2023 was another record year with over 800 Pension Risk Transfers completed, a 30% increase from 2022. The pace continues in 2024 so it’s not a surprise that the PRT insurer participation has doubled over the past decade. Industry experts explain why the market for PRTs is hot right now and a checklist for plan sponsors and insurance companies considering a PRT.

Webinar Panelists:

  • Ellen Kleinstuber, Principal & Chief Actuary at Bolton
  • Ruth Schau is Sr. Director Pension Solutions at Pacific Life
  • Travis Jones, Senior Compliance & Retirement Consultant at Aon
  • Greg Cunningham, Sr. Sales Executive at The Berwyn Group

Greg: Let’s start with the market. What makes it an ideal time for a PRT?

Ellen (actuary):
So interest rates have gone up significantly in the last couple of years and that that drives down the pricing to purchase annuity contracts. We have the equity markets up. We unfortunately also have PBGC premiums that are high relative to the funded status of many plans and to the PBGC’s single employer system. Plan sponsors or plans are paying premium rates that range from just over $100 to nearly $800 per participant per year and plan sponsors just aren’t perceiving that the cost that they’re incurring is aligned to the value of the benefit that is being received.

There has been a fair amount of legislative and regulatory uncertainty. You know some very favorable law changes that have been targeted to help plan sponsors through the recent Secure acts and even the American Rescue Plan Act. But that adds more complexity.

Travis (consultant):
Following record-breaking years in 2022 and 2023, the PRT market has continued its positive momentum. In early 2024, we actually placed nearly $15 billion of premiums in the first quarter of this year, which is the most for any first quarter in history. Insurance engagement remains really strong with 21 insurance companies that are now in the market, you know, we see anywhere from three to five bidders per engagement on average.

Increased insurance engagement yields better pricing. Both sides of the market are seeing positive momentum right now and that’s coming together to really provide a really robust PRT market in general.

Ruth (insurance):
Big concern I have right now and it’s just more of a market perception that these PRT deals may not be in the best interest in planned participants they’re not necessarily losing security as they move from their employer to an insurance company. In fact, they could be actually gaining even a bit more security for the long run instability. Just thinking that insurance companies this is our business – to manage risk.

Five steps to prepare for a pension risk transfer:

  1. Identify your team and decision makers.
  2. Clean up your data.
  3. Understand your options and risk associated with each.
  4. Understand transactional cost.
  5. How will you communicate to participants.

Identify your team and decision makers.

There’s the internal team and external team. Key players internally include pension administrator, actuary, CFO, ERISA council and the plans trustee. External team members include consultants. Questions to ask: Who’s going to run the deal? Who’s going to be your deal advisor, and who’s going to be responsible for the insurance selection?

Consultant:
It’s really just making sure that you’re working with an experienced partner in light of some of the recent lawsuits. Fiduciary support for the process is now more important than ever. So you want to make sure that the partner is able to provide that and then also just having a partner that understands the mechanics of the market can really improve the overall outcome for the transaction.

Actuary:
Hire an independent fiduciary to select the insurance company because that’s not something that many plan fiduciaries have experience with. So I want to bring in someone else who really knows how to do this. Also consider possibly bringing in a non-fiduciary advisor that serves as an extension of your executive leadership team. As you’re going through the process, who can give you a second opinion on and be a sounding board on the many steps you’re going to have to take. And then many decisions you’re going to have to make along the way that get you up to that final ‘OK, now I’m ready to transact moment’.

Clean up your data.

Accurate participant data will attract more insurance companies and ensure the plan sponsor will get the best pricing. Insurance companies want updated addresses so they don’t have to search for missing participants (at least initially) and geography impacts mortality projections. An accurate death audit is also crucial to make sure overpayments are eliminated before the process begins.

Insurance:
Clean data is super helpful. You know, the more stable data we have without a lot of changes later helps us.

Actuary:
Are there any unresolved compliance issues that affect your data that you want to resolve before termination. So things like missing participants. You want to find those. Do you have terminated vested participants who are past their required beginning date and have missed their required minimum distributions.

Another thing is uncashed checks. Just because the custodian has written the check and sent it, and taking the money out of the trust account doesn’t necessarily mean that that check has been cashed, and I’ve seen some chaos created late in the process when a plan sponsors going to close out their trust account and all of a sudden the custodian says, ‘what do you want me to do with all these checks that are sitting over here in the payment in the float account?’

Understand your options and risk associated with each.

