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	<title>Comments on: An Open Letter to Vanguard&#8217;s Steve Utkus</title>
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	<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/</link>
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		<title>By: DIY Investor</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-14340</link>
		<dc:creator>DIY Investor</dc:creator>
		<pubDate>Sun, 08 Aug 2010 13:12:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-14340</guid>
		<description>Knowing the state of pension funds in this country it is hard for me to understand the questioning of the value of this service. It is not about quibbling over a number or arguing about whether the data is 100% complete. It is about whether the workers are getting retirement plans that offer an appropriate set of investment options, whether fees are excessive, and whether fiduciaries are carrying out their duties appropriately. This is about participants and bringing this data together with the analysis produces good questions and points to solutions. Focusing on the appropriateness of a single number is a diversionary tactic in my opinion - the number is merely a starting point. If the number is below 70, for example, I would think that those with fiduciary responsibility would want to know it and have the opportunity to analyze why.. Investment managers, providers, and even plan administrators will have their toes stepped on. So be it. Plans doing a good job will have evidence to point to.
Best of all I see the service as a means to increase the quality of retirement plans for participants. Surely that is a goal we all share.</description>
		<content:encoded><![CDATA[<p>Knowing the state of pension funds in this country it is hard for me to understand the questioning of the value of this service. It is not about quibbling over a number or arguing about whether the data is 100% complete. It is about whether the workers are getting retirement plans that offer an appropriate set of investment options, whether fees are excessive, and whether fiduciaries are carrying out their duties appropriately. This is about participants and bringing this data together with the analysis produces good questions and points to solutions. Focusing on the appropriateness of a single number is a diversionary tactic in my opinion &#8211; the number is merely a starting point. If the number is below 70, for example, I would think that those with fiduciary responsibility would want to know it and have the opportunity to analyze why.. Investment managers, providers, and even plan administrators will have their toes stepped on. So be it. Plans doing a good job will have evidence to point to.<br />
Best of all I see the service as a means to increase the quality of retirement plans for participants. Surely that is a goal we all share.</p>
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		<title>By: 401(k) ratings: Caveat lector &#124; Vanguard Blog</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-11872</link>
		<dc:creator>401(k) ratings: Caveat lector &#124; Vanguard Blog</dc:creator>
		<pubDate>Wed, 16 Jun 2010 03:28:28 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-11872</guid>
		<description>[...] when my recent post on a new 401(k) rating service, Brightscope, elicited some response, including a critique from founders of the company. Frankly, I donâ€™t think anyone has ever created an â€œopen letterâ€ [...]</description>
		<content:encoded><![CDATA[<p>[...] when my recent post on a new 401(k) rating service, Brightscope, elicited some response, including a critique from founders of the company. Frankly, I donâ€™t think anyone has ever created an â€œopen letterâ€ [...]</p>
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		<title>By: BrightScope Blog</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-10938</link>
		<dc:creator>BrightScope Blog</dc:creator>
		<pubDate>Wed, 19 May 2010 01:59:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-10938</guid>
		<description>[...] An Open Letter to Vanguard&#8217;s Steve Utkus Posted  on March 18, 2010, 10:02 am,  by Ryan Alfred,  under Uncategorized.   Steve Utkus is the head of retirement research at Vanguard. Though we have never met personally, we have been fortunate enough to appear alongside Steve in articles, including this article about BrightScope that appeared in BusinessWeek. His comments in the press are generally wise and insightful which makes sense given his 25+ years of industry experience. [...]</description>
		<content:encoded><![CDATA[<p>[...] An Open Letter to Vanguard&#8217;s Steve Utkus Posted  on March 18, 2010, 10:02 am,  by Ryan Alfred,  under Uncategorized.   Steve Utkus is the head of retirement research at Vanguard. Though we have never met personally, we have been fortunate enough to appear alongside Steve in articles, including this article about BrightScope that appeared in BusinessWeek. His comments in the press are generally wise and insightful which makes sense given his 25+ years of industry experience. [...]</p>
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		<title>By: Skeptic</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9462</link>
		<dc:creator>Skeptic</dc:creator>
		<pubDate>Wed, 31 Mar 2010 04:41:13 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9462</guid>
		<description>I don&#039;t know guys, phrases like &quot;I would have expected Mr. Utkus to do a little bit more research before reaching this erroneous conclusion&quot; turn me off from your stuff. If a guy like Mr. Utkus can&#039;t figure it out, what chance to do I have? My 2 cents: Keep it short, simple, and non-personal.

