Defined Contribution in Review A Quarterly Briefing for Plan Sponsors: 1Q16

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Our Defined Contribution in Review is designed to help CEOs, CFOs, Treasurers, Human Resource and Benefits Professionals and Investment Committees stay abreast of recent events that could have an impact on plan or plan participants. Inside you will find the following information: Quarterly Highlights: A summary of plans and sponsors making the news Participants’ Corner: Timely insights about the retirement readiness of plan participants Legislative Review: A summary of new and pending legislation Regulatory Review: News out of the Department of Labor and other regulatory bodies Legal Review: An update on high-profile ERISA cases We hope you will find the information helpful and we are happy to answer any questions you may have.

What’s Inside

Quarterly Updates

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PLANSPONSOR Announces 2016 Plan Sponsors of the Year

For additional information, please see www.plansponsor.com/awards

Category Winner

Corporate 401(k) < $15M RL Worth & Associates

Corporate 401(k) $15M-<$25M National Cattlemen’s Beef Association

Corporate 401(k) $25M-<$50M OSG USA, Inc.

Corporate 401(k) $50M-<$200M Dawn Food Products

Corporate 401(k) $200M-$1B CGB Enterprises/Zen-Noh Grain

Corporate 401(k) >$1B Liberty Mutual Insurance Company

Public DC City of Baltimore

403(b) Mental Health Cooperative, Inc.

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RL Worth & Associates > The San Antonio-based commercial real estate developer recently overhauled

its $2.6M plan with the assistance of a new advisor who serves as a 3(21) nondiscretionary fiduciary at both the sponsor and participant levels

> Recent changes to the RL Worth plan included: ► Establishment of a 6-person investment committee; ► Development of an Investment Policy Statement; ► Benchmarking of plan fees and expenses; and ► Customized advice and one-on-one participant meetings

> The plan lineup was also simplified, and each asset class now offers an active and passive option, helping to reduce investment fees by 57%

> To date, approximately half of the 29 participants have met individually with the plan advisor

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National Cattlemen’s Beef Association > After learning that employees were on track to replace only 22% of pre-

retirement income, not including Social Security, the National Cattlemen’s Beef Association took steps to improve the retirement readiness of its plan’s 130 active participants

> In 2015, auto-enrollment was increased from 4% to 6%, and participants contributing less than 6% were re-enrolled at that amount. Auto-escalation was also added, up to a 16% cap

> In 2016, the default deferral was increased to 8%, helping participants take full advantage of the company’s dollar-for-dollar match up to 8% of salary

> Using 2015 data, the median retirement income replacement ratio improved to 36% and when Social Security was included, the replacement ratio was at 69%

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OSG USA, Inc. > The Illinois-based manufacturer of high-tech cutting tools has established a

75% income replacement ratio goal for its $25.1M plan and 440 participants

> In 2008, the company introduced auto-enrollment at 6% so participants would receive the full employer dollar-for-dollar match, and in 2015, all eligible employees were re-enrolled at 6%; a 1% auto-escalation program was also added

> Also in 2015, the company’s record-keeper rolled out improved plan-level reporting about participant readiness and better tools to help participants achieve the 75% income replacement goal

> Currently, the median income replacement ratio is 68% and fewer than 30 employees are not enrolled or participate at less than 6% of salary; the company is planning to conduct individual education meetings with the help of its plan’s advisor within the next year for this group of employees

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Dawn Food Products > While the international bakery supplier does not auto-enroll employees into

the company’s $154.7M plan, it does default new participants into risk-based portfolios and, upon reaching age 55, balances are transferred into an investment vehicle that provides a guaranteed stream of income in retirement ► Currently, 35% of plan assets for participants age 55 or older are in the guaranteed

income investment and 57.4% of total plan assets are in the risk-based portfolios

> To help mitigate the use of plan loans, the company partnered with PayCheck Direct which allows employees to purchase big-ticket items through payroll deduction

> The company is also rolling out a financial wellness seminar series that will include four 90-minute sessions on budgeting, insurance and generating cash flow in retirement ► The free sessions will be held on-site but outside of business hours so spouses

can attend

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CGB Enterprises/Zen-Noh Grain > The grain transportation company based in Mandeville, Louisiana, has a 94%

participation rate, average deferral of 10.5% and an 84% average income replacement ratio

