Independent Guide, Trusted Partner

Castle Rock Investment Company Participates in PLANSPONSOR National Conference Panel

September 13th, 2013

Michele Suriano, President of Castle Rock, recently participated in a panel at the PLANSPONSOR National Conference in Chicago, “Metric Taking: Going beyond the participation rate when gauging retirement plan success.” The panel encompassed the following topics:

  • Leading Indicators: Suriano uses the following leading indicators: median deferral rate broken down by HCE and NHCEs, percent using auto-escalate, percent using catch-up, percent maximizing company match, percent of assets in auto-diversified options and percent using auto-rebalancing.
  • Benchmarking: Suriano uses the Plan Design Optimization Report from Fiduciary Benchmarks, Inc. to benchmark retirement readiness. She also recommends creating a median-participant “avatar” to measure plan success, which is a composite representative of a particular plan, taking into account the median age, salary, deferral rate and account balance of that specific population. Suriano then compares the avatar against the National Savings Rate Guidelines for Individuals.
  • Fees: Suriano stressed that fees have become a huge issue, although they have very little impact on participant outcome, compared to deferral rate. She recommends using the 401K Averages Book to evaluate plan fees. She has done conducted RFIs with price requests for her clients as an educational tool, which may reveal advancements in the marketplace that aren’t being provided by the current provider. She stressed the importance of researching fees because, “What gets measured gets improved.”
  • Goals and Objectves: Suriano determines her clients’ goals and objectives upfront and includes it on the first page of their quarterly report. She recommends writing down the plan’s goals and objectives since there is turnover on committees.

Click Here to Listen to the Full Panel

For more information, please contact Castle Rock Investment Company at 303-725-7086.

Metric Taking: Going beyond the participation rate when gauging retirement plan success

August 16th, 2013

Michele Suriano, President of Castle Rock, recently participated in a panel at the PLANSPONSOR National Conference, “Metric Taking: Going beyond the participation rate when gauging retirement plan success.” The panel encompassed the following topics:

Part I:  What should plan sponsors be thinking about and keep in mind
Part II:  What benchmarks are available today? Pros and Pitfalls
Part III:  What is the future of benchmarks for plan success

Click Here to Listen to the Panel

For more information, please contact Castle Rock Investment Company at 303-725-7086.

Webinar: Retirement Drain: Fees, Fees, Fees…

May 31st, 2013

Did you miss our webinar, “Retirement Drain: Fees, Fees, Fees…?” Don’t despair, we recorded the whole thing.

Click here to listen to the webinar

This webinar builds on the PBS FRONTLINE presentation, “The Retirement Gamble,” and the fees associated with retirement savings plans. We review:

  • The impact of unnecessary fees
  • What hidden fees to look for
  • Talking to your employees about investments and fees
  • Benefits of hiring a fiduciary

If you have questions about the webinar, or regarding the Frontline program, please contact Castle Rock Investment Company at 303-725-7086.

Surprise! Here’s Your 401K Distribution

May 12th, 2013

(one great way to annoy and piss off your customers)

by Celeste Jacroux (Guest Blogger)

Today I arrived home, got the mail and noticed an important-looking envelope from an investment house that rhymes with “Midelity”.  Generally, I don’t get interesting mail.  Most of it consists of direct mail, bills, and the cherished Title 9 or REI sale catalog.  I open this letter from “Midelity” and see a check.  Woohoo!  Money!  But wait, why are they sending me money?

Back in December, I had sent in paperwork to rollover my entire 401k from “Midelity” to Vanguard.  I had put a lot of thought into consolidating all of my retirement investments and had sought advice from a trusted financial advisor friend.  The bulk of the money had rolled over in December or January.  Apparently, there was some sort of distribution in the funds or stock I held after the transfer and on an arbitrary date in May, Fidelity, I mean “Midelity”, went through all accounts of those that were no longer employees and had less than a certain amount of money, and sent checks to those people.  Made out to the individuals.  Minus taxes.  Yeah, that’s right.  I now had a check made to me, less almost $200 that was already sent to the U.S. government.  Thanks “Midelity”!