I think he also has a point when he says &quot;Itâ€™s not just enough to process data and come up with a rating&quot;. Can a multi-dimensional space of data really be mapped onto a single dimension (a rating) without losing a lot of information and insight?</description>
		<content:encoded><![CDATA[<p>I don&#8217;t know guys, phrases like &#8220;I would have expected Mr. Utkus to do a little bit more research before reaching this erroneous conclusion&#8221; turn me off from your stuff. If a guy like Mr. Utkus can&#8217;t figure it out, what chance to do I have? My 2 cents: Keep it short, simple, and non-personal.</p>
<p>I think he also has a point when he says &#8220;Itâ€™s not just enough to process data and come up with a rating&#8221;. Can a multi-dimensional space of data really be mapped onto a single dimension (a rating) without losing a lot of information and insight?</p>
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		<title>By: Ryan Alfred</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9196</link>
		<dc:creator>Ryan Alfred</dc:creator>
		<pubDate>Wed, 24 Mar 2010 19:50:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9196</guid>
		<description>Jack. Thank you for your comments. I really think you need to spend the time to see some of the tools we have built for plan sponsors and advisors. I have offered to show them to you before without any luck. If you are just viewing the public website there is no way for you to see these things. I think you will find that we have already addressed many of the things you mention in your post.

To address a few of your concerns. 

Other Plans: We already have the capability and encourage plan sponsors and advisors to build peer groups taking into account whether the other sponsors in their peer group offer a DB or other benefit plan.  

Data Timeliness: Right now most of our data is accurate as of 12/31/2007. Most of our clients agree that in the absence of anything else, it is still valuable having 2 year old data until such time as fresher data becomes available. The alternative is no benchmarking at all, and that is not very palatable to most. We are in the process of updating to 2008 over the next month. Due to EFAST2 we will be able to add 2009 data before the end of the year. I think the issue of data timeliness will disappear literally overnight.

Again, I appreciate you taking the time to share your concerns. If at some point you want to come get a demo I would be happy to accomodate you.</description>
		<content:encoded><![CDATA[<p>Jack. Thank you for your comments. I really think you need to spend the time to see some of the tools we have built for plan sponsors and advisors. I have offered to show them to you before without any luck. If you are just viewing the public website there is no way for you to see these things. I think you will find that we have already addressed many of the things you mention in your post.</p>
<p>To address a few of your concerns. </p>
<p>Other Plans: We already have the capability and encourage plan sponsors and advisors to build peer groups taking into account whether the other sponsors in their peer group offer a DB or other benefit plan.  </p>
<p>Data Timeliness: Right now most of our data is accurate as of 12/31/2007. Most of our clients agree that in the absence of anything else, it is still valuable having 2 year old data until such time as fresher data becomes available. The alternative is no benchmarking at all, and that is not very palatable to most. We are in the process of updating to 2008 over the next month. Due to EFAST2 we will be able to add 2009 data before the end of the year. I think the issue of data timeliness will disappear literally overnight.</p>
<p>Again, I appreciate you taking the time to share your concerns. If at some point you want to come get a demo I would be happy to accomodate you.</p>
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		<title>By: BenefitJack</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9108</link>
		<dc:creator>BenefitJack</dc:creator>
		<pubDate>Sat, 20 Mar 2010 13:47:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9108</guid>
		<description>So, we should ignore BrightScope ratings until the defined benefit, retiree medical, and other data are added - including updates for plan changes since 2007?  You&#039;re not suggesting a plan sponsor should consider changes based on 3 year old competitor data, are you?  And, plan sponsors who ignore the differences where some, but not all offer a defined benefit pension plan, do so at their own peril.  All seem to be major flaws for any system that purports to focus on &quot;outcomes&quot;.     

