Please click the image on right to see the Plan Sponsor Gateway. This is a live demo, with updated and current mutual fund prices. This Gateway gives the plan sponsor a solid “hands-on” experience of how robust and well-organized Open Architecture 401k really is. Most plans can be fully administered in only 10 minutes a month...or less. The plan sponsor has complete control over all plan operations---and can view participants' accounts, easily process loan, hardship and distribution requests, print timely audit reports, and perform compliance testing, and all other functions quickly, easily, and with total confidence using Open Architecture 401k's intuitive, proven, rock-solid administration.

Entrance into your Open Architecture 401k plan administration and participation occurs, respectively, through your customized Plan Sponsor Gateway and Plan Participant Gateway.

• The Plan Sponsor Gateway gives your authorized personnel Internet-based access to self-service 401k administration.
• The Plan Participant Gateway gives everyone in your company Internet-based access to self-service 401k participation, which includes access to information about your company plan and participating in it.
• The exact features and capabilities accessible through each gateway depend on the customization options you as Plan Sponsor choose for your company plan and those that the eligible employee chooses for his or her individual 401k account.

The Plan Sponsor Gateway is the plan sponsor's path to customized self-service plan administration, including convenient communication with company employees.

• Access is user-name and password protected. Only those individuals at your company whom you authorize can enter your Plan Sponsor Gateway.
• Functions are separated into two streams: Plan configuration functions (see next topic) control overall plan information and operation parameters, while day-to-day plan administration functions (see the topic after next) power and monitor day-to-day administrative activity.

The below topics explain the key features within the Plan Sponsor Gateway.

As a plan sponsor, you use Open Architecture 401k to further set up your customized 401k plan's operation. Plan configuration functions include:

• Configure Client - Allows authorized user(s) to view and edit the company name, address, tax ID number(s), etc. to be associated with the selected plan (you can run more than one type of retirement plan via Open Architecture 401k; contact us for details) as well as to establish the log-in names and passwords authorizing entry to the plan's day-to-day administration functions.
• Configure Bulletins - Enables authorized user(s) to create Bulletins that will be visible by each employee as they log into the system.
• Configure Divisions - Enables authorized user(s) to create and modify Divisions to attach to employee data. Common Division categories include branch office locations and company departments (accounting, marketing, etc.).
• Configure Employees - Enables authorized user(s) to add, delete, or modify data relating to company employees. Data can be displayed in terms of any of a variety of data fields, including established Divisions.

As a plan sponsor, you will use Open Architecture 401k to run your customized 401k plan. Day-to-day plan administration functions include:

• Plans - Lets you view and edit (as appropriate) a list of your company's existing plan(s) (you can use Open Architecture 401k to run more than one retirement plan) and to model a new plan, if desired, for approval submission.
• Transaction Log - Displays a list of transactions for the currently selected plan as well as the status of each transaction (pending, held, settled, etc.).
• Participants - Leads into the main participant activity functions for the selected plan. The initial panel displays a list of plan participants and links to the Plan Participant Gateway for access to direct management of employees' accounts, including loan, transfer, and distribution activity.
• Investments - Displays the investments currently offered within the selected plan. Open Architecture 401k allows for no-load and/or load mutual funds (including no-load institutional mutual funds), self-directed brokerage accounts, annuities, and more. In fact, if the IRS says it's OK for 401k investment, it's likely compatible with Open Architecture 401k.
• Process Contributions - Allows the people your company authorizes to process regular as well as "special" 401k contributions, such as transfers from a previous employer's 401k plan. Contribution payroll information can be uploaded from a text file directly into the processing grid. The system will perform automatic validation checking and report any errors or rule violations encountered in the data.
  
  The authorized user(s) can do all plan processing at once or save data and continue working with it later.
  
  Once data is submitted for processing, it is held by the system until verification of funds is received through the asset custodian.
  
• Participant Loans, Transfers, and Distributions - Accessed through the Plan Participant Gateway, the Loans, Transfers and Distributions panel displays a list of pending loan, distribution, and transfer requests submitted by plan participants. Authorized plan administration user(s) can approve or deny the requests, and can also model new loans, distributions, and transfers for plan participants.
  
