Disclosure of Compensation for Pension Plan Clients

Direct Compensation

Segal clients pay us directly for services in three ways –

Through a negotiated annual retainer amount, generally payable in monthly installments, covering specified services;

On a flat fee basis for specific projects; and

Through periodic billings based on our hourly time charges

Your specific arrangement is detailed in your retainer agreement with Segal, or described in other communications between you and Segal.  If you would like a copy of your most recent retainer or other agreement with us, please call your Segal representative.  A list of our offices appears below.  Alternatively, please call Allyson Daniels at 212-251-5367, and she will handle your request.

Indirect Compensation

Effective January 1, 2013, we do not receive indirect compensation related to our pension plan clients.

Insurance brokerage services for fiduciary liability insurance, fidelity bonding, employment practice liability insurance, and cyber liability insurance are no longer provided by The Segal Company, but are instead offered by Segal Select Insurance Services, Inc. (Segal Select), a wholly-owned subsidiary of The Segal Group.  For information regarding compensation paid to Segal Select, see the disclosure at: http://www.segalco.com/uploads/Compensation-Insurance-Brokerage-Services.pdf

In any case in which a client requests assistance with the purchase of an annuity, the work is performed by Segal Advisors, Inc. (dba Segal Rogerscasey).   For information regarding compensation paid to Segal Rogerscasey, see the disclosure at: http://www.segalrc.com/disclosure-of-compensation/

Gifts, gratuities, and non-monetary compensation

From time to time, third-party vendors may provide Segal (and its affiliates) with non-monetary gifts and gratuities, such as promotional items (i.e., coffee mugs, calendars, or gift baskets), and access to certain industry related conferences and meals associated with those conferences (collectively, “gifts”).  Segal has implemented policies and procedures intended to identify, quantify, and track gifts received by it and its affiliates.  Pursuant to rules established by the Department of Labor, Segal has implemented a policy for allocating the value of a gift among multiple clients, where applicable.  Under such policy, where potentially reportable compensation is received by Segal (including its affiliates) in connection with several clients, Segal will first divide the fair market value of such gift by the number of individual clients to which such gift is reasonably applicable and then allocate the result to each affected client to determine if it exceeds the de minimis threshold under the Section 408(b)(2) regulation and related and associated guidance.  Based on historic trends, Segal does not expect to receive gifts in excess of the de minimis threshold under the regulations with respect to your Account.

Compensation for Termination of Your Account

We do not receive a termination fee or apply a penalty when your agreement with Segal is terminated.