  • Lump Sums: Offer plan participants a one-time cash payment equal to the current value of their accrued benefits.
    • Risk: Large cash outlays can impact short-term finances.
  • Buy-In: Transfer a portion of the plan’s liabilities to a life insurer who takes responsibility for future benefit payments. The plan sponsor remains involved, managing remaining assets.
    • Risk: Ongoing responsibility for plan administration and potential future contributions.
  • Buy-Out: Transfer all liabilities to a life insurer who assumes full responsibility for future benefit payments, completely relieving the plan sponsor.
    • Risk: Highest cost option with complete loss of control over future benefit payments.

Insurance:
I think we’re finally at a cusp where you can take the DB plan and remove it and offer, you know, extremely similar benefits in a DC plan. And you know, almost no impact on participants. They still have the same choices, and in fact maybe even more flexible. When you think of the savings long term and maybe the lesser volatility in the markets, it may be very helpful for budgeting purposes for plan sponsors.

Actuary:
Are you looking at a full pension risk transfer like a planned termination or just a partial risk transfer? Maybe it’s a lump sum window to buy out some of your terminated investor participants? Or are you going to transact with an insurance company to lift out? And what does that do to the interest sensitivity of your liabilities?

Understand your transactional cost.

  • Annuity buy-out premium: This is the core cost – the price the insurer charges to take on pension liabilities. It’s influenced by factors like the size of the pension obligation, number of insurers bidding, the health and number of plan participants (longevity risk), and current interest rates.
  • Advisory fees: Consultants and advisors to help you navigate the PRT process, analyze bids, and ensure you’re getting a good deal.
  • Due diligence costs: Before finalizing a PRT deal, thorough due diligence is essential. This might involve actuarial analysis, financial modeling, and investigation of the insurer’s solvency.

Actuary:
Doing a full versus partial PRT is going to impact your financials and the timing for report. And then on the cash side, think about what the capital needs will be if the plan is underfunded or it’s sitting right there on the cusp and it depends on how well your new broker does in getting you the best pricing. Is there a timing that’s optimal where you going to generate that?

Insurance:
We get more involved sometimes with plan sponsors talking about buy in versus buy out and which fits the goals better, maybe which leads to softer landing for accounting implications and recognition of liabilities.

How will you communicate to participants.

Plan sponsor should explain how the PRT will affect their pension benefits, including any potential changes in payment structure, guarantees, and protections. Provide participants with resources and tools to help them understand their options and make informed decisions. This could include financial calculators, decision guides, and access to independent financial advisors. Be prepared to answer participant questions and address their concerns openly.

Insurance:
Once we’ve been selected, we work very closely with the plan sponsor to make sure data information, the timing of letters informing the participants and everything is coordinated well and we really try to onboard the participants. If it’s retirees, you know it’s fairly easy if they just continually get their check. We want to make sure there is no break in timing, so you know data and planning and who’s providing the last check from the sponsor side and when do our payments start so that it ends up being very seamless for the plan participant. They need to know who to call when they’re ready to start their benefits. We want to make sure they’ve got the right information.

Watch the Full Webinar

Full Script of the Webinar

Greg: Let’s talk about possible financial implications of the PRT. What should plan sponsors be thinking about what needs to be done?

Ellen:
The first thing that comes to mind for me is you want to look at for two things together, right? Where are your assets invested currently? What kind of allocation do you have? Have you already taken the step to go into a liability driven investment strategy or taken some other?

Actions to move yourself away from the return seeking investment exposure and lock in more of a fixed income allocation. Are you looking at a full pension risk transfer like a planned termination or just a partial risk transfer? Maybe it’s a lump sum window to buy out some of your terminated investor participants? Or are you going to transact with an insurance company to lift out?

And what does that do to the interest sensitivity of your liabilities?

Doing a full versus partial PRT is going to impact your financials and the timing for report. And then on the cash side, think about what the capital needs will be if the plan is underfunded or it’s sitting right there on the cusp and it depends on how well your new broker does in getting you the best pricing. Is there a timing that’s optimal where you going to generate that?

Ruth:
We get more involved sometimes with plan sponsors talking about buy in versus buy out and which fits the goals better, maybe which leads to softer landing for accounting implications and recognition of liabilities.

I think we’re finally at a cusp where you can take the DB plan and remove it and offer, you know, extremely similar benefits in a DC plan. And you know, almost no impact on participants. They still have the same choices, and in fact maybe even more flexible. When you think of the savings long term and maybe the lesser volatility in the markets, it may be very helpful for budgeting purposes for plan sponsors.

