HomeMy WebLinkAboutHandouts_Pension Public Safety_08/11/2005BOGDAHN CONSULTING, LLC.
simplifying your investment decisions
MEMORANDUM
TO: All Trustees
FROM: Joe Bogdahn
RE: SEC / DOL Qu ionnaire for Pension Consultants
DATE: 10 August, 2005
Attached please find our firm's response to the questionnaire provided in the
Department of Labor and the Securities and Exchange Commission's `Tips for Plan
Fiduciaries' white paper.
As you may note, our responses are quite brief. As an independent firm, we do not
participate, and have not participated, in the practices being investigated by the SEC
mention the have not, for we know that many plans have been significantly harmed
through past practices of several consulting firms, who now are scrambling to change
their methods. Please note that:
• Since the inception of our firm, we have extended a standing invitation to all of
our clients to have their auditors review our financial records and tax returns as
assurance that we do not collect any `hidden' revenues.
• We eschew all forms of soft-dollar payments, as we know that such relationships
cloud objectivity and opens the door for potential conflicts.
• We do not participate in any `pay-to-play' schemes.
• We serve as a fiduciary to our clients without caveat or exception.
We take our responsibilities to our clients very seriously. We enjoy what we do, and
are working hard to create a firm and an environment that we and our families can be
proud of. Please do not hesitate to contact us if you have any questions, or visit
www.stoppayinghiddenfees.com for additional resources.
340 West Central Avenue • Suite 300 • Winter Haven, Florida 33880
Telephone (863)293-8289 • Facsimile (863) 292-8717
www.bogdahnconsulting.com
DOL /SEC Tips for Plan Fiduciaries
Pension Consultant Questionnaire
1. Are you registered with the SEC or a state securities regulator as an investment adviser? If so, have you
provided the Fund with all the disclosures required under those laws (including Part II of Form ADV)?
Bogdahn Consulting, LLC is a Registered Investment Advisory firm, registered with the Securities
Exchange Commission and the State of Florida. We provide out Form ADV to all clients with our
proposed agreements, and upon request.
2. Do you or a related company have relationships with money managers that you recommend, consider for
recommendation, or otherwise mention to the plan for consideration? If so, describe those relationships.
NO.
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 consideration? If so, what is the extent of these
payments in relation to your other income (revenue)?
NO.
4. Do you have any policies or procedures to address conflicts of interest or to prevent these payments or
relationships from being considered when you provide advice to your clients?
YES.
5. If you allow plans to pay your consulting fees using the plan's brokerage commissions, do you monitor
the amount of commission 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?
Bogdahn Consulting is compensated in hard dollars only.
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?
We do not use brokerage commissions and do not accept soft dollar payments. We believe this type of
relationship clouds objectivity and opens the door for potential conflicts.
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?
Absolutely!
9. Do you consider yourself a fiduciary under ERISA with respect to the recommendations you provide the
plan?
Absolutely!
10. What percentage of your plan clients utilize money managers, investment funds, brokerage services or
other providers from whom you receive fees?
0%
I certify that the responses above are true and correct. ~
Chief Compliance Officer
Pensions&InY~tm
The International Newspaper of Money Management
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July 25, 2005
Site helps funds
sort out conflicts
Bogdahn Consulting LLC un-
veiled a "stop paying hidden
fees" website as a resource for
pension plan trustees, staff and
other fiduciaries in understand-
ing the issues involving potential
conflicts of interests of some con-
sulting firms, money managers
and brokerage firms, said Joseph
Bogdahn, principal.
The website, www.stoppay-
inghiddenfees.com, "doesn't point
any fingers at anyone" or seek to
promote his firm, he said.
"Unfortunately, the pension
consulting industry is riddled
with conflicts..." said Mr. Bog-
dahn. "While we are pleased that
the {SEC and DOL) have both
weighed in on the topic, we have
found that many trustees and
other plan fiduciaries do not
know where to hnd information
to assist them in learning more
about the conflicts. We felt it was
important for someone to step up
and provide an objective re-
source."
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Joseph Bogdahn said the site
provides 'an objective resource.'
Information on the site include
the Securities and Exchange Com-
mission report on the consulting
industry and a related Department
of Labor report, both issued in
May, as well as the recently adopt-
ed California Public Employees'
Retirement System's protocol for
dealing with potential consultant
conflicts of interests. Postings in-
clude Bogdahn's "show me the
money" questionnaire, providing a
guide to fiduciary obligations of
pension trustees.
Bogdahn, Winter Haven, Fla, is
an independent consulting firm
with some 100 Florida public pen-
sion plans and 13 corporate, en-
dowment and foundations as
clients, Mr. Bogdahn said.
- BARRY B. BURR