Now, I happen to have worked for another mutual fund company in my lifetime and was fairly certain that this was not a good thing in many ways.  I called Midelity to ask why this was sent and got the answer that it was a “sweep” of accounts.  Apparently I had not called them after a letter was sent to me asking how I wanted the funds distributed.  With no response from me, did they distribute the funds the same way the previous rollover was done?  Of course not!  Their default process was to distribute funds directly to the owner.  As many of you know, my options at this point are:

  1. Keep the money and, in addition to paying taxes, pay the 10% penalty for early withdrawal on the entire amount.
  2. Sign over the check (within 60 days), less the taxes to a rollover account, knowing that I will get a refund of some of those taxes, but will also be penalized 10% for the amount of the tax withdrawal.
  3. Cash the check, then write a new check for the gross amount of the distribution and deposit into a rollover account. No penalty and I will receive my taxes back….. when I file them next year.
  4. Convince, threaten or cajole the 401k company to rectify their mistake.  Good luck with that.

This is wrong on so many levels!  As an investor, I am livid!  As a marketer, I have ridiculous amounts of scorn and a boatload of passion to take the time to call out companies that have violated the most basic ‘customer first’ rules. With a background in investing, Iknew that I needed to take extra steps but had to confirm what they were.  The average person would have no idea that there was a problem or know to fix it. So, here is my list of what “Midelity” did wrong and what they can do to fix it.

  1. All of this could have been avoided if “Midelity” simply followed the directions for the initial rollover.  The money would have been transferred to my rollover account, and I would have noticed it on my next statement.  If it is all about CYA (and I have no doubt that it is), just have a box that can be checked on the initial rollover forms that states that any additional funds that are added to the account after the initial transfer will simply be transferred in the same way at a later date.
  2. A single letter to notify a person that you are about to take money out of their bank account (to make up the tax withdrawal), force a possible tax penalty and cause headaches is not enough.  There are numerous ways to communicate with customers..  A single form of outdated communication is not enough today.  Make the effort.  Because if a company doesn’t, they will soon find out how many forms of communication can hurt them.
  3. Defaulting a process to the most painful choice for your customers is NOT a way to win loyalty.  There was no need to default to a distribution, unless the sole reason is that a company doesn’t want to maintain low balance accounts.  If that is the case, shout that loud and clear.  Make your audience abundantly aware that you don’t want their business before making life difficult for them.  Otherwise, change the process so that the default is not obnoxious, annoying and irritating.  Those are never great words to describe a business.
  4. After receiving my call and hearing my annoyance, nothing was done to rectify the situation on their end.  No admission of a mistake and no offer to reverse the situation.  Companies make mistakes once in a while.  That’s okay.  It’s in how they handle it that shows what kind of company they are.  In fact, rectifying mistakes is how you gain your most loyal customers.  Give more power to your front line people.  And have your policy makers answer phones just a single day of every month to learn the effects of their policies.Don’t blame the mistake on the company plan.  I realize that the customer service rep has to follow the plan rules, but who helped the company set up those rules in the first place?  Why hasn’t someone pointed out to the plan sponsor that their rules are not good?

It doesn’t matter how big you are.  If you don’t treat your customer fairly, someone else will.  Thanks for letting me guest blog!

Celeste Jacroux
Guest Blogger for Castle Rock Investment Company

Tip: Plan sponsors can instruct their recordkeepers to follow the original distribution instructions when liquidating a participant account.  It’s a good customer service practice that is rarely instituted.

Castle Rock Investment Company Client Named a Finalist for 2012 PLANSPONSOR of the Year

April 1st, 2013

Castle Rock Investment Company is pleased to announce that its client – Platte Valley Financial Service Companies, Inc. a Scottsbluff, Nebraska-based banking and insurance company – has been named a finalist for 2012 PLANSPONSOR of the Year.

Each year, the editors of PLANSPONSOR magazine—the industry’s leading resource for retirement-benefits related news—recognize employers that demonstrate leadership in providing a more secure retirement for their employees.

Platte Valley Financial Service Companies, Inc. strategically revamped their retirement program once its adviser, Michele Suriano of Castle Rock Investment Co., suggested they focus on their employees’ retirement readiness. The company incentivized its 266 employees by implementing a “super-match” program, offering a standard 3 percent contribution to their retirement accounts, along with increased match percentages as their own contributions increase.

Read More in the Official Press Release

2013 Compliance Calendar

February 3rd, 2013

We realize that the onset of a new year means many deadlines for our industry. To help you, Castle Rock Investment Company has compiled a compliance calendar to help you keep track of all of the important 2012 compliance dates!

Click Here to View the 2013 Compliance Calendar

For more information, please contact us at 303-725-7086, or via e-mail at Have a great 2013!



