401k Plan Fees How does your Plan compare

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401(k) Plan Fees … How does your Plan compare? 2007 Benefits New York Show

401(k) Plan Fees … How does your Plan compare? 2007 Benefits New York Show and Conference March 12, 2007

About Your Presenters n Michael Crowley is Associate General Counsel for the National Futures

About Your Presenters n Michael Crowley is Associate General Counsel for the National Futures Association, the industry wide, self-regulatory organization for the U. S. futures industry. For 15 years, Mike has advised NFA’s benefits committee and senior management on issues concerning retirement and health benefits. In those years, Mr. Crowley has been an integral part of NFA’s efforts to build a comprehensive retirement benefits program with particular focus on aiding the benefit committee in discharging its fiduciary responsibilities in the operation of NFA’s retirement plan. In addition to his work in the benefits arena, Mike heads NFA’s legal department who license all futures professionals in the United States. He also provides legal advice to management on a variety of other issues, including intellectual property, privacy, insurance and contracts. Mike received his B. A in Political Science from the University of Illinois and his J. D. from Chicago Kent College of Law. Before joining NFA, he prosecuted slumlords in the office of the Cook County, Illinois States Attorney and represented indigent clients at the Legal Assistance Foundation of Chicago. n Wayne G. Bogosian is founder and President of The PFE Group, Southborough, MA, a leading retirement plan vendor search, investment advisory and financial education consulting firm. Wayne is a frequent public speaker, having conducted more than 1, 000 workshops and seminars on topics ranging from retirement planning and investments to corporate downsizing and mergers and acquisitions. He is co-author of The Complete Idiot’s Guide to 401(k) Plans and has been quoted in a variety of publications including Business Week, CNNMoney, Employee Benefit News, Reader’s Digest, USA Today, Wall Street Journal, Washington Post, and appeared on WCVB, MSNBC, and AOL. Wayne has a B. S. from Northeastern University, an M. B. A. from Suffolk University, is an Accredited Investment Fiduciary (AIF), and holds various securities licenses. 401(k) Plan Fees … How Does Your Plan Compare? | | 1

Workshop Objectives n What’s all the fuss over 401(k) plan fees? n What fees

Workshop Objectives n What’s all the fuss over 401(k) plan fees? n What fees are sponsors and participants paying? n What is a “reasonable” fee for: – Investment Management? – Plan Administration? n How can plan fiduciaries protect themselves from feerelated lawsuits? n What actions should fiduciaries take? 401(k) Plan Fees … How Does Your Plan Compare? | | 2

What’s the fuss over 401(k) plan fees? n 401(k) Fee Lawsuits – ABB, Bechtel,

What’s the fuss over 401(k) plan fees? n 401(k) Fee Lawsuits – ABB, Bechtel, Boeing, Caterpillar, Deere, Exelon, General Dynamics, Int’l Paper, – – – Lockheed Martin, Northrop Grumman, United Technologies Claim: Fiduciaries were “unaware” of plan expenses Claim: Plan expenses were undisclosed Claim: Revenue sharing arrangements between service providers and fund managers were: (1) not properly disclosed to sponsor or participant, (2) not used for the benefit of participants, (3) fiduciary breach Claim: Active managers were “shadow index funds” Claim: Employer Stock Fund cash holdings reduced return; asset based fees charged for administration Plaintiffs asking for: § Monetary relief (direct losses and investment losses) § Jury trial n Fee-Related Regulations Likely – – – House Chair George Miller (D-CA) will initiate hearings DOL to issue fee-related guidance in 2007 New “Required Disclosures” are likely At issue: pro-rata vs. per capita fees Fee disclosures to participants? 401(k) Plan Fees … How Does Your Plan Compare? | | 3

Are You Ready for Full Fee Disclosure? Relate these questions to your retirement plan?