Certainly, companies have done benchmarking, however, most benchmarking is focused on plan design:  
(1)  First, whether you are talking about the Hewitt Benefit Index or other consulting firm efforts, the actuaries are always careful to focus on the value of the design - not the cost, 
(2)  Second, to get at the value of the design, they use a uniform demographic group and run the formula/features through calculations - which may or may not produce a reasonable view of where you stand - depending on whether your firm&#039;s demographics are typical, 
(3)  Third, they tend to only look at new hires because of all of the grandfathering from the massive level of changes over the past two decades (for example, one of my retirement plans has two totally different values for two halves of the population due to grandfathers), and 
(4)  Fourth, they also remember to aggregate analysis into &quot;events&quot; - a retirement event, a medical event, etc. - because they are well aware that the designs focus on all plans as a package, and, specifically, all retirement plans (income, medical, etc.) as a separate package/event.  

A caveat about benchmarking is that whatever BrightScope thinks is &quot;best practices&quot; as demonstrated by what other firms do would not necessarily be &quot;best practices&quot; for your firm; even if it were attainable.    

How the plan defines covered compensation, accumulated service for vesting, age of the participants, whether the plan uses automatic features, etc. - and how those features interact with the specific demographics of the population - all tend to have a significant impact.  The same design can produce different results depending on those and other factors. The folks at Hewitt and elsewhere know this and expend more effort on confirming designs - versus focusing their attention on 5500 data.  

Finally, the plan must also be considered within the context of the total rewards strategy, affordability, etc.</description>
		<content:encoded><![CDATA[<p>So, we should ignore BrightScope ratings until the defined benefit, retiree medical, and other data are added &#8211; including updates for plan changes since 2007?  You&#8217;re not suggesting a plan sponsor should consider changes based on 3 year old competitor data, are you?  And, plan sponsors who ignore the differences where some, but not all offer a defined benefit pension plan, do so at their own peril.  All seem to be major flaws for any system that purports to focus on &#8220;outcomes&#8221;.     </p>
<p>Certainly, companies have done benchmarking, however, most benchmarking is focused on plan design:<br />
(1)  First, whether you are talking about the Hewitt Benefit Index or other consulting firm efforts, the actuaries are always careful to focus on the value of the design &#8211; not the cost,<br />
(2)  Second, to get at the value of the design, they use a uniform demographic group and run the formula/features through calculations &#8211; which may or may not produce a reasonable view of where you stand &#8211; depending on whether your firm&#8217;s demographics are typical,<br />
(3)  Third, they tend to only look at new hires because of all of the grandfathering from the massive level of changes over the past two decades (for example, one of my retirement plans has two totally different values for two halves of the population due to grandfathers), and<br />
(4)  Fourth, they also remember to aggregate analysis into &#8220;events&#8221; &#8211; a retirement event, a medical event, etc. &#8211; because they are well aware that the designs focus on all plans as a package, and, specifically, all retirement plans (income, medical, etc.) as a separate package/event.  </p>
<p>A caveat about benchmarking is that whatever BrightScope thinks is &#8220;best practices&#8221; as demonstrated by what other firms do would not necessarily be &#8220;best practices&#8221; for your firm; even if it were attainable.    </p>
<p>How the plan defines covered compensation, accumulated service for vesting, age of the participants, whether the plan uses automatic features, etc. &#8211; and how those features interact with the specific demographics of the population &#8211; all tend to have a significant impact.  The same design can produce different results depending on those and other factors. The folks at Hewitt and elsewhere know this and expend more effort on confirming designs &#8211; versus focusing their attention on 5500 data.  </p>
<p>Finally, the plan must also be considered within the context of the total rewards strategy, affordability, etc.</p>
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		<title>By: Rich and Co.</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9091</link>
		<dc:creator>Rich and Co.</dc:creator>
		<pubDate>Fri, 19 Mar 2010 16:11:24 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9091</guid>
		<description>Open exchanges and critical thinking can only help the real beneficiaries we are all focused on - participants and plan sponsors.