408(b)(2) Regulation Checklist

March 16th, 2012

The Department of Labor (“DOL”) published its final Section 408(b)(2) regulation in February, prescribing the disclosure requirements that are required from retirement plan service providers. Fiduciaries and service providers of covered plans must ensure to abide by the new regulation by July 1, 2012. Now that you have had a chance to review the regulation, expect the disclosures to cross your desk soon.

Castle Rock Investment Company (CRIC) has compiled a checklist to help plan sponsors determine if they are responsible for a covered plan and outline the steps necessary to ensure that fiduciaries have fulfilled their new obligations. You will need to establish a process to keep track of the disclosures as they flood your desk since a summary roadmap is not required yet. Please contact us at 303-725-7086 for a copy of the checklist.

Please plan to attend our workshop on May 10th where we will teach a step-by-step-process for plan sponsors that want to take a hands-on approach in fulfilling their 408(b)(2) obligations. Please be on the lookout for more details on this informative event.

If you have any questions, or need assistance, please feel free to contact me at 303-725-7086.

Best Regards,

Michele L. Suriano, QPFC, TGPC, AIF®

It’s Time for Nondiscrimination Testing!

January 13th, 2012

Happy New Year from Castle Rock Investment Company!

The New Year means many tasks for your to-do list, which may include passing the Actual Deferral Percentage (ADP) test. If you fail the test, it means that your company’s highly compensated employees, or those who made more than $110,000 in 2010 or own five percent of the employer, made excess 401(k) contributions in 2011.

These excess funds must be refunded back to the employees by March 15th, 2012. Failure to do so could result in a 10 percent penalty by the IRS.

There are many reasons why you may have failed nondiscrimination testing, including that your plan is not properly aligned with your employees’ needs, or that your administrator is not properly monitoring the situation.

If you have questions about this process, please feel free to contact me at 303.725.7086 or by email at

Best Regards,

Michele L. Suriano, QPFC, TGPC, AIF®

401(k) Questionnaire Project

June 12th, 2011

Back in May of 2010 the IRS sent letters to 1,200 401(k) plan sponsors instructing them to complete the 401(k) Questionnaireonline by visiting a secure website and using a PIN number provided in the cover letter.     Their stated intention is to:

  • better understand 401(k) plan compliance issues,
  • determine how their tools and voluntary compliance programs are working, and
  • identify participant awareness and plan sponsor compliance issues

The IRS wants to ”encourage all plan sponsors to use the Questionnaire as an internal control tool to review your plan and determine if it is in compliance.

They also announced that “Non-reponders” will be subjected to a full-scope examination to provide the data needed for their 401(k) market segment analysis.

If your plan is a 401(k) I encourage you to review the questionnaire and highlight the areas of uncertainty that should be addressed.  If you need assistance please feel free to contact me.

New IRS Initiative Targets 401(k) Plan Compliance

June 12th, 2011

by Ed Frado, J.D.

IRS recently announced that, starting in March, it would begin sending questionnaires to “a random sample of 401(k) plan sponsors” for a new initiative to gauge the “health of these plans.”  As background, the IRS provides on its website several tools (e.g., a “401(k) Fix-It Guide”) intended to encourage plan sponsors to conduct periodic reviews of their plans and to self-correct documentary or operational compliance issues discovered in those reviews.  Top IRS officials have stressed over the past couple of years that it will be a lot less expensive if plan sponsors find errors and self-correct them than having the IRS discover those errors during a plan examination.

In announcing this new initiative, the IRS stated that the questionnaire will elicit information that will help the IRS to determine if the tools referenced above are being used and are working.  Overall, the IRS noted that it drafted the questionnaire to help the IRS “better understand compliance behaviors.”

What will the IRS do with the questionnaire answers?  The IRS stated that it will prepare a report of findings and publish that on its website, as well as update its website materials “to better serve the needs of the plan sponsors.”  However, even a small amount of cynicism could lead to the thought that the IRS may eventually use the questionnaire responses as a way to target plans for an examination.

In any event, plan sponsors that receive a questionnaire under this initiative should consider discussing it with the plan’s service provider and having the responses reviewed before submitting the completed questionnaire to the IRS.  Also, this serves as yet another reminder that plan sponsors should conduct periodic reviews that are distinct from the plan’s annual ERISA audit and self-correct any discovered compliance issues.

Ed Frado is an employee benefits attorney who has specialized exclusively in this field for more than 11 years.  At Denver Compensation & Benefits, LLC, he advises clients in a wide array of employee benefits issues.  Also, Ed is a frequent speaker at seminars,  conferences, and accounting firms’ in-house training for employee benefits auditors.  You can reach Ed at

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