  In addition, authorized plan administration user(s) can key in loan payoffs, partial payoffs, and re-amortizations. In the case of payoffs or partial payoffs, transactions remain in Pending status until verification of funds is received from the asset custodian.
  
• Activity - Accessed through the Plan Participant Gateway, the Activity panel displays a detailed list of buy/sell activity for all participants of the selected plan. Data can be filtered by date range, participant, investment name, and source.

If you like, try out some or all of these functions using our demo Plan Sponsor Gateway, which is accessible through our Product Demos section.

Open Architecture 401k's Forms and Reports functions include:

• Testing & Reports - The Advisor can run the following tests and reports for any number of plans at will:
• The Global Audit Log - maintains a record of ALL activity performed throughout the system, including activities at the general system administration level. Sponsor can search for information by client, plan, date range, plan administrator, participant, and/or transaction type.

Tests:

• ACP Test-Section 401(m)
• ADP Test-Section 401(k)
• Calendar Year Deferral Limit Test-402(g)
• Compensation Nondiscrimination
• Maximum Annual Additions Test-415 (c)
• Ratio Percentage Test
• Top Heavy Test- Section 416

Reports:

• Age 50 Reports
• Balance Less Than $5000
• Deferral Change Summary Report
• Distribution Activity Summary
• Investment Elections Report
• Loans-Activity Summary
• Loans-Delinquent Loans
• Loans-New Loan Summary
• Loans-Reconciliation
• Participant Address Report
• Participant Allocation Report
• Participant Contribution Summary
• Participant Hours & Compensation Summary
• Participant Statements
• Participant Synoptic Report
• Participant Vesting Detail
• Participant Vesting Summary
• Participation Allocation Summary
• Required Minimum Distributions

Open Architecture 401k employs technological as well as operational security features designed to safeguard all information without overly complicating the end-user experience. Security features range from the simple to the complex. For instance:

• Plan sponsors have the option of designating a person or persons (generally the company's 401k plan administrator) who must approve account changes that participants make via the Plan Participant Gateway before the changes can become effective.
• 128-Bit Encryption Security - Encryption helps protect private financial information as it travels over the Internet communications between the browser on the user's computer. Data is scrambled with 128 bit encryption security, then de-scrambled when it arrives back into the user's computer web browser.
• Confidential Log-in - Account information is accessible only with a valid log-in and PIN or password. Users who do not successfully enter login and password are locked-out after a few attempts.
• Automatic Log-off - The system terminates the user session if computer remains inactive for a designated period of time. This log-off feature helps prevent on-lookers from accessing confidential information if the user steps away from the computer.
• User Activity Reports + Logs - The system records all successful and unsuccessful sign-on, monitors all activity, including unusual activity or discrepancies in user sign-on, and locks out users who do not correctly enter the registered login and password for the account, whether that account be a participant account or the administration account.

Please click the image on right to see the Plan Participant Gateway. This is a live demo, with updated and current mutual fund prices. This Gateway gives you a solid “hands-on” experience of what your employees will use to manage their 401k investments online. participants can review past and current investments, change their investment line-up, apply for a loan, hardship, or in-service distribution, update beneficiary and other personal information, change their password, send the plan sponsor a confidential email, and download and print-out a current statement.

Open Architecture 401k empowers plan participants to serve themselves to their 401k account activity and information, which they can do at any time, day or night, from any location connected to the Internet.

• Open Architecture 401k self-service plan participation gives eligible employees on-the-spot access to enrolling in the plan, updating personal information, making and updating investment designations, viewing and printing activity reports and account statements, and 401k loan, transfer and distribution modeling and submissions, among other things.
• General as well as plan-specific investment information is available at a mouse click.
• Self-service plan participation is extremely convenient for plan participants and can greatly boost plan participation rates.
• Self-service plan participation means far less work for your in-house plan administrator.

Open Architecture 401k creates a home page for each plan participant. Upon login, the participant arrives at his or her home page.

• As plan sponsor, you can have Open Architecture 401k display certain categories of information on each participant's home page, for instance, the participant's investment designations, account balances, and/or recent account activity.
• As plan sponsor, you can compose Bulletins via your Plan Sponsor Gateway for posting on employees' home pages. (Scroll up or use the middle tab in this page's topics menu to read about Open Architecture 401k's plan administration features, which are accessed via the Plan Sponsor Gateway.)