Are You Ready for Full Fee Disclosure? Relate these questions to your retirement plan? Yes No Don’t Know 1. We have identified those services which are considered necessary to the effective and efficient operation of the plan? 2. We have identified all fees charged for necessary services and confirmed (a) who is currently paying the fee (participant or sponsor) and (b) how the fee is being assessed (pro-rata or per capita)? 3. We have identified all Plan Administration services (and fees) which are currently paid through plan investments? 4. We offer less expensive share classes today (if possible) than we did three years ago? 5. We have re-negotiated our plan fees (or moved our business) within the past three years? 6. We have benchmarked our plan services and fees to similar plans in the past three years? 7. Total plan expenses are reported to plan fiduciaries at least once each year? 8. An independent investment advisor, who is a fiduciary of the plan, regularly reviews our plan’s services, investments and fees? ERISA § 406(a)/408(b)… “Prohibited transaction occurs if plan assets are used to pay service providers more than reasonable compensation for their services” 401(k) Plan Fees … How Does Your Plan Compare? | | 4

Required Fee Disclosures n Investment Fees Prospectus – Fund Expense Ratio – Contingent or

Required Fee Disclosures n Investment Fees Prospectus – Fund Expense Ratio – Contingent or Short-term Redemption Fee n Administration Fees Enrollment Form, SPD, 5500, SAR – Recordkeeping Services – Loans and Distributions – Transactions – Compliance, Legal, Investment Advisory, Audit 401(k) Plan Fees … How Does Your Plan Compare? | | 5

Required Fee Disclosures (continued) n GAO Report – Inv Mgt and Recordkeeping fees dominate

Required Fee Disclosures (continued) n GAO Report – Inv Mgt and Recordkeeping fees dominate – Fees are primarily paid pro-rata – Only net returns are shown (i. e, can’t determine a fee’s impact) – Laws governing 401(k) plan fees are limited in scope & do not provide for easy comparison – Fee and expense disclosures are presented in piecemeal and confusing ways – Revenue sharing arrangements between providers (services and funds) may contribute to higher fees – Recommendation: § Disclose all fee-related information § Provide for easy comparison between funds § Report all fees paid from plan assets and paid by participants 401(k) Plan Fees … How Does Your Plan Compare? | | 6

How do fees impact return? Fee as a % of Invested Assets Fee Fund

How do fees impact return? Fee as a % of Invested Assets Fee Fund Gross Return Investment Management Fees % Return 10. 00% 0. 45% Distribution and Shareholder Fees (e. g. , 12 b-1) + 0. 25% Other Expenses of the Fund (audit, legal, etc. ) + 0. 40% Expense Ratio (Total Fund Operating Expenses) = 1. 10% Fund Net Return (Net Asset Value) Subtract All Fees 1. 10% 8. 90% “What am I paying for? 401(k) Plan Fees … How Does Your Plan Compare? | | 7

It takes a lot to service a 401(k) plan! Guiding Influences a) Plan Sponsor

It takes a lot to service a 401(k) plan! Guiding Influences a) Plan Sponsor b) ERISA, DOL & IRC c) Plan Document d) Investment Policy e) Consultants Primary 401(k) Service Provider Trust & Custody Administration Compliance Custody Trading Reconciliation Reporting Payments Distributions Participant Accounting Trans. Processing Technology ERISA & IRC Discrimination Filings Restatements Participant Support Customer Reps Online &VRS Print, Web, DVD Meetings Statements Notices Prospectus Sponsor Support Conversion Relationship Mgr. Support Team Online Reporting M&A, Divestiture “What is the true cost of 401(k) plan administration? 401(k) Plan Fees … How Does Your Plan Compare? | | 8

What fees are Sponsors and Participants paying? VENDOR SERVICE SPONSOR PLAN (Participant) ADMINISTRATION FEES