> In 2014, the company switched its Stable Value to a separate account structure to reduce costs and improve the crediting rate for plan participants. It later added a real asset option to the plan menu which invests in TIPS, real estate and commodities

> Realizing that not all hourly employees were licensed to use a computer and therefore lacked access during the workday, the company licensed their entire workforce to company email, which could be accessed via smartphone; all employees now receive electronic and paper mail from the record keeper

> The opt-out rate for the plan’s 6% auto-enrollment is less than 1%, and the plan matches 50% for every $1 dollar up to the IRS limit

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Liberty Mutual Insurance Company > The Boston-based insurer recently pared down its investment lineup from 20

to 10 offerings and moved to white-label funds focused on asset allocation rather than offering name brands

> Following the plan repositioning, 31% of participants made an active election to reallocate their portfolios; those who didn’t make an election were defaulted into the plan’s custom, age-appropriate target-date portfolios

> The plan’s auto-enrollment default is 6% of salary, and the company provides a dollar-for-dollar match up to 3% plus an additional 3% discretionary match depending upon financial performance; the company also sponsors a cash balance plan and contributes 4.5% of salary for eligible employees

> The company recently added a Roth 401(k) feature and is considering in-plan conversions, separate investment elections across money sources, a self-directed brokerage window and retirement income solutions

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City of Baltimore > All employees hired since July 1, 2014, are required to make a 5%

contribution to a newly established 401(a) plan and have access to a supplemental 457(b) plan

> The city also provides a Defined Benefit plan with hybrid and non-hybrid options

> Recently the Board of Trustees voted to change the $330M 457 plan’s QDIA to a managed account, and reduced the number of funds from 22 to 11

> The city conducted 29 benefit maximization seminars at 13 city locations to explain the changes; nearly 1,000 employees attended at least one seminar with more than 500 taking some direct affirmative action, including scheduling a one-on-one retirement planning session with a retirement plan counselor

> The average deferral rate for the approximately 10,000 employees in both DC plans is 13%

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Mental Health Cooperative, Inc. > When Mental Health Cooperative changed 403(b) providers in 2014, it

reduced the $14M plan’s investment costs by nearly 50%

> The plan also introduced a Roth deferral option and changed its QDIA to an index-based passive target-date fund series

> The plan also offers custom target-date funds, created from the plan’s investment menu, which offer more active managers, and constructed by a 3(38) service provider; nearly 90% of participants are invested in either passive or active target-date funds

> The nonprofit matching formula is 35% of 6% of deferrals; non-elective contributions of 3% on the first $45,000 of salary and 6% on salary over $45,000 are also made

> Mental Health conducts annual, mandatory retirement readiness meetings where personalized statements are provided

Participants’ Corner

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Survey Reveals Favorable Impressions of DC Plans by American Households > The Investment Company Institute (ICI) released its eighth annual American

Views on Defined Contribution Plan Savings report. Among the findings:

> 72% of U.S. households had favorable impressions of 401(k) plans in 2015, up from 71% in 2014 and 66% in 2013;

> About nine out of 10 households with DC accounts agreed that these plans helped them think about the long term and made it easier to save;

> About eight in 10 DC-owning households said the tax treatment of their retirement plans was a big incentive to contribute; and

> Nearly all households with DC accounts agreed that it was important to have choice in, and control of, the investments in their DC plans. 84% indicated that their DC plan offered a good lineup of investment options

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The New Flexible Retirement Report Offers New Vision > The Aegon Center for Longevity and Retirement found that among 16,000

respondents in 15 countries, a new vision of retirement is emerging that includes a desire to work longer; continue earning income, stay active and involved, and fully retire at an older age – while freeing up time for family, friends and enjoyment

> The report finds, however, that few employers have employment practices in place to support these aspirations and, in some cases, new laws are needed to facilitate this new vision of retirement

> The report lists a number of recommendations that employers and governments might consider to address increases in longevity and mitigate the challenges created by an aging population

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Transamerica Provides Sixteen Facts About Women’s Retirement Outlook > As part of its annual Retirement Survey of American Workers, the Transamerica

