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The Services Available to Your 401(k) Plan

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The Services

Available to

Your 401(k) Plan

Spectrum Group

at Graystone Consulting

a business of Morgan Stanley Smith Barney LLC

(2)

According to the Employee Retirement Income Security Act of 1974 (ERISA), fiduciaries of 401(k) plans must carry out their duties prudently and act in the best interest of plan participants. Fiduciary responsibilities can include: choosing a provider to administer the plan, selecting an appropriate menu of investments and monitoring such providers and investments on an ongoing basis. It has been said that ERISA’s prudence standard is one of the highest duties known to the law. Fulfillment of fiduciary duties will generally be measured by the steps a fiduciary takes to meet its obligations and whether a fiduciary has made informed and reasoned decisions. In fact, the Department of Labor and the courts have taken the position that

fiduciaries without the knowledge or

experience to make sound decisions have a duty to seek expert assistance.

For example, when making investment decisions, a fiduciary who lacks investment experience should hire an investment

specialist. For many plan sponsors, investment and other fiduciary responsibilities can seem overwhelming. That’s where Spectrum Group can help.

Spectrum Group can provide guidance and information to help you meet your fiduciary responsibilities. We know you’re busy managing your business and that you may not have the experience or the time to do the necessary research to make the right decisions. Spectrum Group is one of the teams of Graystone

Consulting, the institutionally-focused business of Morgan Stanley Smith Barney. We are equipped with the tools and experiences to help you make informed investment decisions as well as address your other plan responsibilities. You can feel confident knowing that Spectrum Group is committed to putting our resources and experience to work for your retirement plan.

By offering your employees a retirement plan,

you are providing them with the opportunity to

save for a secure retirement. You play a

fundamental role in managing this essential employee

benefit and it is important that you understand your

obligations as the plan’s fiduciary.

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SPECTRUM

GROUP

Morgan Stanley and Smith Barney have joined forces to

create a new industry leader. With a combination of more than

130 years of experience has as emerged as one of America’s

largest investment firms and has consistently demonstrated

leadership in all areas of financial services.

Morgan Stanley Smith Barney, LLC is a diversified financial services company and

one of the world’s leading providers of investment services. Graystone Consulting a

business of Morgan Stanley Smith Barney delivers a suite of specialized tools and

capabilities developed specifically for institutional investors, which can help you and

your employees build a robust retirement savings strategy.

Spectru SpectruSpectru Spectrummm Groupm Group Group Group

aaaat Graystone Consulting t Graystone Consulting t Graystone Consulting t Graystone Consulting

Upon request,

Spectrum

Group at Graystone Consulting

can offer any of the following

services to your retirement

plan.

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Evaluation

Investment Management

Investment Policy Statement

An investment policy statement clearly defines plan goals and investment parameters and provides the plan investment committee with guidelines for investment management decisions. It is also an effective way to ensure your investments are meeting your plan objectives on an ongoing basis.

Spectrum Group can help you develop this important document.

 Provide a sample investment policy statement

 Help identify specific goals

 Assist in selecting a broad range of asset classes to be represented in your retirement plan

Needs Assessment

To derive the maximum benefit from your retirement plan, it is important to select the most appropriate features and services for your business. Spectrum Group can offer valuable guidance by identifying and evaluating your company’s needs.

 Examine the history of your business and goals for your plan

 Review your retirement plan objectives  Analyze the demographics and

investment behavior of your employees

Investment Services

Spectrum Group has the ability to help you select the appropriate range of potential investment options to meet your plan’s specific needs.

 Educate on general investment concepts such as diversification, risk, asset

allocation and historical rates of return  Identify multiple investments within each

asset class from the provider’s fund universe that are consistent with your plan’s investment policy statement  Help ensure that the funds meet the

requirements of Section 404(c) of ERISA

Diversification does not guarantee a profit or protect against a loss.

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Plan Management

Fiduciary Audit File

One of the best ways to demonstrate compliance with the appropriate standards under ERISA is through adequate written documentation. This can be compelling evidence of an adherence to a prudent process and an effective argument against allegations of a fiduciary breach.

Spectrum Group can help you establish a fiduciary audit file.

 Organize key plan records

 Help identify areas requiring further Development

 Demonstrate that policies and procedures were established

 Documentadherence to those policies and procedures

Investment Monitoring

While selecting appropriate investments is critical to the success of your plan, monitoring each investment option is just as important. The criteria you use to monitor your investment options should be consistent with the goals outlined in your investment policy statement.

