Archives: retirement

This is not a major news story for most Americans, but if you participate in a defined benefit retirement plan, one where you are due to receive regular payments of a fixed amount monthly when you reach retirement; pay heed: Bad things are happening.

The current news relates to the International Brotherhood of Teamsters and their Central States Pension Fund. Ironically, irregularities in the fund’s investment strategies are part of what caused Congress to codify pension reform in the 1970s with the Employee Retirement Income Security Act (ERISA).

The Teamsters started to collect and invest pension funds in the 1950s. In the 1970s it came out that many of these investments had lots to do with the needs of union management and little to do with those of pension beneficiaries.  One of the reforms brought about by ERISA was a requirement that pensions be separately managed from the unions or businesses which collected and invested the money.

The ideal pension plan collects contributions and has them independently and intelligently managed so that funds are there to meet all of the obligations the employer or union has promised. It all should make sense except that some assumptions once considered reliable just aren’t reliable any more.  In the 1960 and 1970s when many contributions were made, the assumption was that most retirees would not collect beyond age 70 or 75 at the latest.  That’s when people died back then.  Of course today, the number of retirees living and collecting into their 80s and 90s grows every day.  Problem 1 is that the plans were modeled on the wrong life expectancy assumptions.  Problem 2 is the stock market and its brother the real estate market.  Historically, pension contributions have been invested in securities and/or real estate because these investments could be relied upon to increase 7-8% per annum over the long term.  At these assumed rates, money doubles in value every 8 to 9 years.  Yes, we all know that some years are up and some are down but in the long term the 7-8% returns were thought reasonable.

Using the Standard & Poor 500 stock index as a benchmark stocks reliably increased from 1985 to 2000 when we had the Enron crash. They did not recover their 2000 values until 2008 and as soon as they did, that crash caused another huge decline.  Again it took us six years to get back to 2008 values or, as some would say, back to 2000 values.  Stocks snapped back and rose quickly until August, 2015 but since that date, values have been bouncing, bouncing, bouncing.  From February 2014 to February, 2016 the index made no real headway.

Pension plans need to liquidate investments like real estate and securities to pay benefits. They don’t get to tell the retiree, “Hey we will pay later this year when stocks recover.”  The money is due every month no matter what condition the market.

Today, the Central States Teamsters Pension Fund pays out almost $3.50 for every dollar it takes in. In theory, that should not make a difference because today’s dollar in should not be paid out for many years.  But, some of the dollars paid in overtime not only haven’t earned their 7-8% returns.  In fact some “lost” value, particularly those invested in hedge funds during the past 10 years.  What that means is that huge swaths of defined benefit plans are grossly underfunded.  The crisis the Central States Plan faces is that it has no place to go to secure enough to pay the benefits it promised.   So, there is now a very acrimonious debate underway involving Congress, crisis manager Ken Feinberg and the Teamsters over who will pay.  The Teamsters say the taxpayer should make up the shortfall.  Needless to say, Congress is not viewing those prospects with any contentment and Feinberg is saying top end benefits in particular need to be cut or the whole ship goes down.

State pensions are another animal. A state obligation to pay a retirement benefit comes with the guarantee that if the state lacks the money, the taxpayer will be assessed.  Pennsylvania has some of the worst funded pension plans in the United States.  The effect is that state contributions to pension payments have quadrupled in the past six years.  Underfunded obligations to public employees were 1.5% of state expenditures in 2010.  By 2019 it will be 10% by 2019.  If you think that’s a problem take a look at Philadelphia’s situation.  Today 20% of the city’s budget is devoted to paying retirees.  At the state level, the pension fund actually declined in value in 2015.  When bond agencies see these kinds of problems, ratings are downgraded and interest rates soar.

So, why is this part of a divorce law blog? Because, if you or your spouse are due money in the future on a monthly basis, there is a very real possibility that you won’t see all of it.  Yes, we just wrote that by law states cannot cut pension benefits because these are contracts for deferred compensation on services the state already got from its employee.  But much as with the situation in Puerto Rico and Atlantic City where governments are verging on default of their bond payments and other general obligations every day, these problems do not present easy solutions.  Taxpayers earning $4,000 a month are not going to quietly accept large tax increases to pay unfunded retirement obligations that often are double that amount.