Center for Retirement Studies has published research showing that women are at a greater risk of not achieving a financially secure retirement compared to men

> Some of the published facts include:

► Few women are very confident about retirement: Only 12% of women are very confident in their ability to fully retire with a comfortable lifestyle, compared to 16% of men;

► Most women plan to retire after age 65 or not at all: 56% of women plan to retire after age 65 or do not plan to retire, a slightly lower percentage than men (59%); and

► Most baby boomer women don’t have a backup plan: Among baby boomers, only 21% of women have a backup plan if forced into retirement sooner than expected

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New Research Indicates Surprising Motivations Behind the Decision to Retire > New research by Fidelity Investments has concluded that financial goals

aren’t the key trigger for retirement but rather, health and lifestyle are stronger factors

> Also, the transition to retirement was found to be a gradual process. Most employees experience three distinct phases of “pretirement,” which are rooted in life stage, not age:

► Climbing – 10+ years to retirement: Finances outweigh other factors

► Base camp – 2-9 years to retirement: Starting to feel like they have enough

► Summit – less than 2 years to retirement: Feeling the lure of leisure and family

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Willis Towers Watson Encourages Employers to Help Participants Leverage Roth 401(k)s > In a new paper, Capturing the Opportunity of Roth 401(k) Contributions, Willis

Towers Watson points out that according to their most recent DC sponsor survey, the percentage of employers offering a Roth option has increased to 54% today from 46% in 2012, yet the percentage of employees making Roth contributions remains very low at 10%

> The paper highlights the potential advantages a Roth 401(k) offers participants, suggestions for evaluating Roth calculators, and ideas for more effective employee education and communications

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A Formal Written Retirement Plan Boosts Investor Confidence > A new LIMRA Secure Retirement Institute study finds that pre-retirees and

retirees (ages 55-75 with financial assets of $100,000+) who have a formal written retirement plan are more than twice as likely to feel very prepared for retirement than those without one (50% vs. 17%)

> The study, The Benefits of Retirement Planning, also revealed that: ► 80% of those with a formal plan have estimated how many years their assets will

last into retirement, nearly double of those who don’t have a formal written plan (42%) and

► More than three quarters of pre-retirees and retirees who have a formal written plan (78%) have developed a specific plan for generating retirement income from savings; only 38% of those without a formal written plan have done this planning

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Survey Shows Wide Misuse of Target-Date Funds > According to a new report by Financial Engines, only one-quarter (26%) of

plan participants are using target-date funds as intended, while two-out-of-three (68%) target-date fund investors hold only a portion of their total investments (less than 90%) in these funds

> The report, Not So Simple: Why Target-Date Funds Are Widely Misused by Retirement Investors, concluded that investor overconfidence and a desire for greater diversification, not a lack of understanding, are behind the misuse

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Broadridge: Consumers Don’t Want Communication, They Want Personal Guidance > A new paper from Broadridge Financial called The Experience Revolution

suggests that plan sponsors must migrate from providing employee education to creating an experience that allows participants to access information when, where and how they prefer, in a way that is easy, convenient and enjoyable

> The paper lists 10 practices to create strong participant experiences including:

► A personalized “next best step” messaging approach to communications;

► Retirement income projections for each participant;

► Targeted campaigns supplemented with life stage and life event content and messaging; and

► “People like me” benchmarks and comparisons

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Trend Toward 401(k) Among Higher Education Sponsors Continues > In Transamerica’s 2015 Retirement Plans for Institutions of Higher Education,

a survey of 166 public and 110 private colleges, fewer than two-thirds (64%) are sponsoring a 403(b) plan while almost half (46%) now offer a 401(k) to some segment of their workforce

> Additionally, the percentage of institutions that offer only individual contracts dropped from 44% to 40% in the last year, while the institutions offering only a group contract increased from 35% to 36%, and institutions offering both a group contract and individual contracts increased from 15% to 18%

> 17% of institutions partner with a plan advisor or consultant and twice as many (38%) are considering hiring an advisor within the next year

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The Guardian: Company Benefits Positively Impact Employee Security > The Guardian’s 3rd Annual Workplace Benefits Study found that employees

believe their benefits positively impact their financial security, and they feel they need help