Greg: When a plan sponsor has decided to move forward with the PRT, obviously finding the key partners is important? Can you share what that process looks like?

Travis:
So the first is who’s going to run the deal? Who’s going to be your, your deal advisor, and the second would be who’s going to be responsible for the insurance selection?

DOL 95-1 specifically states that if you don’t have the expertise internally to go out and interact with the insurance marketplace and evaluate insurance companies, then you need to hire an independent expert to assist you with that process. There’s lots of experienced deal advisors in the market, obviously Aon is among them.

But your deal advisor is really going to project manage the entire transaction and they’re going to coordinate with all of the different stakeholders who are involved in a pension risk transfer.

And it’s a long list. You know, we’re going to be talking about the plan’s actuary and administrator. And your ERISA council and the plans trustee and of course we have to interact with the insurance market itself, folks like Ruth and her team, so that the deal advisors going to handle all of that.

From a decision-making perspective the selection of an insurance company is a fiduciary decision, so the plans fiduciaries are going to be involved, generally, that’s either the investment committee, the benefits committee, somebody like that.

But alternatively, plan sponsors could hire an independent fiduciary, where that independent fiduciary would come in, evaluate the insurance companies on your behalf with the help of their own independent expert that they would hire. So they would take the reins determining suitability under 95-1 and then ultimately own the selection decision of which insurance company is going to provide benefits and this approach with an independent for these areas is something that we really see more often for very large transactions, typically in excess of $500 million or more.

Greg: Let’s discuss data. Which is a key step to the entire process. Travis, start with you again. What do you find is the most important piece with regards to data.

Travis:
I put the data considerations into two groups. The first group is really just that the insurance companies need and plan sponsors need to provide the bare minimum information that the insurance companies will need to underwrite and administer benefits for your participants.

This is going to be things like full name, date of birth, Social Security number for all of your primary participants, but then also, and this is sometimes where plan sponsors have a data gap, is that information that same information is going to be required for all of the contingent annuitants or beneficiaries for participants who are receiving joint and survivor options, and so sometimes that’s an area where some data cleanup is going to be needed.

As obvious as it sounds, you know, knowing the right benefit amount and the form of payment that somebody is receiving is important. And then also you know, insurance companies are going to need participants address ideally, including zip plus four because many insurance companies do include as part of their underwriting process, geography based mortality assumptions. So being able to provide that zip plus four in addition to just general correspondence with your participants as the insurance company is administering benefits it does assist in the underwriting process.

So that’s really kind of the first bucket.

The second bucket is what I would consider as data that’s really going to be able to help you get the best pricing from the insurance companies and this is data that’s not necessarily always collected by your plan’s actuary for the valuation or by the plan’s administrator for the day-to-day administration. But it can have a big impact on insurance company underwriting.

But to the extent that any or all of that information is available for retiree only transactions, it certainly can go a long way to improving the pricing that you get from the insurers.

Ruth:
Clean data is super helpful. You know, the more stable data we have without a lot of changes later helps us. I think also looking at data and understanding you know are there medical payments going out of the plan or other things. Sometimes we are a little surprised later on doesn’t happen too often, but to find out that payments are made or other things. So that may be another clean up item to think through. Do we want to keep this process in the plan or take it outside of the plan, what works better for pricing.

The zip +4 you know is good sometimes other you know data elements could be helpful to the hourly bargaining, salary codes, job descriptions. Sometimes when you think about getting a benefit, say it’s 2000 a month it’s very hard to tell whether it’s somebody that’s worked, you know, 35 years for the company and actually is an hourly employee or it’s the CEO who was just covered for a few years. You know, so that’s where zip +4 or job descriptions can help us actually analyze and produce much more targeted pricing for a client.
Looking to the future too, there’s one thing that you know, it’s on my personal list that I think for data purposes, we haven’t gotten there yet, but adding in cell phone numbers as another source to try to find people when we get into missing participants would be helpful. I don’t think anybody’s collecting this yet, but you know. It’s been on my personal list for quite a while already, so just something that you think about for the future.

Ellen:
Part of my background is I spent a lot of time working in compliance and helping plan sponsors deal with things that have not gone quite right. So one of my takes on this is to think about, are there any unresolved compliance issues that affect your data that you want to resolve before termination. So certainly things like missing participants. You want to find those. Do you have terminated vested participants who are past their required beginning date and have missed their required minimum distributions.

