% showing neutral results. Only 10% of the studies support the attorneys generals’ claim.[i]
While all the factors Environment (E), Social Responsibility (S), and Governance (G) had positive factors on performance, G was the highest at over 60%. A good example of ESG dumping losers is when S&P ESG index dumped Tesla from its index May 2022 when its price was over $317 a share and, by year end 2022, was down to 65% to $112 a share. S&P cited governance related codes of business conduct, lack of transparent reporting on breaches, and the occurrence of corruption and bribery cases and anti-competitive practices as bases for its decision. S&P also cited Tesla’s handling of the NHTSA investigation following multiple deaths and injuries were linked to its autopilot vehicles. [ii] The dominance of single board member, as is the case with Tesla, is considered a substantial weakness in governance,
Governance has focused on corporate governance of public regulated securities. The Council of Institutional Investors in the US has developed an extensive and effective framework for dealing with governance issues in public securities. [iii] The CFA institute has developed an ESG certificate and curriculum, including governance, whose factors highlight overall transparency, accountability and financial integrity, as well boards independence and expertise [iv] There needs to be more upstream applications of governance in investments, first to money managers, consultants, and to the boards of retirement plans and other asset owners
As we have found out with Crypto, the structure of real asset matters. The best structure is to directly own a regulated liquid security that is transparent in your own independent custodial account. This structure allows institutions, such as CII, to have the ability to control and monitor their own individual assets and have complete transparency of the management including fees and commissions associated with trades. Another good structure is owning a regulated liquid security within a SEC registered mutual fund. Collective investment trusts (CIT’s) can be a good structure or a bad structure.[v]
Like crypto, many the most vocal ESG large institutional investors have a blind spot for gof investment structure. Private equity and hedge funds have an extreme lack of transparency and liquidity, as evidenced by the fact that it has been shown that most investors have no idea of how much they pay in fees and expenses and they even lie about their ESG attributes.
New York State and New York City claim to have strong ESG policies. Yet they invest in have private quity firms with horrible ESG records.[vi] Ownership via a contract has few of the protections that a registered security. M of such firms any are domiciled in the Cayman Islands, which seems to be for the benefit of the managers.[vii] Many of these contracts absolve the manager of fiduciary duty and push the risk onto the asset owner.
The majority of 401(k) plan investment options are in transparent SEC registered mutual funds. However, there are significant retirement assets that are not owned by participants directly, but via non-transparent and high fee annuity contracts. These annuity contracts absolve the insurance company of fiduciary duty and push the risk onto the participants, who then have to sue the plan sponsor if they feel they are wronged. I believe that a plan sponsor who puts participants in non-transparent annuity contracts as breaching their fiduciary duty. [viii]
Regulation does matter. For US based asset owners, we have seen the collapse of totally unregulated investments like Crypto. We have private equity and hedge funds that are lightly regulated by the SEC . Federal regulation matters. Annuities and insurance products can cherry pick the weakest state regulator among the fifty states. CIT providers could use the Federal OCC, but mostly choose to use the weakest state bank regulator they can find.
ESG ratings of corporate governance look at regulatory violations. [ix] Violations such as EPA fines for pollution and labor violations, are looked at by ESG analysts. However, many retirement plan and asset owners seem oblivious to continuous violations from asset managers like Wells Fargo and others for violations that include fee gauging and fiduciary breaches. [x]
Good governance is great for investors and should be encouraged. I think these governance principles are consistent with one’s fiduciary duties and need to be expanded. Fiduciaries should follow solid governance by buying real stocks and bonds they can own, instead of fake assets like crypto and/or vague contracts for firms domiciled in the Caymans or regulated by the state of Iowa. Fiduciaries using common sense governance principles should avoid companies that have been fined for fiduciary breaches by the government.
Chris Tobe, CFA, CAIA, was recently awarded the CFA Institute Certificate for ESG investing. He is Chief Investment Officer for the Hackett Group, where he helps manage an ESG Racial Justice Impact Fund.
Whenever plan sponsors and plan advisers talk about 401(k) litigation, they always point the finger at those bad ‘ol ERISA plaintiff attorneys. Since I am one of those bad folks, I respectfully disagree with such sentiments. I respectfully suggest that plan sponsors should look in the mirror to see the real party for such litigation. As the famous comic strip, “Pogo,” once said, “we have met the enemy and he is us.”
Whenever I talk with a CEO and or a 401(k) investment committee, this is the first graphic I show them. Most plan advisers insist on plan sponsors agree to an advisory contract that contains a fiduciary disclaimer clause. Many plan sponsors are not aware that they have agreed to such a provision since they are usually set out in legalese. But they are usually there.
When a plan sponsor agrees to such a clause, it waives important protections for both itself and the plan participants. With a fiduciary disclaimer clause, securities licensed advisers can claim to be subject to Regulation “Best Interest” (Reg BI) rather than the more demanding duties of loyalty and prudence required under a true fiduciary standard.
Reg BI claims that it requires brokers to always put a customer’s best interests first, including considering the costs associated with any and all recommendations. The Reg BI turns around and allows brokers to only consider “readily available alternatives,” which the SEC considers to be the cost-inefficient and consistently underperforming actively managed mutual funds and various annuity products. In whose best interests?
Unless a plan sponsor properly performs the investigation and evaluation required under ERISA, this usually results in 401(k) litigation and the plan sponsor settling for a significant amount. As we discussed in a previous post, when you consider that all of this can be easily avoided by a plan sponsor by performing a cost-efficiency analysis using our free Active Management Value Ratio, you have to wonder why plan sponsors do not better protect themselves by simplifying their plans and ensuring that they are ERISA-compliant.
My experience has been that most plan sponsors create unnecessary liability exposure for themselves due to a mistaken understanding of their true fiduciary duties. “The CommonSense 401(k) Plan”™ provides a simple solution that reduces both administration costs and potential liability exposure, resulting in a win-win situation for both plan participants and plan sponsors.
So, for plan sponsors and plan advisers, the next time you point a finger at ERISA plaintiff’s attorney and blame us for the number of 401(k) litigation cases, remember the words of my good friend, Charles Nichols, when you point at us, three of your remaining fingers point back at you. Then contact InvestSense for a free “The CommonSense 401(k) Plan” consultation at “CommonSense InvestSense.” (investsense.com)
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This article is for informational purposes only, and is neither designed nor intended to provide legal, investment, or other professional advice since such advice always requires consideration of individual circumstances. If legal, investment, or other professional assistance is needed, the services of an attorney or other professional advisor should be sought.
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