Upon hiring us as Investment Advisor, an implementation process is undertaken which involves the following steps:

Step 1: Plan Level Analysis & Industry Review

We want to understand how the Retirement Program fits into our clients' broader benefits strategy. Our goal will be to learn about the unique drivers and demographics that make the organization what it is today and to incorporate that understanding into everything that follows.

Also included in this phase will be a thorough education of the Committee on issues involved in the current retirement investment marketplace. Such issues may include, but are not limited to:

• Contemporary Investment Theory and Current Legislative Issues
  We educate our clients as to the latest interpretations of compliance with Section 404(c) and compliance with the fiduciary requirements of ERISA.
  
  
• Record-keeping Vendor Selection and Management
  We help our clients to be sure they are selecting the vendor with the most appropriate platform and product line for their Plan.
  
  
• Revenue Sharing and Mutual Fund/Retirement Plan Pricing Strategies
  Having built several different retirement plan service platforms, we are uniquely qualified to help our clients receive as much benefit as possible from any fee sharing arrangements between investment managers and their chosen record-keeper.
  
  
• Investment Education Strategies
  Our experiences in creating educational materials, conducting hundreds of education and enrollment meetings, and counseling participants helps us determine the effectiveness and appropriateness of different education strategies for our clients.

Step 2: Investment Policy Statement

We write customized Investment Policy Statements with each of our clients. These statements specifically establish:

• The roles and responsibilities of the Plan Investment Committee and the Investment Consultant hired to assist in the fulfillment of the Committee's fiduciary duties.
  
  
• Appropriate investment asset classes for inclusion in the Plan's menu of alternatives.
  
  
• A prudent process for selecting funds/managers to be made available for participant direction.
  
  
• An investment alternative, or strategy, as a "default" to which all assets will be directed by the Plan Investment Committee in the absence of a positive election by a participant or beneficiary.
  
  
• A prudent process by which selected funds/managers shall be monitored for compliance with the Policy.

Step 3: Investment Review

Using the criteria established in the Investment Policy Statement and an understanding of our clients' objectives and the Plan demographics, we review the current investment selection and the available investment alternatives offered by the record-keeper and make specific recommendations for fund changes, eliminations, and/or replacements. We will also negotiate directly with record-keepers to make those changes.

Part of our investment analysis includes quantitative measures such as performance measurements, relative risk measurements, portfolio concentration, expenses, and style consistency. Equally important, however, is the analysis of various qualitative measures such as corporate governance, manager compensation, manager tenure, internal procedure and controls, selling disciplines, litigation or investigation, and so on. The process will include, but not be limited evaluating the following issues:

• Asset Class Diversification
  It is critical that investments offered by a Plan deliver unique risk and return characteristics. Many Plans find themselves holding multiple investments that are holding very similar, if not identical, underlying securities. We investigate investment lineups to identify overlapping funds. We also identify any menu "gaps.
  
  
• Relative Performance
  It is impossible to determine the future performance of any fund. It is possible, however, to identify investments, managers and strategies that have consistently delivered above benchmark performance over longer periods of time. Performance is evaluated both with respect to annualized performance over multiple year periods, and return consistency on a period-by-period basis.
  
  
• Management Quality
  It is important to understand how a given alternative achieved its results and who was responsible for that return. As a result, determining management tenure and the identifying the process of management change are crucial steps in evaluating funds. The recent mutual fund trading scandal has also pointed out how important corporate governance and organization structure can be.
  
  
• Portfolio Consistency
  As part of the overall goals of maintaining asset class diversification and generating consistent performance within that asset class, we evaluate the historical ability of the investment managers to stay within their asset class and style categories in both favorable and unfavorable market conditions.
  
  
• Fee Minimization & Revenue Maximization
  All other things being equal, our bias will always be to find the least expensive alternative available.