If you are an attorney dividing a defined benefit pension, get your client to investigate how well funded that obligation is. And if there is a reason for concern, the retirement model for settlement or trial should consider sharing that risk.  This is not an easy evaluation in any circumstance.  Let’s say that wife is a teacher with a defined benefit plan that has a $300,000 cash value, but she is five years away from retirement and the plan is only 70% funded.  Does that not arguably make it a $210,000 plan? Conversely, suppose she is married to a spouse with a $300,000 IRA who is also five years to retirement. In theory, during the next five years she can still be accruing benefits, albeit underfunded benefits, while spouse’s IRA undergoes a 10% market correction that reduces his $300,000 to $270,000.  He may also be self-funding IRA contributions but they could decline as soon as they are funded if he invests in oil and gas or department stores or office supply chains.  There is no happy solution here but there is reason to model a retirement distribution where the risk is shared.  In other words, perhaps both the IRA and the defined benefit plan should be divided even though they are today, technically of equal value.

 

This is not a money management blog but what we increasingly find is that many divorce clients simply “trusted” that their resources would be sufficient to carry them through retirement. The great awakening comes when they discover they are now splitting what looked like a comfortable retirement and that their ability to make up for lost time has been lost amidst the sands of time.

So today, lawyers need to help clients be creative, and based on an article in the March 22 Wall Street Journal, there is reason to take a second look at a device invented a few years ago called the reverse mortgage. When first introduced, they were disparaged as a kind of sleight of hand trick. The number of them issued spiked just after the Great Recession but then eased off as the economy (or at least the stock markets) recovered.

A reverse mortgage is what it sounds like. You have equity in a home that is essentially a trapped asset. A reverse mortgage involves your pledge of that equity to a lender who gives you your own trapped money. The true economist would dismiss this as absurd. If you need cash out of your home, don’t pay anyone fees or anything else to tap it; just sell, downsize and take the cash from the settlement proceeds. That’s why economics is called the dismal science.

The problem with today’s older divorced couples is that they want everything to stay the same. Sure, it’s only you living in the house that once held three or four. But you like it, you like the neighborhood, and besides, moving means dealing with 30 years of accumulated things that you call treasures and your child dismiss as “crap” when they come for Thanksgiving.

I typically advise clients that they should at least consider downsizing. The response is the same. A longing look like I told them they need to put the dog down unless his health improves and either a testy “Maybe next year” or even more challenging “Must I?” In the end, we assess matters and give clients options. No pets have met their demise on my watch but I have told several clients that unless they reduce their housing costs in the near term, they may need to consider a shorter life.

Reverse mortgages can be a way to ease the pain. At their worst, people borrow them to speculate. This is pure foolishness. But the mortgage in reverse can be a very effective tool, especially to cover late life rainy days. The best example is a sustained down market. If you are retired and drawing $4000 a month while getting $2,000 in social security, when the market tumbled, your $4,000 is coming out of a measurable smaller pool. If you had $300,000 in retirement and drew $3,000 a month in January, 2008 you had  100 months of retirement assuming no increase in value and no inflation. Your draw was 1%. By late Fall, your $300,000 was now $150,000 which mean your pool had halved and your draws were 2% a month.  The market quickly shot back up to 11,000 but if the trough had been sustained and you didn’t halve your expenses, you were burning retirement fast.

If you had a line of credit associated with a reverse mortgage, you could have reduced the impact on your portfolio by drawing on your home equity. Then you would have had more on hand to ride the market back to some form of equilibrium even though your home equity would have been reduced. There was a time when home prices could be said to keep pace with the market. But that is not a recent trend. A tract home in the Philadelphia region with 3,000 square feet  sold in July, 2008 for $400,000. Six years later it sold for $420,000 and it today draws estimates for $410-425,000.  Had you known in Fall, 2008, you could have borrowed $100,000 in home equity; stuck it in a Dow index fund and today your $100,000 would be worth $251,000. But, alas, that would require speculation.

But there are good times to draw on home equity. You sit, happily in your crap filled house burning through $3,000 a month of retirement. The roofer tells you “It’s time for me to get $20,000.” That roof can come out of home equity much more readily than an investment portfolio because the house is not really gaining value.