What fees are Sponsors and Participants paying? VENDOR SERVICE SPONSOR PLAN (Participant) ADMINISTRATION FEES Account Recordkeeping (Daily tracking of all activity) Account Payments (Loans, QDROs, Distributions, Rollovers) Account Access (Online, VRS, CSR) Communication (Prospectuses, enrollment kits, statements, fact sheets, fund changes, required notices, CRF disclosure) Education (Participant meetings, one-on-one) Investment Oversight (Independent Investment Counsel) Compliance (ERISA counsel, required testing, form 5500) Audit (Required for plans > 100 participants) Trust & Custody ASSET MANAGEMENT Investment Performance 401(k) Plan Fees … How Does Your Plan Compare? | | 9

Which investment-related fees might 401(k) Participants pay? FUND EXPENSE LOAD DEFINITION Applies to Most

Which investment-related fees might 401(k) Participants pay? FUND EXPENSE LOAD DEFINITION Applies to Most 401(k) Plan Investmen ts Sales charge for buying or selling a mutual fund Front-end Load Initial Sales Charge for buying a mutual fund (generally 1% – 8. 5% of invested assets) No Back-end Load Deferred Sales Charge for selling a mutual fund. Also called Exit Fee or Deferred Load (up to 5% of redemption) No Declining Load Declining fee (e. g. , begins at 10% and reduces to 0% by year 10) No No Load Fund Mutual fund that is sold without a load (i. e. no sales charge for buying or selling shares) Yes WRAP FEE Annual fee for an investment program that bundles together investment services such as advisory, brokerage, research and management. Wrap Fees may be charged in addition to all other fund fees and loads EXPENSE RATIO Mutual fund's cost of doing business; passed on to all shareholders – expressed as a percentage of assets Yes Investment Management Fee to investment manager for their services. Typically a percentage of average net assets invested in fund Yes Distribution Fee or Shareholder Service Fees (aka 12 b-1 Fee) Fees paid by the fund to cover marketing, sales and shareholder services. "Distribution Fees" compensate brokers and other intermediaries who sell fund shares, pay for advertising, printing and mailing of prospectuses and sales literature. "Shareholder Service Fees" compensate those persons who respond to investor inquiries. Shareholder Servicing Fees can be paid inside or outside of a fund Yes Other Expenses Includes all expenses not listed above, including custodial, legal, accounting, transfer agent, 401(k) Plan Fees of …the How and other administrative expenses fund. Does Your Plan Compare? | Yes| 10 No

Sources of Provider Revenues (“Economic Benefit”) n Proprietary Product Placement – Fully “bundled” using

Sources of Provider Revenues (“Economic Benefit”) n Proprietary Product Placement – Fully “bundled” using ALL/MOSTLY proprietary product is MOST profitable – Internal “revenue crediting rates” (for proprietary funds) differ by fund company – Default fund option (Stable Value, Life Cycle, Managed Accounts) – Spreads (fixed income products) n Non-Proprietary Product Revenues – – – Revenue Sharing Arrangement Sales Commission Yield Spread 12 b-1 Fees Sub Transfer Fees Shareholder Service Fees Brokerage “shelf-space” Fees Preferred Provider or Placement Fees “Soft-dollar” Brokerage (proprietary & third-party research) Directed brokerage (for investment products other than mutual funds) Other: Allowances, Subsidies, Conferences, Reciprocal Referrals, Directed Brokerage, Rollovers upon Termination 401(k) Plan Fees … How Does Your Plan Compare? | | 11

How do 401(k) Service Providers make their money? EXPENSE RATIO (Component Parts) (%)* CATEGOR