► Only 3 in 10 workers feel financially secure and the study shows what little security they feel hinges – to a large degree – on the insurance and savings benefits they receive at the workplace

> The study examines key areas that present opportunities and challenges including:

► The impact of the Affordable Care Act;

► Advancements in outsourcing and technology; and

► Tailored benefits and communications

Legislative Review

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White House Budget Proposal Contains Numerous Retirement Provisions > On February 9, 2016, the Obama Administration released its budget request

for Fiscal Year 2017. Specific retirement provisions include: ► Allow unaffiliated employers to adopt a Defined Contribution Multiple Employer

Plan (MEP); ► Impose an overall cap on the amount individuals can save in tax-advantaged

accounts (approximately $3.4M based on today’s interest rates); ► Limit post-death payments to non-spouse beneficiaries to a period not to exceed

five years; ► Exempt individuals from required minimum distributions if the aggregate value of

their retirement accounts is less than $100,000; ► Impose required minimum distributions on Roth IRAs; and ► Limit Roth conversions to pre-tax dollars

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New Jersey Employers Could Be Required to Provide Retirement Accounts > New Jersey has become the latest state to introduce legislation that would

require certain employers that do not sponsor their own retirement plans to automatically enroll employees into a state-run program

> The “New Jersey Secure Choice Savings Program” would apply to businesses in existence for at least two years with 25 or more employees and require an automatic salary deferral of 3% unless employees opt out

> Employer contributions would not be required

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Bill Introduces New Type of Retirement Plan > Senator Jeff Merkley (D-OR) has introduced the American Savings Account

Act of 2016, which is aimed at employees of businesses that offer no retirement plan and at self-employed individuals

> Employees would be automatically enrolled starting at 3% of salary, which can be maintained, increased, reduced or halted; self-employed professionals would have the opportunity to proactively enroll

> The maximum employee contribution would equal the deferral limit that applies to 401(k) plans

> A board of directors would establish policies for the investment and management of the fund to which contributions would be made

Regulatory Review

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Reminder: Second Quarter Compliance Calendar April June April 1: > Required beginning date for participants attaining age 70½

or retiring after age 70½ in prior year [Deadline for taking first required minimum distribution (RMD) under Internal Revenue Code (IRC) Section 401(a)(9)]

April 15: > Deadline for processing corrective distributions for IRC

Section 402(g) excesses

April 18: > Deadline for filing individual and/or partnership returns and

contribution deadline for deductibility for unincorporated entities (without extension)

June 30: > Deadline for processing

corrective distributions for failed ADP/ACP test from plans with EACA without the 10% excise tax

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The Final DOL Fiduciary Rule Expected to be Issued Soon > The DOL submitted the final version of its Conflict of Interest rule to the Office

of Management and Budget (OMB) at the end of January 2016, officially starting the 90-day clock for the rule to be issued

> Legislation continues to be introduced in Congress in an effort to stop the rule, but even if a bill does pass, it is likely to face a Presidential veto

> It is possible that even after the final rule is issued, lawsuits may be filed challenging the substantive content of the rule and/or the process by which it was promulgated

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IRS Notice 2016-03 Modifies the Determination Letter Program > In IRS Notice 2016-03, the IRS provides the following clarifications to the

determination letter process:

► The current determination letter program for individually designed plans will end with the Cycle A filers. Controlled groups may only file their plans under Cycle A if they previously made a Cycle A filing election;

► The expiration dates included in determination letters issued prior to January 4, 2016, are no longer operative; and

► Sponsors of pre-approved Defined Contribution plans have until April 30, 2016, to amend their plans; this deadline has been extended to April 30, 2017, only for sponsors who first adopt a pre-approved Defined Contribution plan after January 1, 2016

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IRS Allows Mid-Year Changes to Safe Harbor Plans > On January 19, 2016, the IRS issued Notice 2016-6 which provides that a safe

harbor plan may generally be amended mid-year if: > The plan satisfies the notice and election opportunity conditions, if applicable, and > The change is not a prohibited mid-year change listed in the Notice