Now for some of the trickier strategies; tricky but solid if done in the right way. You are on a fixed income. You have $300,000 in equity but $200,000 in mortgage debt. The monthly mortgage of $200,000 plus $600 a month in real estate taxes is really crimping your ability to see the grandkids. Why not take a reverse mortgage on the equity to service the real mortgage you owe. This cuts expenses while leaving your investment portfolio intact. Yes, your real estate portfolio is going to decline but that wealth right now is trapped in housing and not really increasing.

Another strategy. We are told that if you delay drawing on Social Security from ordinary retirement to age 70, the monthly benefit payable rises by 7% a year. That’s a pretty solid return and it’s guaranteed unless you conk out along the way. But, you may look at the pension and retirement money you now have and say, I can’t really make it to 70 without tapping my social security. Why not consider a reverse mortgage to fund the “gap” of payments you might otherwise get if you applied early or at normal retirement age.

Your employer lays you off in December 2015. Because you are not a kid it is going to take time to find a job, which means that your 2016 income will be low. Financial planners will suggest that the off-year is a prime time to convert a traditional IRA to a Roth because your income will be low. But you do still have to pay the tax on the conversion. Why not take that out of a reverse mortgage to cover the taxes.

Typically, reverse mortgage payments come without tax because the payment is not income but a reduction in home equity. You are effectively getting your own money. Federal regulations now make it so that a steep decline in home equity such that the amount you took out exceeds the equity does not open the door to liability on your part. So this is now a tool and not a toy. It can be abused but it has options that can make your retirement far more comfortable.

In April, 2014 the Federal Reserve Bank in St. Louis published a monograph on financial status of older Americans.  It corroborated a trend that has been evolving for several decades. Beginning with the advent of Social Security old Americans began for the first time to preserve and in many cases grow their net worth in retirement where historically, they had become dependent on their children for financial support as their earning years ended.

The Fed study reported on data last compiled in 2010 and found that by 2010, the median wealth of older age groups (ages 70+) were more than twice as large as the median wealth of a middle-aged family (ages 40-61) and close to 20 times as large as the median wealth of a young family (under 40).  What made this data all the more startling was that it came just after a major economic downturn which typically would be expected to hit older investors harder than middle and younger aged income earners.

Another interesting piece of datum comes from the Center for Disease Control and was published in an article about “graying divorce” published by the Washington Post on October 8 2014. The CDC statistics tracked divorce filings between 1990 and 2012 among various age groups. Among those aged 34 and younger, the rate of divorce actually declined over 20 years. Among those over 34-45 it rose slightly. But once we look at folks over 45 the rates have doubled. And yes, this was true for even those aged 65 and older where a length marriage was once considered a sign of stability today more than half the divorce filings are by individuals who have been married 20 or more years.

While, there is no direct correlation to be had from these facts, as practitioners we see a developing trend. In a word, old people have money that young people do not. Younger people perceive that their parents and grandparents don’t really need a lot of the money they have. So when mom and dad find that their marriage is no longer working for them, a growing number of younger Americans are insinuating themselves into the economics of their parents’ divorces. A generation ago, children typically became involved in providing emotional support to one parent to allow him or her to “stand up” to the spouse. Today, children appear to have their own agenda; whether it is private school/college for their children or to finance a business or some other project. In some situations we have had clients express fear that access to their grandchildren may become a bargaining chip if the divorce does not proceed as the adult children would like. This makes an emotionally tense world, doubly so. Much as the first World War began, once one adult child decides to become a participant in a parent’s divorce, siblings tends to wade in either to thwart that child’s agenda or to introduce one of their own. Then the acrimony really heats up with accusations like: “Mom never worked so how is it that she is entitled to so much of Dad’s money” and “There would be more to divide if you hadn’t spent an extra year getting your degree and spent a month in rehab.”

If you are an adult child of a parent getting a divorce, perhaps there should be a neutrality compact early on. And if you are the mature adult getting a divorce, it may make sense to agree with your spouse that adult children are not invited to the party. It’s bad enough going through a divorce without bringing the entire family through it with you.

We were consulted recently by a personal representative of an estate concerning the decedent’s death beneficiary of his 401(K) retirement plan.  The decedent had married before ERISA became law, but executed a beneficiary form shortly afterward naming his then spouse.  Later he divorced that spouse with a property settlement agreement by which spouse waived all rights to his ERISA retirement.  The decree of divorce, naturally terminated her status as a spouse.  But the decedent never bothered to execute a beneficiary designation naming a substitute.  As the reader might suspect, decedent dies with his former wife’s name on the form he executed forty years earlier.