How do 401(k) Service Providers make their money? EXPENSE RATIO (Component Parts) (%)* CATEGOR Y AVG EXP. RATIO (%)* REVENU E SHARE TO SERVICE PROVIDE R Inv. Mgt. Distributi on Other EXP. RATIO * Proprietary Stable Value 6 bp 0 bp 44 bp 50 bp N/A 44 bp Fixed Income PIMCO Total Return (Ins) 25 bp 0 bp 18 bp 43 bp 102 bp 0 bp Allocation Strategy Moderate Allocation Strategy 40 bp 18 bp 58 bp 108 bp 16 bp Balanced Proprietary Balanced (Ins) 75 bp 0 bp 11 bp 86 bp 113 bp 75 bp Allocation Strategy Aggressive Allocation Strategy 63 bp 11 bp 75 bp 113 bp 22 bp Real Estate Morgan Stanley Ins U. S. RE (A) 76 bp 0 bp 13 bp 89 bp 154 bp 10 bp Large Cap Value Proprietary Equity (I) 80 bp 80 bp 134 bp 50 bp Large Cap Index BGI Equity Index (Q) 5 bp 0 bp 1 bp 6 bp 115 bp 1 bp Large Cap Growth Fund of America (R 5) 28 bp 0 bp 8 bp 36 bp 142 bp 5 bp 141 bp 10 bp 143 bp | 12 0 bp INVESTMENT CATEGORY INVESTMENT OPTION Cash Equivalent Janus Adviser Mid Cap Value 64 bp 0 bp 11 bp 75 bp Source: Morningstar 2006; Fund Prospectus Value (I) 401(k) Plan Fees … How Does Your Plan Compare? | Vanguard Mid-Cap Index Mid Cap Index 11 bp 0 bp 2 bp 13 bp

About NFA • Founded 1982 • Nationwide Self-Regulatory Org. for US Futures Industry •

About NFA • Founded 1982 • Nationwide Self-Regulatory Org. for US Futures Industry • Not for Profit • 249 Employees • $51 M 401(k)/Profit Sharing Plan • 99% Participation; 7. 14% Avg. Deferral • Auto-enrollment @ 6% • QDIA – Balanced Fund • 13 Funds plus 3 AA Funds • Avg. participant uses 7 plan funds • Formal Plan Oversight 401(k) Plan Fees … How Does Your Plan Compare? | | 13

Fiduciary Committee – Plan Oversight n Retained Responsibilities (Non-Delegated) – – – Fiduciary Oversight

Fiduciary Committee – Plan Oversight n Retained Responsibilities (Non-Delegated) – – – Fiduciary Oversight (“Benefit Plan Trustees”) Committee Charter and Investment Policy Fund Manager Performance Fee Analysis (Total and Vendor-specific) Service Provider Oversight n Delegated Committee Responsibilities – – – Trust (directed-trustee) Plan Administration (day-to-day recordkeeping) Investment Advisory ERISA Counsel Communications and Education 401(k) Plan Fees … How Does Your Plan Compare? | | 14

“State-of-the-Plan” Report to Board of Directors n Purpose: Inform Board of the Actions of

“State-of-the-Plan” Report to Board of Directors n Purpose: Inform Board of the Actions of their Appointed Fiduciaries – Plan Amendments and Material Modifications – Claims and Appeals – Plan Administration – Plan Demographics – Plan Qualification – Litigation – Agents (ERISA Counsel; Investment Advisor) – Plan Expenses – Plan Funds 401(k) Plan Fees … How Does Your Plan Compare? | | 15

Plan Fees Paid by Participants ANNUAL PARTICIPANT PAID FEES EXPENSE (based upon Invested Plan

Plan Fees Paid by Participants ANNUAL PARTICIPANT PAID FEES EXPENSE (based upon Invested Plan Assets of $50, 500, 000 as of 12/31/2006) Fees for Plan Administration $131, 144 or $338/participant 26 basis points Fees for Investment Management, Shareholder, Distribution and Other Services $235, 788 or $608/participant 47 basis points Total Annual Fees Paid by Participants $366, 932 or $946/participant 73 basis points NFA’s Average Account Balance is ~ $132, 000 401(k) Plan Fees … How Does Your Plan Compare? | | 16

Which is the right way to allocate expenses? Pro Rata Large Accounts Pay More

Which is the right way to allocate expenses? Pro Rata Large Accounts Pay More Per Capita Everyone Pays the Same 401(k) Plan Fees … How Does Your Plan Compare? | | 17