How are you going to handle those and is that something that you can take care of before the planned termination starts or is it something that you’re going to handle as part of the planned termination? Are there any other, I’ll call them skeletons in the closet that are hanging out there, even saying, hey, I got to deal with that.

Now’s the time to deal with it before you’re ready to go ahead with the termination. The last thing that any of my clients who were on the HR side, who are typically where they own the data, want to have to do is go to their bosses and finance people who have said, hey, it’s time to go forward. The planned termination and say, well, hold up.

Another thing I think was touched on, but I want to make sure people hear is uncashed checks, Just because the custodian has written the check and sent it, and taking the money out of the trust account doesn’t necessarily mean that that check has been cashed, and I’ve seen some, you know, little mini chaos created late in the process when a plan sponsors going to closeout their trust account and all of a sudden the custodian says, what do you want me to do with all these checks that are sitting over here in the payment in the float account?

My last part, a lot of people won’t think of this as data, but it drives the data going forward. Don’t forget about your plan documents, make sure they are up-to-date or do you have all your required amendments in place? Are there any compliance issues to deal with there?

And then think about any voluntary amendments that you want to make, things like eliminating complex planned provisions that are no longer relevant or obsolete or have significant value where you don’t have the data to administer. If you don’t have it, the insurance company is not going to have it. But if they have to price it, they’re going to need that data.

The insurers don’t want the plan document. They want you to summarize that, but you need to make sure that your document is in good order so that when you’re taking the plan and you’re handing it off to an insurer, that you’re handing them something that they’re going to want to pick up.

Greg:
This is the area of the PRT that the Berwyn Group can assist. We can give you the life status or if they’re deceased from the plan sponsor so they can get the best rate possible from the insurance company. We clean up, we find missing participant data, we find their missing addresses. We actually have a treasury management process that cleans up stale, dated ERISA checks.

Greg: What steps are important to take to ensure you’re doing what is best for the participant or the policyholder?

Travis:
As we think about the process that governs these PRT transactions, Greg, you know ERISA is really the only legal precedent that we have. But outside of, you know, doing what’s in the best interest of planned participants and following the plan documents, there’s really not a lot in the list of fiduciary standards that are overly specific to PRT transactions.

And that’s where the guidance from Department of Labor Interpretive Bulletin 95-1 comes in. So as a plan fiduciary that’s looking to execute a PRT DOL 95-1 says there’s really six items that you need to specifically look at, four of which are related to insurance company financials. The other two are related to participant protections.

So you know, looking at the lines of business that an insurance company operates in, you know, are they a monoline business or do they have a well diversified, business portfolio?

We need to look at the size of their balance sheet relative to the size of the liability that you’re trying to place with them. We don’t want the plan sponsors liability to represent too much of their overall liabilities. If for some reason they made some sort of a pricing mistake or had adverse experience on your plan, we don’t want that to cause them to get into any financial distress.

We need to look at the quality and diversification of their investment portfolio and we need to look at the levels of capital that they’re holding. You know the risk-based capital standards came out of the wake of the insurance company failures in the early 90s. And those standards have done a really good job of making sure that insurance companies are well capitalized.

Very different from a pension plan which can operate at say 80 or 90% funded. Insurance companies always have to be 100% funded and in fact, they’ve got to be holding a certain level of excess capital on their balance sheet in case the investment bets or the underwriting they did have some adverse experience and if they are holding below that level of required surplus, they can potentially even lose control of their business from the regulators. So really have done a great job of keeping insurance companies honest and healthy and haven’t seen any PRT failures of insurance companies since the advent of those risk-based capital standards.

The last two items under 95-1, which are participant protections, you know we do look at the levels of protection afforded by state guarantee associations and then also the levels of participant protection based on the account structure that’s being written, whether it’s a, a general account or separate account.

There’s some factors that go above and beyond 95-1 that certainly need to be looked at to make sure that you’re doing what’s in the best interest of your, your participant or the policyholder. And so that’s going to be things like understanding the organizational structure of the insurance company, rather than just looking at the issuing entity, understanding what their experience is in this market.

We like to believe that our participants today are getting great levels of service from the current administrators. So we want to make sure that that level of service continues on at the insurance company.

It’s important to know that you have a fiduciary obligation not only to the participants that are transitioning over to the insurance company, but you also have a fiduciary obligation to the participants that are remaining with the pension plan.