So, the personal representative (e.g., executor) makes claim on the pension as part of the decedent’s estate.  The surviving non-spouse intervenes to say “Not so fast, he named me.” Executor responds “You waived.”  Ex-wife says: “I waived the right to make a claim in an adverse proceeding, but decedent’s failure to act demonstrates that he intended to retain me as beneficiary since he knew of my waiver but never named anyone else including the estate.”

Our client had slightly different facts, but those recited above produced Kennedy v. Plan Administrator for DuPont Savings and Investment Plan, 555 U.S. 285.  The Supreme Court of the United States decided that case in 2009 and held that absent more, the failure to change beneficiary designations after divorce means the designations will remain effective despite the intervening severance of the marital relationship.  The Court’s unanimous ruling states succinctly that while ex-wife waived the right to claim benefits in an adversarial sense that waiver also afforded the decedent the right to name his estate or anyone else in substitution by completing a simple form.  His failure to do so must be given meaning in its own right, absent some document or instrument showing a different intent. Ironically, in this case, the decedent had named a different beneficiary for another ERISA qualified DuPont retirement plan.

Matter resolved, correct?  Well, the Estate of William Kensinger was not taking no as an answer. The facts were essentially the same as in Kennedy except that the Estate waited until the benefits were distributed and then sued to recover the funds on the theory that the waiver of interest in the property settlement was effective as a matter of contract law, even if it was not as a matter of federal pension law.  The District Court of New Jersey dismissed the suit, citing Kennedy, but the Third Circuit Court of Appeals reversed on the basis that Kennedy was intended to prevent pension plans from becoming adjudicators among retirement plan claimants. But it held that the once the plan was distributed, it was subject to claims. Estate of Kensinger v. URL, Inc. 674 F.3d 131 (3d Cir. 2012)

So, for now, the word to clients is, even if you do not draft an alternate estate plan, Pennsylvania law helps you by means of a statute holding that a divorce revokes testamentary provisions to someone who is rendered a former spouse by decree of divorce.  20 Pa.C.S. 2507.  But that protection does not extend to matters governed by federal law and ERISA based pensions are the creature of the Congress, not the General Assembly.  The corollary warning is to attorneys who need to tell their clients the importance of changing these designations where they are ERISA based.

 

The rate divorce among couples in their 50’s or older has grown so much in recent years that it has earned its own moniker: gray divorce. A recent article in the Fiscal Times by Christina Couch highlights some of the financial issues which are resulting in retired couples spitting up. Not surprisingly, they are really not any different from the reasons why any couple decides to divorce. A generalization of the reasons would be that couples in their 50’s develop different expecations as to how to spend this time of their life. In many respects, the decision to retire or not retire; the type of lifestyle to live in retirement; or life goals closely mirror the same tensions younger couples have in their marriages.

People come into a marriage or grow within a marrige to have different goals for how they want to live their life. From the standpoint of what one person is prepared to accept in the other, the decision to retire at 62 while the other spouse works is not too dissimilar from a spouse in their late 20’s deciding to go back to go back to school or make a radical career change with finanical reprecussions. There are pressures which may not have been expected. From a financial standpoint, the couple may not have been on the same page as to the impact the retirement of one has on the financial stability of the couple.

Ms. Couch makes some connections that this growing segment of divorces is driven by demographics as much as anything: members of the baby boomer generation are living longer lives; women have had long careers and can afford to divorce; parties are not necessarily in disparate financial positions once they reach retirement age. As complications arise with health care, Social Security, and other retirement issues increase, the rise of gray divorce is not likely to subside; the possibility exsits, however, that some divorces could be prevented through communication and financial education.

This question is one that financial planners want us to focus upon every day in their quest to increase our savings rates and their assets under management.  We have previously reported on this subject in earlier blogs but one of the leading retirement savings managers, Fidelity Investments, published its findings on this subject last month.  The story was the subject an amusingly contentious video clip posted on October 25 on MSN in its “Money” column.

Fidelity should have some knowledge on this subject.  They manage 12,000,000 retirement accounts.  The average balance is just over $70,000.  But as with any prognostication, estimating costs decades ahead can be a frightening subject for any economist.