> The guidance does not apply to mid-year changes that were already permitted such as: > Adoption of a short plan year; > Adoption of safe harbor plan status by plans that provide for a safe harbor non-elective

contribution if contingent and follow up notices are provided; and > Reduction or suspension of safe harbor contributions or changing from a safe harbor

plan to a non-safe harbor plan

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Two Changes to IRS Form 5500 > When new questions were added to the 2015 Form, the IRS described the

questions as optional for plan year 2015. However, in its most recent instructions, the IRS has specifically advised plan sponsors not to complete these questions for the 2015 plan year. The decision to delay is because the Office of Management and Budget did not approve these questions when the forms were issued last year

> The new Fixing America’s Surface Transportations Act (FAST Act) repealed the recently introduced 3½ month automatic extension to file Form 5500 and reinstated the original 2½ month extension period

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IRS Proposes Regulations Limiting New Comparability Allocations > The IRS’s proposal would impose a new “reasonable classification”

requirement on highly compensated employee rate groups that will make it significantly harder for plans that allocate these rate groups on an individual or specific basis to pass the general nondiscrimination test for cross-tested Defined Contribution plans

> The regulations are proposed to become effective the plan year beginning after the regulations are finalized

> The IRS is currently accepting comments until April 28, 2016, with a public hearing scheduled for May 19, 2016

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DOL Increases Scrutiny of Large DB Sponsors > The Department of Labor has recently implemented an initiative to investigate

the manner in which Defined Benefit plans of Fortune 500 companies comply with the required minimum distribution rules set forth in Section 401(a)(9)

> The initiative is focused on plan procedures in three key areas: ► Locating missing participants; ► Informing deferred vested participants that a retirement benefit is payable; and ► Commencing benefit payments when the participant reaches age 70½

Legal Review

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Chevron Hit with Excessive Fee Lawsuit > A class-action lawsuit has been brought against the fiduciaries of Chevron’s

$19B 401(k) plan. The allegations include:

> Participants lost more than $130M in retirement savings because the plan offered a money market fund rather than a stable-value fund as its capital preservation option;

> Failure to select the lowest-cost share class for several of the plan’s investment options cost the participants more than $20M in unnecessary fees;

> Chevron should have investigated non-mutual fund investment options such as separately managed accounts and collective trust funds; and

> Recordkeeping costs were excessive because fees were based on plan assets without a cap and the company failed to engage in a competitive bidding process within the past six years

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Anthem Sued Over 401(k) Fees > In Bell v. Anthem, a class of participants in the $5.1B 401(k) plan are suing

the plan sponsor and retirement plan committee. According to the lawsuit:

► Recordkeeping fees varied between $42 and $94 per participant annually, but a reasonable “outside limit” would have been $30 per participant;

► The plan should have used a higher return stable value fund rather than a very low return money market fund; and

► The retirement committee should have considered reducing investment costs by using collective trust funds rather than mutual funds

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Oracle Faces Class-Action Lawsuit > On January 22, 2016, an excessive fee lawsuit was filed against Oracle

alleging that the plan’s fiduciary paid excessive recordkeeping fees

> The lawsuit alleges that Oracle paid between $68 and $140 per participant rather than a reasonable per head fee of $25

► Between 2009 and 2015, the number of participants in the plan increased from 38,000 to 60,000 and plan assets increased from $3.6B to $11B

> Additionally, the lawsuit alleges that the plan’s small-cap value, inflation-protection and small-mid cap growth investments should not have been selected due to underperformance

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U.S. Supreme Court Again Remands Amgen Case > In Harris v. Amgen, the U.S. Supreme Court reversed, for the second time, a

decision by the U.S. Court of Appeals for the Ninth Circuit holding that participants in the Amgen plan had validly stated a claim that plan fiduciaries had breached their duty of prudence by continuing to invest plan assets in company stock

> The Supreme Court held that it “has not found sufficient facts and allegations to state a claim for breach of the duty of prudence” and that the circuit court did not correctly apply the Fifth Third Bancorp v. Dudenhoeffer decision

> The lower courts will now decide whether or not the participants may amend their complaint to meet the standards set forth in the Fifth Third decision

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District Court Rules in Reverse Stock Drop Case > In Tatum v. R.J. Reynolds Tobacco Co., on remand from the U.S. Court of

Appeals for the Fourth Circuit, the Middle District Court of North Carolina held that a hypothetical fiduciary would have decided to divest Nabisco company stock from its 401(k) plan, and that the plan fiduciaries were therefore not personally liable for damages