Plan participants never have to involve your plan administrator in routine account information updates:

• Plan participants, after logging into their customized section of your 401k plan's Plan Participant Gateway, can update their personal information themselves, online, at their leisure. Participants can amend their address, telephone number(s), disbursement preferences, passwords, and more. Open Architecture 401k immediately notifies your designated plan administrator via e-mail of any changes.
• As plan sponsor, you can elect to mandate that a designated party (likely your in-house plan administrator) approve changes before they can become effective.

Plan participants never have to go through your 401k plan administrator to access and/or amend salary deferral rates and/or investment designations.

• The participant's customized Plan Participant Gateway displays available plan investments and indicates those to which the participant is contributing and at what rates.
• The participant can, at any time, opt to amend his/her designations.
• Your company can elect to mandate that your 401k plan administrator approve changes before they become effective.
• All investment and salary deferral designations are restricted within Open Architecture 401k by rates allowable under the current federal law.

Plan participants never have to go through your 401k plan administrator for transaction information on existing loans, transfers, distributions, etc.. Instead, they simply go online and access the information themselves.

In addition, participants considering a new loan, transfer or distribution can have Open Architecture 401k model the effect of such on their 401k account:

• During the modeling process, Open Architecture 401k calculates the availability of funds based on money sources, aged buckets (if applicable), and other applicable rules.
• To accept a new loan, transfer or distribution, the participant must correctly answer one of the security questions that the employee established in setting up his or her Log In name and Password.
• New loans, distributions, and transfers must be approved by the 401k plan administrator and are indicated as Pending until so approved.
• Open Architecture 401k gathers all the information the 401k plan administrator needs to approve or deny an application.
• You can elect to have Open Architecture 401k automatically decline any new submissions for loans, transfers or distributions if an application for such from the employee is already in the system as pending approval of your plan administrator. This works as a safeguard against plan participants flooding the system with applications for the same transaction while the plan administrator awaits, for instance, consent of spouse approval.

Within the Loans, Transfers, and Distributions panel, the participant also has the option of downloading and/or printing necessary forms to request loans, distributions, and transfers in person from your 401k plan administrator and to manually perform other related account maintenance activities.

Plan participants enter the Plan Participant Gateway by keying in the user name and password they establish during their first visit.

• Your 401k plan administrator issues a temporary password for that first visit to allow an employee entrance into the system.
• Eligible employees not currently enrolled in the plan can easily be granted temporary passwords by your 401k plan administrator so they can learn about the company 401k plan, investigate the online self-service system and see how easy saving money via the company's online 401k plan will be.
• When establishing their user name and password, plan participants also establish three identifying questions and answers, such as "Mother's maiden name?" answer: "Johnson." The questions are later used to confirm the participant's identity when the participant attempts certain transactions (for instance, applying for a 401k loan, or retrieval of his/her password).
• The system houses a log of each employee's user name, password and three questions/answers within the Plan Sponsor Gateway. Plan participants can request help from your 401k plan administrator (via the Open Architecture 401k, in person, by phone, etc.) at any time.

Please click the image on right to see the Financial Advisor Gateway. This is a live demo, with updated and current mutual fund prices. This Gateway gives financial advisors a solid “hands-on” experience of how robust and well-organized Open Architecture 401k really is. Most plans can be fully administered in only 10 minutes a month...or less. The financial advisor gets an excellent “birds-eye” view of all Plan Participants' past and current investments and balances, and can also monitor the operations performed by the Plan Sponsor.

Advisors are able to view summary plan balances of all their plans on the Open Architecture 401k system, and view the specifics of each plan and individual participant accounts. To keep their clients informed about investments regarding the plan, the built in email message center allows the advisor to post bulletins and send/receive messages with plan sponsors and participants.

Advisors can view and print detailed histories of a variety of administration reports, including contribution statements for participants, allocation logs, loan activity, liquidations, transfers, and distributions. All Plan Reports are instantly created as Adobe PDF documents for printing or archiving.