Greg: Ruth, from an insurance perspective, the participants are now policyholders, right?

Ruth:
Yes. Once we’ve been selected, we work very closely with the plan sponsor to make sure data information, the timing of letters informing the participants and everything is coordinated well and really try to, onboard the participants if it’s retirees, you know it’s fairly easy they just continually get their check. We want to make sure there is no break in timing so you know data and planning and who’s providing the last check from the sponsor side and when does our start.

So that it ends up being very seamless for the plan participant, and they need to know who to call when they’re ready to start their benefits. And we want to make sure they’ve got the right information. We updated our administration operations a few years ago. To allow more flexibility, people can do some of this online now. They don’t have to call in or if they want to call in, they can. We want the participants to have a good experience.

Greg: From a participant or beneficiary perspective, what do you see as the pros and the cons to a PRT?

Ellen:
You’ll have participants that are going to be concerned about the security of their benefit, right? They don’t like change and especially when it comes to their finances and their retirement security, they understand their employer having responsibility for providing their benefit.

And they there’s some uncertainty if this is going to go to an insurance company and it’s ironic, right, because these insurance companies are professionals that take on these obligations. This is what they do.

There’s a lot of things that go into managing some of the discomfort the participants might have or some of the anxiety that they may have for active employees. They may hear. My plan is terminating.
And start to get concerned over the financial health of their employer and is this some sort of sign that there’s bigger issues going on? Could that jeopardize their job, their livelihood, their ongoing finances?

So a lot of it is just taking the right steps proactively to think about how you message this to employees and participants where it’s feasible, maybe have meetings for your active employees. I have a a client I worked with recently. They’ve been frozen for a very long time. They have a group of 30 or so remaining active participants, and they went and met individually with them and let them know when the communication was coming out. So they got that audience to express any questions.

On the on the pro side, I’ll go back to. This is what insurers do. One of the benefits to participants is that they’re taking this obligation to pay benefits and transferring it over to someone whose job it is to do this, the job isn’t to make widgets or consult on that or sell this. It is to ensure pension benefits. They’re very highly regulated even more so than private companies, they have state guarantee association coverage that replaces the PBGC insurance. And maybe that’s not dollar for dollar. But given that there, I think there’s a very low likelihood.

Based on all of the rigorous analysis that Travis talked about under 95-1, the likelihood is so low that that state guaranteed reinsurance coverage is ever going to be needed. I think that’s less of a concern and the more that can be done to help plan participants understand what this is going to look like going forward that their benefit is secure and that there is a very structured process around this will help ease some of those nerves.

Travis:
I think Ellen hit on a lot of really great information. I think a couple of quick parting shots. I would say, you know, first there’s no action required by the participant for a lift out PRT. And you could argue that maybe a pro or a con. But you know from a participant perspective, it is very seamless. The only difference that they’re going to notice is the watermark on the check is coming from a different spot.

You may get pickups in, you know administrative capabilities as Ruth talked about, you know, this really is something that’s evolving, but it’s part of the daily fabric for the insurance companies and they’re very focused on that participant experience from an administrative perspective. And then lastly, you know not all plans that are out there have.

There are a lot of church plans out there that do not have any coverage from the pension benefit guarantee corporation. So a risk transfer, whether it be as part of the planned termination or for a retiree lift out, it’s actually additive in terms of protection of their benefits. Not only are you moving to what is probably a more stable institution at the insurance company relative to the planned sponsor, you’re picking up that state guarantee.

Greg: On the legal standpoint, do you see or expect any changes on the horizon?

Ruth:
You know it’s really hard to say. I do think we have a great process under 95-1. It’s led to a lot of stability when it was created, there was a lot of instability in this part world at that time. There hasn’t been an insurer that’s failed since 95-1.

On the other hand, of course there will be some changes, whether it’s maybe the process of how the insurer gets selected, maybe there’ll be a few more check boxes in due diligence that needs to be.
But I do think you know we’re in a little bit of a year of change. We’re expecting the new 95-1, whatever that gets labeled, if it ever gets released by the Department of Labor. And then there’s some lawsuits out there that also could, maybe change some processes.

It’s hard to know at this point, but you know, I can’t say I expect anything in particular, but I expect change.

Ellen:
Yeah, I’m hearing some of the and monitoring a lot of the same things that that Ruth is, you know, there’s legislators are looking at some of the officer reinsurance arrangements. I think that’s part of you know sort of separate from the lawsuits there that Ruth alluded to.