Benchmarking Fees … Easier Said Than Done n Few Benchmarking Surveys Capture all Expenses

Benchmarking Fees … Easier Said Than Done n Few Benchmarking Surveys Capture all Expenses – Loan, Distribution, and Ad Hoc Fees can be substantial – Managed Account fees are often not counted – Expenses paid by plan sponsors are often not reported (as a result overall fee looks low when compared to all-in expensing) n Not all Plans are created equal – What provider services do you use? – How complex is your plan design? – How “demanding” are you? n What services are of value to “your” plan and participants, but incur additional cost? – Independent Investment Advisor – ERISA Counsel – Demographic-specific communications – Financial education and one-on-one counseling n Index and ETF Plans vs. Active Manager Plans – Active Manager Plans tend to look expensive when compared to all-Index or ETF plans – Expenses alone do not tell the entire story; return and risk must also be included 401(k) Plan Fees … How Does Your Plan Compare? | | 18

Comparing Cost and Performance COMPOSITION Asset Class/Style Class Moderate Allocation Fund Aggressive Allocation Naïve*

Comparing Cost and Performance COMPOSITION Asset Class/Style Class Moderate Allocation Fund Aggressive Allocation Naïve* Index Fund Cash & Equivalent Schwab Stable Value 10% 10% ------ Investment Grade Bonds PIMCO Total Return D 50% 30% 20% 12% Inflation-Adjusted Bonds PIMCO Real Return Instl ------ 20% ------ 8% 8% Large Cap Value Westwood Equity AAA ------ 11% ------ 17% Large Cap Blend S&P 500 Index 40% ------ 80% ------ Large Cap Growth Fund of America R 4 ------ 9% 9% ------ 13% Midcap Value JP Morgan Midcap Value Sel ------ 5% 5% ------ 8% 8% Midcap Growth Alger Midcap Growth Instl ------ 4% 4% ------ 5% 5% Small Cap Value Royce Low-Priced Stock ------ 3% 3% ------ 6% 6% Small Cap Growth Wasatch Small Cap Growth ------ 2% 2% ------ 4% 4% Real Estate Third Avenue Real Estate Val ------ 3% 3% ------ 8% 8% International Equity Amer Funds Euro. Pac A ------ 3% 3% ------ 14% Emerging Markets Equity Oppenheimer Dev Markets A ------ 5% 5% FIVE YEAR PERFORMANCE** (ending 12/31/2006) Annualized Return 5. 53% 7. 80% 8. 00% 6. 15% 11. 77% 11. 92% Alpha vs. Naïve 0. 00% 2. 31% 2. 79% 0. 00% 5. 54% 6. 06% Beta vs. Naïve 1. 00 0. 97 0. 92 1. 00 0. 95 0. 88 R-Squared vs. Naïve 1. 00 0. 87 0. 82 1. 00 0. 88 0. 84 Standard Deviation 4. 78% 4. 96% 4. 83% 9. 72% 9. 84% 9. 34% Sharpe Ratio Tracking Error vs. Naïve Information Ratio 0. 63 1. 07 1. 14 0. 37 0. 94 1. 01 0. 00% 1. 77% 2. 08% 0. 00% 3. 47% 3. 88% N/A 1. 31 1. 34 N/A 1. 60 1. 56 401(k) Plan Fees … How Does Your Plan Compare? | | 19

What’s Next From Washington? n Revamped Form 5500 – complete disclosure of all expenses

What’s Next From Washington? n Revamped Form 5500 – complete disclosure of all expenses paid by plan (w/o any context, of course) n Required disclosures/notices to participants n “Periodic” review of plan expenses by an “independent source” n Surprises? 401(k) Plan Fees … How Does Your Plan Compare? | | 20

A Fiduciary’s “Fee-Related” To Do List … n Service provider revenue/service assessment n Comparing