Spectrum Group can provide the tools and guidance to help you maintain an appropriate range of investment options within your plan.  Review periodic reports to help you

monitor the plan’s investment performance

 Conduct searches to replace

investment options that are no longer consistent with the plan’s investment policy statement

 Provide investment education and research to encourage sound decision-making

Issue Resolution

While the ongoing maintenance of your plan is important, at Spectrum Group we understand that it is not your only responsibility. Spectrum Group can help you resolve issues that arise in connection with the day-to-day activity of your plan.

 Interface with your plan provider to address your questions

 Seek corrective action for any deficiencies in service

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Plan Participation

Enrollment Meetings & Participant Education Participation is vital to the success of any plan—and a strong participant education program contributes to this success. Now more than ever, investors are looking for assistance in reaching their financial goals.

Spectrum Group can help your employees make informed decisions by educating them on the features of their plan and basic retirement planning concepts.

 Explain your plan’s features  Review the importance of

diversification and other asset allocation strategies

 Reinforce the benefits of participation and increasing contributions

 Encourage the use of retirement planning Strategies

Strategic Enhancements

While a good education program is important, it may not always help to ensure a successful plan. If you are concerned about low

participation rates, low deferral rates and whether your employees are properly diversified, Spectrum Group can introduce strategies with the potential to improve the health of your plan.

 Review plan demographics and asset allocation to identify areas for

improvement

 Recommend appropriate strategies including automatic enrollment, automatic deferral increases and default investment options

 Help you monitor the impact of the strategies you choose to implement

Investment Seminars & Re-Enrollment Meetings

One of the best ways to encourage your employees to maximize the benefit of their retirement plan is through in-person meetings and seminars. Spectrum Group can provide continuing education for your existing employees and enrollment meetings for new employees.

 Reinforceconcepts presented in initial enrollment meetings

 Offer programs to further employees’ understanding of financial markets and personal financial planning strategies  Assist retiring employees with

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Meet Your Financial Advisor Team

Source: Barron's “Top 100 Financial Advisors,” February, 2009, as identified by Barron's magazine, using quantitative and qualitative criteria and selected from a pool of over 800 nominations. Advisors in the Top 100 Financial Advisors have a minimum of seven years of financial services experience and $600 million in assets under management. Qualitative factors include, but are not limited to, compliance record, interviews with senior management, and philanthropic work. Investment performance is not a criterion. The rating may not be representative of any one client's experience and is not indicative of the Financial Advisor's future performance. Neither Morgan Stanley Smith Barney nor its Financial Advisors pay a fee to Barron's in exchange for the rating. Barron's is a registered trademark of Dow Jones & Company, L.P. All

An experienced institutionally-focused

team backed by the strength and resources

of an industry leader in investment advice.

James Pupillo was

Chosen by Barron’s Magazine as one of America’s Top 100 Advisers in 2006, 2007, 2008, 2009 and

Ranked #1 in Arizona for 2009

by Barron’s Magazine Top 1000 Financial Advisers.

selection criteria related to ethical standards, professionalism and success.

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Upon request, Spectrum Group can offer any of the

following services to your plan

EVALUATION



Needs Assessment

INVESTMENT MANAGEMENT



Investment Policy Statement



Investment Services

PLAN MANAGEMENT



Investment Monitoring



Fiduciary Audit File



Issue Resolution

PLAN PARTICIPATION



Enrollment Meetings &

Participant Education



Strategic Enhancements



Investment Seminars &

Re-Enrollment Meetings

Spectrum Group at Graystone Consulting

is dedicated to making your retirement

plan a success and, at the same time, helping you meet your fiduciary

responsibilities. To deliver the retirement plan you and your employees deserve, contact

Spectrum Group today.

6710 North Scottsdale Road, Suite 250 Scottsdale, AZ 85259

TELEPHONE: 480.368.6507

TOLL FREE: 888.477.2876

Tax laws are complex and subject to change. Morgan Stanley Smith Barney LLC, its affiliates and Morgan Stanley Smith Barney's Financial Advisors do not provide tax or legal advice and are not “fiduciaries” (under ERISA, the Internal Revenue Code or

otherwise) with respect to the services or activities described herein except as otherwise agreed to in writing by Morgan Stanley Smith Barney. This material was not intended or written to be used for the purpose of avoiding tax penalties that may be imposed on the taxpayer. Individuals are urged to consult their tax or legal advisors before establishing a retirement plan and to understand the tax, ERISA and related consequences of any investments made under such plan.

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