> The case was remanded from the Fourth Circuit, which ruled that a “would have” rather than a “could have” standard should be applied after the lower court originally dismissed the case concluding that a prudent fiduciary “could have” made the same decision

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Failure to Furnish Custodial Agreement Violated ERISA > A trial court has ruled that a 401(k) plan administrator violated ERISA when it

failed to furnish a copy of a custodial agreement between the plan sponsor and a trust company in response to a participant’s request

> The court found that the custodial agreement in this case was a formal, legal document that dictated important aspects of participants’ benefits under the plan including where and how accounts would be invested and who would manage and administer them

> The court deferred a decision on whether to impose penalties and, if so, their amount noting unresolved factual disputes regarding whether there was intentional misconduct on the part of the plan administrator, or harm to the participant

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Phone Calls Alone Fail to Change Beneficiary > On remand from the Ninth Circuit, the District Court ruled that a deceased

plan participant who contacted his plan’s call center to change beneficiaries from his former spouse to his son, but failed to execute new beneficiary paperwork, did not change the designation

> The District Court earlier ruled in favor of the ex-spouse but on appeal, the Ninth Circuit noted that the plan document did not require non-married participants to make their designation in writing, and ruled in favor of the decedent’s son who had filed a competing claim to receive the benefits

Defined Contribution Capabilities

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Janus Defined Contribution Capabilities > 40+ years of industry experience

> Retirement excellence and leadership

> Three highly specialized investment managers: Janus, INTECH and Perkins

> Experience in:

► Fiduciary responsibility

► Industry trends

► Legislative and regulatory updates

> $21.076 Billion in DC Assets Under Management as of 12/31/15

> Products utilized by the top 25 DC record keepers in the industry

> Availability on over 200 recordkeeping platforms

Janus Capital Group Inc. is a global asset manager offering individual investors and institutional clients complementary asset management disciplines. Janus Capital Management LLC, Perkins Investment Management LLC and INTECH Investment Management LLC serve as investment advisers. Perkins and INTECH are indirect subsidiaries of Janus Capital Group Inc.

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Janus QDIA Capabilities Dynamic Allocation Risk-Based

Janus Balanced Fund

Perkins Value Plus Income Fund

Janus Global Allocation Fund - Conservative

Janus Global Allocation Fund - Moderate

Janus Global Allocation Fund - Growth

A: JDBAX C: JABCX S: JABRX I: JBALX

R: JDBRX T: JABAX

A: JPVAX C: JPVCX S: JPVSX I: JPVIX

T: JPVTX

A: JCAAX C: JCACX S: JCASX I: JCAIX

T: JSPCX

A: JMOAX C: JMOCX S: JMOSX I: JMOIX

T: JSPMX

A: JGCAX C: JGCCX S: JGCSX I: JGCIX

T: JSPGX

Managers(s) Marc Pinto, CFA Darrell Watters

Jeremiah Buckley, CFA Mayur Saigal

Theodore Thome, CFA Darrell Watters

Ashwin Alankar, Ph.D. Enrique Chang

Description Equity and fixed income product capitalizes on Janus' uniquely integrated firmwide research

Flexibly allocates between Perkins income-focused equity and Janus

fundamental-informed fixed income

Diversified portfolios of Janus, Perkins and INTECH mutual funds with target risk determined allocations across global equity, fixed income and alternatives

Asset Class Allocation Process

Ongoing at the discretion of the portfolio management team

Ongoing at the discretion of the portfolio management team

Long-term strategic asset allocations with ongoing monitoring and rebalancing of underlying funds. Oversight provided by

Janus‘ asset allocation committee

Allocation Ranges Equity 35-65%

Fixed Income 35-65% Alternatives 0%

Equity 40-60% Fixed Income 40-60%

Equity 30-50% Fixed Income 50-65%

Alternatives 0-20% International Allocation: ~40%

Equity 45-65% Fixed Income 30-45% Alternatives 5-20%

International Allocation: ~40%

Equity 70-85% Fixed Income 10-25%

Alternatives 5-20% International Allocation: ~40%

Fund Inception Date 9/1/92 7/30/10 12/30/05

Benchmark S&P 500® Index Russell 1000® Value Index Barclays Global Aggregate Bond Index