A Fiduciary’s “Fee-Related” To Do List … n Service provider revenue/service assessment n Comparing plan investments and plan costs to correct benchmarks n Share class selection and monitoring n Service provider revenue capitation ($ or bp) n Default fund selection (Who recommended? What were revenue implications? ) n Pension plan vs. 401(k) due diligence n Reporting fiduciary actions to Board of Directors If you don’t know what you are doing … ERISA requires you to find someone who does. 401(k) Plan Fees … How Does Your Plan Compare? | | 21

Thanks for coming! Wayne G. Bogosian Michael Crowley President, CEO Associate General Counsel The

Thanks for coming! Wayne G. Bogosian Michael Crowley President, CEO Associate General Counsel The PFE Group NFA 144 Turnpike Road, Suite 360 Southborough, MA 01772 (508) 683 -1400, ext. 205 wayne_bogosian@pfegroup. com 200 West Madison, Suite 1600 Chicago, IL 60606 (312) 781 -1388 mcrowley@nfa. futures. org 401(k) Plan Fees … How Does Your Plan Compare? | | 22

Interpreting Modern Portfolio Theory Statistics Annualized Return – the constant one-year rate of return

Interpreting Modern Portfolio Theory Statistics Annualized Return – the constant one-year rate of return on an investment which would result in the same total return as the actual annual returns over the performance period being measured. Example: A three-year investment has three yearly returns of +5%, -4%, and +10%, for a total return of +10. 9%. The annualized return on this investment is +3. 5%, since a return of 3. 5% for each of the three years would result in the same total return of +10. 9% with compounding. Alpha – the expected return of the actively managed portfolio when the return of the index is 0%; it is determined by comparing the monthly or quarterly returns of the portfolio and the index over a period of time. A positive alpha is always good, although it is not abnormal to have a low alpha accompanied by a high beta (see beta below) Beta – a measure of the market-related risk of a portfolio, expressed as a multiple of its benchmark. A beta of 1. 10 means that the portfolio is 10% riskier than its benchmark; a beta of 0. 90 means that the portfolio is 10% less risky than its benchmark. Modern Portfolio Theory states that higher betas should be rewarded with proportionally higher returns over long investment periods. R-Squared (R 2) – a measure of the effectiveness of the alpha and beta statistics in estimating the expected risk and return levels of a portfolio. As a rule of thumb, an R 2 statistic of 0. 70 or higher means that there is a significant relationship between the performance of the portfolio and the performance of the index to which it is being compared. Lower numbers are acceptable if the measurement period is longer, and vice-versa Standard Deviation – a measure of the consistency of periodic returns of a portfolio or index over time. For any given twelve-month period, the investment has a 68% probability of producing a return within the range defined by its long-term average return plus or minus its standard deviation. Similarly, it has a 95% chance of providing a return in the range defined by its long-term average return plus or minus two standard deviations. Sharpe Ratio – a measure of the tradeoff between the value added through active management of a portfolio and the amount of risk incurred through the management process. There is no constant number that is considered “good” or “bad”; the only objective for an actively managed portfolio is to produce a Sharpe Ratio that is higher than its benchmark. The Sharpe Ratio uses standard deviation as its measure of risk. (Note: The Sharpe Ratio statistic has a slight bias in favor of more conservative portfolios. ) Tracking Error – A measure of the similarity between the periodic returns of a portfolio and its benchmark. A low tracking error indicates a high degree of similarity, and vice-versa. Like the standard deviation statistic, the interpretation of tracking error is that a portfolio has a 68% probability of performing in a range defined by its benchmark return plus or minus its tracking error over any twelve-month period. There is no “good” or “bad” tracking error – it is simply a reflection of the investment policy of the portfolio manager. Information Ratio – a comparable measure to the Sharpe Ratio in that it measures the tradeoff between return and risk; however, the return used is the alpha, and the measure of risk is the tracking error. 401(k) Plan Fees … How Does Your Plan Compare? | | 23

Disclaimers and Attributions General Notes § The information contained in this document is as