No need to be immediately reactive or defensive.  Our &quot;critics&quot; are always our best source of new ideas and improvements.  Let&#039;s remember:
-  The DC system is still very new and evolving - the very first generation to retire using it is only now starting to happen
-  No one expected it to be so popular and such a massive phenomena - so we re always playing &quot;catch-up.&quot;
-  It has become critical to the global financial system and the health of US society

Any new effort will need evolve and data collection and analysis is always a moving target.  This all seems like a healthy and needed debate.  We encourage it to continue.</description>
		<content:encoded><![CDATA[<p>Open exchanges and critical thinking can only help the real beneficiaries we are all focused on &#8211; participants and plan sponsors.</p>
<p>No need to be immediately reactive or defensive.  Our &#8220;critics&#8221; are always our best source of new ideas and improvements.  Let&#8217;s remember:<br />
-  The DC system is still very new and evolving &#8211; the very first generation to retire using it is only now starting to happen<br />
-  No one expected it to be so popular and such a massive phenomena &#8211; so we re always playing &#8220;catch-up.&#8221;<br />
-  It has become critical to the global financial system and the health of US society</p>
<p>Any new effort will need evolve and data collection and analysis is always a moving target.  This all seems like a healthy and needed debate.  We encourage it to continue.</p>
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		<title>By: Privacy Policy &#124; Healthy Blood Pressure.net</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9074</link>
		<dc:creator>Privacy Policy &#124; Healthy Blood Pressure.net</dc:creator>
		<pubDate>Thu, 18 Mar 2010 22:43:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9074</guid>
		<description>[...] A&amp;#1495 Open Letter t&amp;#959 Vanguard&#8217;s Steve Utkus &#124; BrightScope Blog [...]</description>
		<content:encoded><![CDATA[<p>[...] A&amp;#1495 Open Letter t&amp;#959 Vanguard&#8217;s Steve Utkus | BrightScope Blog [...]</p>
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		<title>By: Scott Henderson</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9071</link>
		<dc:creator>Scott Henderson</dc:creator>
		<pubDate>Thu, 18 Mar 2010 20:14:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9071</guid>
		<description>Ryan and the BrightScope Team, congrats on your swift and fact based response to Mr. Utkus&#039;s blog. Not many companies will take the time to respond in a meaningful way that actually creates a marketing opportunity to a compelling business model. Yes, the BrightScope summary numbers can be confusing at first glance, or at least initial assumption can be wrong. Thank you for the clarification.</description>
		<content:encoded><![CDATA[<p>Ryan and the BrightScope Team, congrats on your swift and fact based response to Mr. Utkus&#8217;s blog. Not many companies will take the time to respond in a meaningful way that actually creates a marketing opportunity to a compelling business model. Yes, the BrightScope summary numbers can be confusing at first glance, or at least initial assumption can be wrong. Thank you for the clarification.</p>
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		<title>By: michael w</title>
		<link>http://www.brightscope.com/blog/2010/03/18/an-open-letter-to-vanguards-steve-utkus/comment-page-1/#comment-9068</link>
		<dc:creator>michael w</dc:creator>
		<pubDate>Thu, 18 Mar 2010 18:21:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.brightscope.com/blog/?p=1697#comment-9068</guid>
		<description>Glad you responded so quickly and directly......will be looking for Mr. Utkus&#039;s response. The observation and response has provide more light into BrightScope&#039;s work.</description>
		<content:encoded><![CDATA[<p>Glad you responded so quickly and directly&#8230;&#8230;will be looking for Mr. Utkus&#8217;s response. The observation and response has provide more light into BrightScope&#8217;s work.</p>
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