 

Fidelity’s conclusion as to required savings rates are expressed in terms of annual earnings. Their report concludes that by age 35 your savings for retirement should equal your salary at that time. Thus, if you are making $70,000 a year, by your 35th birthday you should have $75,000 invested.  But the number climbs precipitously after that:  For our discussion let’s keep the salary fixed at $70,000.

 

Age                         Salary                     Salary multiple     Target Retirement Account Balance

45                           70,000                   3x                                            $210,000

55                           70,000                   5x                                            $350,000

67                           70,000                   8x                                            $560,000

 

Fidelity assumes that their deposits will grow long term at the rate of 5.5%.  The model is built upon the concept that a 25 year old would invest 6% of his earning and increase it by 1% per year until the rate reaches 12%.  A 3% employer match is also assumed. Of course the 5.5% return is no more guaranteed than the cost of health insurance at age 67 can be estimated.

T. Rowe Price has issued a similar model but it concludes that a retiree at 67 will need 12x final salary or $840,000.

 

These targets can be helpful as a benchmark.  But as we have stated in the past, retirement is not only a function of saving but formulating what your lifestyle will be once you have retired.

Most financial planners say that your expenses in retirement will be different but only 20% less than they were while you were working.  We have recently seen a spate of clients nearing retirement who have undertaken major debt to help a child through graduate school or some other seemingly worthy enterprise.  This has prevented retirement savings or even worse; resulted in huge obligations that retirees really won’t be able to pay off once they leave the workforce.  It is one thing to profess that you will work until you drop.  But, many of us don’t seem to realize that health problems could force retirement upon us.

Social Security benefits can be an integral part of a divorce case. The ages of parties when they divorce may create a factual circumstance where the timing of Social Security benefits needs to be considered. Suffice to say, Social Security is a vast and complicated system but, as pointed out in an excellent article by economist Larry Kotlikoff, it is one that can provide some significant benefits if applicants know what they are doing. Mr. Kotlikoff was featured on PBS Newshour’s webpage recently and wrote "34 Social Security ‘Secrets’ All Baby Boomers and Millions of Current Recipients Need to Know". The article is as informative as it is intimidating as to the variety of options available to retirees and how best to maximize their benefits.

The Weekend Edition of the Wall Street Journal on February 19-20 reported on something most of us already knew:  Americans are not saving enough for retirement. The proposition is old but the data is new and, therefore, worthy of attention.

Why is this germane to a series on Separation and Divorce?  That’s easy.  In divorce we divide retirement savings that a couple has accumulated during the marriage.  In many instances the savings for retirement were calibrated based upon the principle that two live almost as cheaply as one.  But when the two go their separate ways, the economies of scale go out the door with them. That means re-thinking retirement plans in realistic ways.

 

The Journal’s research comes from several sources including Boston College’s Retirement Research Institute.  Roughly 60% of Americans approaching retirement have 401(k) plans.  Almost all Americans are eligible for some form of social security payment. These two devices are the engines of retirement income. The Boston College data shows that households headed by folks ages 60-62 with 401(k) type plans have median income of $87,700 in 2009.  The benchmark of most financial planners is that in retirement you will need 85% of your pre-retirement income to enjoy a comfortable lifestyle.  Eighty-five percent of $87,700 is $74,500 per annum or just over $6,000 a month.  For these median Americans social security will provide about $35,000 in income.  So the “gap” between the income target and the social security benefit is about $39,500, or $3,300 a month.  That’s where retirement savings on the individual’s part comes in.  The typical 401(k) for our near retirement couple is averaging $150,000.  New York Life Insurance would suggest that the balance be funded with a fixed income annuity.  An annuity through NY Life, however, throws off only $9,000 in income, or one-quarter of what we need based on current returns.  To get the income up to $3,300 with a quality annuity would require an investment base of $630,000.

 

About half of those on the cusp of retirement also have defined benefit retirement plans. These plans are a form of annuity themselves and the typical retiree with a defined benefit plan can bank on $26,500 a year or roughly $2,200 a month upon retirement.  For those folks the shortfall that must be made up by savings is only $13,000 a year.

 

All Americans over 30 years of age should be looking at how these numbers affect them. Admittedly young people view retirement as someone else’s problem. But the longer retirement contributions are ignored, the more implausible a sound retirement becomes because the funds do not have enough time to build value through investment.  The starting point is to assess what is projected to come from social security.  From there on, it is mostly going to be individual retirement contributions that will make the difference as defined benefit plans paying out monthly stipends continue to evaporate from the private sector.