Disclaimers and Attributions General Notes § The information contained in this document is as of December 31, 2006 and is believed to be accurate. Data was gathered from a variety of sources believed to be reliable, including Morningstar, Mobius, Ibbotson Associates, Standard & Poor’s and other third-party administrators. Every attempt has been made to verify data; however, no guarantees or endorsements of accuracy are to be made. Any discrepancies between the numbers contained herein and other sources are unintentional. § Total returns include changes in share values and reinvestment of dividends and capital gains distributions, if any. Gross returns will be reduced by management fees and other expenses in an amount proportional to performance. For example, a fund with a gross return of 10% and an expense ratio of 1% will experience a reduction of 1. 1%. Individual client performance numbers may differ from reported numbers for a fund due to contributions or withdrawals made during the performance measurement period. Past performance is no guarantee of future results. § Performance numbers calculated by PFE Advisors, LLC are compliant with AIMR standards. AIMR had no involvement with the preparation of this report. § All references to Company Plans reflect information that was available at the time of publication. Actual benefits will be based upon information and formulas contained in the appropriate Plan Document(s). The inclusion of non-plan funds in certain exhibits is for comparative purposes only, and does not imply an endorsement of those funds by PFE Advisors, LLC. § The information on specific investments contained in this document is not an offer to sell, nor a solicitation of an offer to buy, these securities. Plan sponsors should review fund prospectuses and other relevant information before making any investment decisions. § This presentation is for the exclusive use of PFE Advisors, LLC and its respective clients, and is not authorized for public distribution. All Copyrights are the property of their respective owners. Index Definitions § The S&P 500 is an unmanaged index of 500 large-cap domestic stocks that is commonly used as a proxy for the large-cap stock market. Historically, the index has targeted a composition of 400 industrial companies, 40 financial companies, 40 utility companies, and 20 transportation companies. The index does not contain real estate investment trusts. Changes in the index composition may be made at any time. Performance numbers for the index are a size-weighted average of the performance numbers for each index constituent. § The Russell 2000 is an unmanaged index consisting of the smallest 2000 stocks in the Russell 3000 universe, which in itself consists of the largest 3000 publicly-traded domestic companies. This index is commonly used as a proxy for the liquid small-cap stock market. The index is reconstructed on July 1 of each year. Performance numbers for the index are a size-weighted average of the performance numbers for each index constituent. § The MSCI EAFE® Index (Europe, Australasia, Far East) is a free float-adjusted market capitalization index that is designed to measure developed market equity performance, excluding the US & Canada. The index consists of the following 21 developed market country indices: Australia, Austria, Belgium, Denmark, Finland, France, Germany, Greece, Hong Kong, Ireland, Italy, Japan, the Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland the United Kingdom. § The NAREIT index is an unmanaged index of securities that meet the definition of Real Estate Investment Trust (REIT) and are traded on the NYSE, AMEX, or NASDAQ. REITs are investments in rental properties, and are required to pay out 95% of their earnings each year as dividends. Performance numbers for the index are a size-weighted average of the performance numbers for each index constituent. § The Lehman Aggregate Bond Index is an unmanaged index made up of the following fixed-income securities: all debt securities issues to the public by the U. S. Government or its agencies, as well as quasi-federal corporations or corporate debt guaranteed by the U. S. Government; all public obligations of the U. S. Treasury except flower bonds and foreigntargeted issues; all 15 -year and 30 -year fixed-rate securities backed by mortgage pools of GNMA, FHLMC, and FNMA, with the exception of graduated payment mortgages, manufactured home mortgages, and graduated equity mortgages; and all publicly-issued, fixed-rate, non-convertible, investment-grade, dollar-denominated, SEC-registered corporate debt securities with at least one year to maturity and an outstanding par value of at least $100 million. © 2007 PFE Advisors, LLC, an independent investment advisory firm and wholly-owned subsidiary of PFE Consultants, Inc. d/b/a The PFE Group. 401(k) Plan Fees … How Does Your Plan Compare? | | 24