MSCI All Country World IndexSM

MSCI All Country World IndexSM

S&P 500® Index measures broad U.S. equity performance. Russell 1000® Growth Index measures the performance of those Russell 1000® companies with higher price-to-book ratios and higher forecasted growth values. Barclays Global Aggregate Bond Index is a broad-based measure of the global investment grade fixed-rate debt markets. MSCI All Country World ex-U.S. IndexSM is an unmanaged, free float-adjusted, market capitalization weighted index composed of stocks of companies located in countries throughout the world, excluding the United States. It is designed to measure equity market performance in global developed and emerging markets outside the United States. The index includes reinvestment of dividends, net of foreign withholding taxes.

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Continuing Education

> Janus offers accredited continuing education seminars for financial advisors, CPAs, human resources professionals and other retirement and financial industry participants

> Each seminar qualifies for one credit hour of continuing education (CE) credit

> Live, in-person, on-demand and webcast options available

> Available for CFP®, CIMA®, CPWA®, CRPC®, CRPS®, CRC®, AIF®, CPA®, HR and CEBS designations

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Additional Support Provided by Janus

Experience in: > Fiduciary Responsibility

> Wealth Management

> Industry Trends

> Legislative and Regulatory Updates

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About the Author

Matt Sommer, CFP®, CPWA®, CFA®

Vice President, Retirement Strategy Group Matt Sommer is Vice President and leads the Defined Contribution and Wealth Advisor Services team at Janus. In this role, he provides advice and consultation to Financial Advisors surrounding some of today’s most complex retirement issues. His expertise covers a number of areas including regulatory and legislative trends, practitioner best practices, and financial and retirement planning strategies for HNW clients.

Prior to joining Janus, Matt spent 17 years at Morgan Stanley and its predecessors. Matt held a number of senior management positions including Director of Financial Planning at Citi Global Wealth Management and Director of Retirement Planning at Smith Barney.

Matt received his undergraduate degree in Finance from the University of Rhode Island and received a Masters of Business Administration with a specialization in Finance from the Lubin School of Business at Pace University. Matt currently serves on the Investment Management Consultant Association (IMCA) Wealth Management committee and CPWA examination sub-committee.

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Please consider the charges, risks, expenses and investment objectives carefully before investing. For a prospectus or, if available, a summary prospectus containing this and other information, please call Janus at 877.33JANUS (52687) or download the file from janus.com/info. Read it carefully before you invest or send money. A Fund’s performance may be affected by risks that include those associated with nondiversification, non-investment grade debt securities, high-yield/high-risk securities, undervalued or overlooked companies, investments in specific industries or countries and potential conflicts of interest. Additional risks to a Fund may also include, but are not limited to, those associated with investing in foreign securities, emerging markets, initial public offerings, real estate investment trusts (REITs), derivatives, short sales, commodity-linked investments and companies with relatively small market capitalizations. Each Fund has different risks. Please see a Janus prospectus for more information about risks, Fund holdings and other details.

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The information contained herein is provided for informational purposes only and should not be construed as legal or tax advice. Your circumstances may change over time so it may be appropriate for you to evaluate tax strategy with the assistance of a professional tax advisor. Federal and state tax laws and regulations are complex and subject to change. Laws of a particular state or laws that may be applicable to a particular situation may have an impact on the applicability, accuracy, or completeness of the information contained in this document. Janus does not have information related to and does not review or verify your financial or tax situation. Janus is not liable for your financial advisor’s or your use of, or any position taken in reliance on, such information.

A retirement account should be considered a long-term investment. Retirement accounts generally have expenses and account fees, which may impact the value of the account. Non-qualified withdrawals may be subject to taxes and penalties. For more detailed information about taxes, consult a tax attorney or accountant for advice.

No investment strategy can ensure a profit or eliminate the risk of loss.

In preparing this document, Janus has relied upon and assumed, without independent verification, the accuracy and completeness of all information available from public sources. For more information contact your financial advisor.

Janus Distributors, LLC 151 Detroit Street, Denver, CO 80206 I 800.668.0434 I www.janus.com C-0316-660 04-30-17 166-15-40660 04-16