1.

Are you registered with the SEC or a state securities regulator as an investment adviser? If so, have you provided me with all the disclosures required under those laws (including Part II of Form ADV)?
John F. McAvoy, Investment Advisor Representatives of Investors Capital Advisory, a Registered Investment Advisor regulated by the SEC. Our firm’s Form ADV is available for your review.

2.

Do you or a related company have relationships with money managers that you recommend, consider for recommendation, or otherwise mention to the plan? If so, describe those relationships.
Waterstone Retirement Services is an independent investment advisory firm with no material conflicts of interest. This means that we have no alliances or financial or other relationships with any outside money management firms, mutual fund companies or insurance companies. Because we remain independent from any outside parties, we can retain complete objectivity in rendering advice to you.

3.

Do you or a related company receive any payments from money managers you recommend, consider for recommendation, or otherwise mention to the plan for our consideration? If so, what is the extent of these payments in relation to you other income (revenue)?
Waterstone Retirement Services does not receive payments from outside money management firms or any other third parties, thereby ensuring that we have no material conflicts of interest.

4.

Do you have any policies or procedures to address conflicts of interest or to prevent these payments or relationships from being a factor when you provide advice to your clients?
This question is not applicable to Waterstone Retirement Services because we do not receive payments from any outside third parties.

5.

If you allow plans to pay your consulting fees using the plan’s brokerage commissions, do you monitor the amount of commissions paid and alert plans when consulting fees have been paid in full? If not, how can a plan make sure it does not over-pay its consulting fees?
This question is not applicable to Waterstone Retirement Services. If Waterstone Retirement Services is hired on a fee basis any commissions, 12(b)1 fees or revenue sharing by the mutual fund families is used to offset the record keeping expenses of the plan.

6.

If you allow plans to pay your consulting fees using the plan’s brokerage commissions, what steps do you take to ensure that the plan receives best execution for its securities trades?
Waterstone Retirement Services does not accept commissions if hired on a fee only basis. Commissions, 12(b)1 fees and revenue sharing from the mutual fund families is used to offset the record keeping expenses of the plan.

7.

Do you have any arrangements with broker-dealers under which you or a related company will benefit if money managers place trades for their clients with such broker-dealers?
No.

8.

If you are hired, will you acknowledge in writing that you have a fiduciary obligation as an investment advisor to the plan while providing the consulting services we are seeking?
Waterstone Retirement Services acknowledges its fiduciary obligations to all the retirement plans it advises. This acknowledgment is provided in writing through execution of an Investment Advisory Agreement that acknowledges our status as an ERISA-defined “investment manager” in accordance with ERISA section 3(38) and as an “independent fiduciary” in accordance with ERISA section 405(d)(1). Our acknowledgment makes Waterstone Retirement Services solely responsible for the selection and monitoring of the investment options offered by your 401(k) plan.

9.

Do you consider yourself a fiduciary under ERISA with respect to the recommendations you provide to the plan?
Waterstone Retirement Services is an ERISA-defined fiduciary as described in the immediately preceding question. Because we receive no fees from third parties as a result of our recommendations, no ERISA-defined prohibited transactions occur.

10.

What percentage of your plan clients utilizes money managers, investment funds, brokerage services or other service providers from whom you receive fees?
0% - Waterstone Retirement Services accepts no such fees from any money managers, investment funds, brokerage services, or other service providers.

11.

How are you different from a broker or agent?
Most brokers or agents represent certain products or providers; therefore they lack flexibility and independence and are limited in what services & products they can sell. Because they typically sell an array of other products, (insurance, annuities, stocks, bonds) they are not focused solely on qualified retirement plans. Often we find that a great deal of confidence has been given to a broker or agent who knows enough to sell a qualified retirement plan, but not enough to provide the required service. Conversely, we focus on qualified plans and are ERISA experts. Our independence affords us total flexibility and a clear path when evaluating the strengths and weaknesses of the products and services required by your plan to operate efficiently. Our time is devoted to making improvements to your plan, not selling you a product.

12.

What products or providers does Waterstone represent?
None. We have no affiliations or alliances with any service provider or product vendors. This affords us the ability to remain totally independent and unbiased: keeping in mind that we represent our clients, not the vendor.

13.

If we pay you to manage our plans, how will we save money?
“ Out of sight, out of mind”—Many plans are sold with “zero pricing” (no visible expense to the plan sponsor). Although a popular concept and easy to sell, we all know that nothing is free. The concept is that if you can’t see the actual cost of the plan, you won’t be able to tell if you are being overcharged. We know how to identify the true cost of your plan and believe in full disclosure up front. We can determine if these costs are reasonable compared to the plans of similar size and where applicable, negotiate and leverage these expenses to your advantage.

14.

Does Waterstone Retirement Services consult on other employee benefits such as insurance or COBRA?
No. We learned long ago that the Pension industry is very complex and that the only way to truly master the field was to specialize. By focusing exclusively on qualified retirement plans, we are able to be the best at what we do. We do know companies in this field that we recommend to you.