The Advisor can run the following tests and reports for any number of plans at will:

• The Global Audit Log - maintains a record of ALL activity performed throughout the system, including activities at the general system administration level. Advisor can search for information by client, plan, date range, plan administrator, participant, and/or transaction type.

Tests:

• ACP Test-Section 401(m)
• ADP Test-Section 401(k)
• Calendar Year Deferral Limit Test-402(g)
• Compensation Nondiscrimination
• Maximum Annual Additions Test-415 (c)
• Ratio Percentage Test
• Top Heavy Test- Section 416

Reports:

• Age 50 Report
• Balance Less Than $5000
• Deferral Change Summary Report
• Distribution Activity Summary
• Investment Elections Report
• Loans-Activity Summary
• Loans-Delinquent Loans
• Loans-New Loan Summary
• Loans-Reconciliation
• Participant Address Report
• Participant Allocation Report
• Participant Contribution Summary
• Participant Hours & Compensation Summary
• Participant Statements
• Participant Synoptic Report
• Participant Vesting Detail
• Participant Vesting Summary
• Participation Allocation Summary
• Required Minimum Distributions

The following is a summary, in question and answer form, of the Department of Labor's position regarding financial advisory services rendered to 401(k) pension plans. These guidelines can change without notice, so it is important to review them with your legal council before relying upon them:

Is it legal to provide investment advice services or portfolio management services, or both, to ERISA plan participants?

Would doing nothing, in other words, not providing these services to participants, be safer from a legal perspective?

What is the Department of Labor's view on providing advice and/or portfolio management?

Is providing investment education a sufficient way to fulfill my role as a fiduciary?

If we decide to provide advice or portfolio management, how do we go about selecting a service provider to satisfy our fiduciary responsibilities?

Is it legal to provide investment advice services or portfolio management services, or both, to ERISA plan participants?

Yes. In fact, the U.S. Department of Labor is on record saying that it wants participants to have as much assistance as possible, and that it encourages plan sponsors to offer participants investment advice if plan sponsors determine their participants need it to make informed decisions. In addition, the DOL, Congress and the Administration have increasingly voiced strong support of investment advice for participants.

Portfolio management services have been used in ERISA plans for many years. ERISA includes provisions for plan sponsors to appoint investment managers, and the Department of Labor regulations on 404(c) plans discuss various examples involving investment management services.

Would doing nothing, in other words, not providing these services to participants, be safer from a legal perspective?

Not really. We think that providing advice and/or portfolio management can actually reduce your risk as a plan sponsor. Employees who make uninformed decisions about savings and investing are less likely to be prepared for their retirements. By making advice and/or portfolio management available, you ensure that your employees have access to the help and information they need to plan for their futures, decreasing the chances of dissatisfaction and possible litigation.

Furthermore, if you as a plan sponsor/fiduciary know that the participants in your plan need help with investing for retirement, you should provide the needed help, whether it is education, advice, professional management, or all three. This is supported by ERISA section 404(a)(1)(B), which requires that all plan fiduciaries exercise their responsibilities "with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims." (Emphasis added.)

What is the Department of Labor's view on providing advice and/or portfolio management?

The Department of Labor has stated that providing advice can actually reduce a sponsor's fiduciary risk. In a major policy speech on September 15, 2000, Leslie Kramerich, Acting Assistant Secretary of Labor, Pension and Welfare Benefits Administration had this to say on the subject:

"[W]e believe that employers can be responsive to the investment education and investment advice needs of their employees, without significant burdens or risk of liability. The selection of providers that offer informed, unbiased and appropriate investment education or investment advice will, in our view, not only serve to increase the likelihood of employees achieving retirement security, but also significantly reduce the potential for employee dissatisfaction and possible litigation."

Is providing investment education a sufficient way to fulfill my role as a fiduciary?

Informed policymakers caution that relying on education alone is no longer enough. According to DOL's current Assistant Secretary, "[m]eaningful comprehensive investment advice is more important now than it has ever been" and "[i]nvestment education, while important, is simply not enough." Assistant Secretary Ann L. Combs delivered this message to Congress on July 17, 2001 in connection with testimony on the subject of "Retirement Security Advice Legislation" to the Subcommittee on Employer-Employee Relations of the House Committee on Education and the Workforce.