 

Vanguard Group has recently increased what it deems to be the model for retirement savings from 9-12% of income to 12-15%. This means that couples with household income of $100,000 a year should be funding retirement savings at the rate of $1,000-1,200 a month.

 

As we noted at the outset, reassessment is required when a couple divides their retirement and doubles their expenses by moving from one household to two.  Commonly the impact is to defer retirement and scale back lifestyle expectations when it does occur. This is, for most, a price of divorce that cannot be avoided.

 

Bear in mind, the Journal does not discuss this, but we counsel clients to think carefully about what their expenses will be going into retirement.  The conventional wisdom is that living expenses constitute 85% of pre-retirement income.  However, upon retirement two large pieces of modern household budgets often change dramatically.  People who take on a 30 year mortgage at ages 30-35 should have satisfied that mortgage by the time they retire.  The home mortgage is commonly the largest single household expense.  The second largest is health insurance and 65 is the age when Americans become Medicare eligible.  Most of us will buy a supplemental policy at age 65, but we can hope that this coverage will be less expensive than the private plans we now pay to maintain.

 

The other thing to be learned from the Journal article is to invest conservatively.  The sad stories recounted there frequently involved folks who “took a chance” on investments calculated to make them wealthy rather than secure a retirement.  As most of us who were invested in 2008 learned, many of the high flying investments in real estate or start up companies crashed and burned in the last recession.  Sadly, that money is not coming back for those who are the vanguard of the baby-boom retirees.

In case you are one of those driven under a rock by the economic news of the past few months, you may have missed the latest news.  One of Wall Street’s most prominent investment advisers appears to have walked off with $50 billion dollars in what may qualify as the largest Ponzi scheme in world history.  For once, it wasn’t the little guy that got hit.  The client list for Madoff Investment Securities included some of America’s wealthiest investors. Sadly it also included some of the charities underwritten by those investors.

So why are the divorce lawyers writing about this? Because every day we are meeting with folks who don’t understand their investments and tend to buy based on “reputation” instead of the facts. Worse, they own things like hedge funds or derivatives without knowing what these things are.  These “country club investments” (based on the locale where they tend to be sold) can and often do transform rich people to middle class in a hurry. 

The defenses we commonly hear aren’t very good.  1. My spouse handles all of this.  2. We wanted to please a customer or client.  And worst of all:  3. The returns were too good to pass up.  Ask Mr. Madoff’s clients.  Indeed, they were too good to be believed.

It is pretty common during an initial interview to ask a client about an investment only to discover that the client doesn’t know how it works. It is common to see clients who have millions in life insurance but not a penny of disability insurance.  It is not uncommon to see 80% or more of an employee’s retirement invested in the stock of the employer. Presumably, this means that the collapse of Enron could not occur again.  Until Bear Sterns and Lehman Brothers did it again in 2008.

Certainly, it must be conceded that even the blue chip securities took it on the chin in the fourth quarter of 2008. And the Lipper Indices shows that the pain was felt across the board among the mutual funds.  But there are plenty of companies that have seen 80 -90% declines in their stock prices.   Are you qualified to decide when to hold and when to fold?

There are two kinds of money in this world; gambling money and retirement money.  Investors tend to ignore the distinction. If you have made it to age 40, there is a good chance you will live to 90.  That makes for 25 years of retirement.  At 40 we see little reason why we can’t work until we are 90 if we need to.  But, ask the person who is 70 what employment options he or she has. And if you are 40 with little saved for the golden years, investments in satellite radio or Philippine gold mining are not the way to make up for your refusal to save earlier.

The corollary to this rule is that if you are married to one of these riverboat gamblers you need to realize that you may be lashed to the mast of the boat. If I save and my spouse does not, there will be only one retirement fund to live on.  And should my nonsaving spouse decide to dump me and move in with my wealthy neighbor, chances are we will be dividing my retirement savings.

So what are the rules?

1.       Save for retirement like you mean it.

2.       Make your spouse do the same as soon as realistic

3.       Find a professional to manage your retirement money.  Make certain that professional

is SIPC insured and that every aspect of the investor operation appears transparent.

4.       Challenge your professional to produce returns.