And then you know I interact a lot with different regulators at the PBGC, IRS, Treasury, DOL, and they’re all very interested in what’s going on in the pensioners transfer market. You know, deal obviously coming from the fiduciary side of it and the participant protection side of it, DC also from the participant protection side and then IRS and Treasury, a little bit of that and a little bit of you know making sure that all the boxes are being checked from a tax compliance standpoint.

I’m also hearing legislators are just more interested in retirement issues, retirement security issues, the Senate Health Committee recently had some hearings there. They’re looking at this a lot. So I think it’s on regulators, right? Along with a lot of other things. So the big question is how? How does this rate relative to other things that they want to give attention to?

I think from my perspective, just talking with regulators. I’ll summarize as the better these transactions are handled, the less regulators may feel the need to step in and be more prescriptive.

So think of that from a participant perspective, right? Are they being given all the information?
They need to make a decision. Are the communications clear? Are people following the current rules? How much are as consultants? Are we being asked or driven to try to stretch the boundaries of the current rules and how we support our clients with some of these transactions?

And the more comfortable that regulators are that there’s not a lot going on for them to be concerned about, the less they are going to change how these transactions are regulated or reviewed.

Greg: If we can get any additional advice or insight around the PRT’s in general, what would that be?

Ruth:
I’d say, you know, knowledge and early planning. I think we’ve heard that a few times between Ellen and Travis and that, but I’d you know add to that and saying that at Pacific Life you know we welcome phone calls from plan sponsors sometimes to go through what are the options just learning a little bit about it.

Sometimes, yeah. Consultants like Travis are on the phone with the client and just going through questions and just getting some comfort of the process and insurance company. What everything might look like and feel like. So I I’d say that’s one thing you know again that we’d be very happy to talk to plan sponsors and consultants early in the stage just to give some comfort and insight.

Travis:
Yeah, I would say, you know, for me, Greg, it’s really just making sure that you’re working with an experienced partner in light of some of the recent lawsuits we just talked about, fiduciary support for the process is now more important than it ever has been. So you want to make sure that the partner you’re working with is able to provide that and then also just having a partner that understands the mechanics of the market can really improve the overall outcome for the transaction. So understanding when it’s appropriate to use asset in kind premium funding, whether or not to provide mortality experience data.

Provide better underwriting and just knowing the right data exclusions to make if you’re looking for a retiree only transactions. Should we exclude folks that have missing data, exclude folks that have certain payment forms that are more complex to increase the number of bidders excluding New York participants?

That have some additional regulatory hurdles that insurance companies have to climb over and experienced partners able to guide you through all of those decisions to make sure that you have the best outcome possible. And obviously we’re happy here at Aon to help you with any and all of those discussions.

Ellen:
I think as the person who’s anchoring this, I would say summarize as get your whole house in order.
And I think that’s really the message that Travis and Ruth and I have been trying to get across through today as we go come through this checklist.

There’s a famous quote from Abe Lincoln that goes something like if you give me 6 hours to chop down a tree, I’ll use four of them, sharpening the axe.

The planning is everything. Execution is important. Planning is a big part of what’s going to make you successful. So as Travis has talked about, build the right team of advisors who have experience doing this work, who have seen it all, who know what the possible road bumps are going to be.

That you might encounter and what you can do proactively to avoid or minimize them and deal with them ahead of time. Have a plan for them so that you are being proactive in addressing them rather than being reactive when.
You know, one of one of my mottos when I work with our consultants and our clients is no surprises.

There’s things are going to happen that there’s no realistic way of foreseeing, but if it’s possible to foresee it, see it and plan for it. And this is all part of that planning and the last thing I have is I’ve, I’ve heard more talk recently.

About bringing in outside advisors that you haven’t worked with through the life of the plan, so Travis talked very well about hiring an independent fiduciary to select the insurance company because that’s not something that many plan fiduciaries have experience with. So I want to bring in someone else who really knows how to do this. Also consider possibly bringing in a non fiduciary advisor that conserves an extension of your executive leadership team.

As you’re going through the process up to selecting the insurer, who can give you a second opinion on and be a sounding board on the many steps you’re going to have to take. And then many decisions you’re going to have to make along the way that get you up to that final OK, now I’m ready to transact moment.

To the lump sum, and this is the lump sum window kind of gone over here. And then we’re going to deal with the retirees post RBD here, see if we can get them into payment. So that when we hand the plan over to an insurance company.