Jason Roberts: Fiduciary Rule & ESG Compliance | Retireholics

[0:02] Jason Roberts: Oh, Jake. [0:04] Chad: Or I'd rather. Chad, I would just rather you mute yourself when you try to talk. [0:10] Mark: Oh, thanks, Mark. [0:12] Chad: Are you welcome? [0:15] JD: All right, let me know when you're ready, Brandon. [0:19] Jason Roberts: All right, I'm gonna launch away here. [0:22] Mark: Unint. [0:45] JD: Welcome, everybody. Welcome to another episode of Sheltering. [0:48] Mark: In place boat owner. [0:50] JD: Yeah Roberts, boat owner. Brought to you by the retireholics. Thanks for attending another shitty webinar because our goal is to change the retirement plan industry one shitty webinar at a time. We've got a special guest here today, the infamous, the well respected Erisa attorney Jason Roberts. And someone who there's only a handful of people that have done a live on stage show with us. Jason was one of them. We had a blast with him. In Portland or Seattle? Portland. [1:30] Chad: Portland. [1:32] JD: That was a lot of fun. But this is your next time. Back to the couch. I'm sorry that's in virtual. But we still plan to have a lot of fun with you today. Jason, welcome to the show, man. [1:44] Jason Roberts: Thank you. Glad to be back. [1:47] JD: Love the art above your head. Okay. [1:49] Mark: And you brought in a surfboard too to add to it. [1:52] JD: I like, love it. [1:54] Chad: I don't think that's a surfboard. [1:56] Mark: What is that? That's a surfboard. [1:58] JD: That's a surfboard [2:01] Jason Roberts: surfboard over there. [2:04] JD: Oh, look at the little single fin kind of retro action. I don't know if you guys know this, but Jason's almost like a neighbor of mine now. I should have put that in there. He's a brand new father, by the way. [2:17] Mark: Yeah, congrats. [2:20] JD: And yeah, he lives like not too far from where I'm at. Apparently. He's got a beautiful garden, he's got produce, and I'm actually going to ask him about that later, so we'll save that. But Jason, we're psyched to have you. There's lots of big topics happening in this current environment. I know you spend a lot of time thinking about them, writing about them, counseling on them. So we're super excited to have you. Let me hit a few housekeeping items. Make sure you're in gallery view. That's in your top right. And Chad, you had a little tip. If you see Jason Roberts audio frame, what can they do? [2:57] Mark: You can click on either the three dots if you're on the computer or if you're on your phone. You can swipe over on that screen, touch it and say hide. Non video participant. [3:06] JD: Thank you, Chadwick. We appreciate that help. And if you're, we do want you to chat. So please share your comments. Share Your ideas. Let us know where you want the conversation to go. Have fun with each other on there, but make sure you're not just sending it to the panelists. You're sending it to all the attendees so everyone can see what you're thinking about. And today, thanks to Nevin Adams from the ara, the word of the episode, Jason. We had Nevin choose it. And Jason has got to be in our top three prohibited word like contestants. Would you guys agree? [3:46] Chad: Hall of fame. Oh, yeah. [3:48] Mark: I wasn't there solid for like the first 18 minutes and then all downhill from there. [3:53] JD: To remind you, if you say this prohibitive word, you must drink from your prohibitive drink. I've got a little vodka mixed with some oj. I've got some vodka just straight up in here. I might dabble between the two, who knows? But the word will be rule R [4:12] Mark: U L E. Piece of cake. Dangerous. [4:17] Jason Roberts: Again, [4:20] JD: let's get started right away. Let me explain the boat owner graphic and then my captain sailor hat here. We've been given Jason shit for years that he lives on a boat. We actually thought it was really cool that he lived on a boat. I think he got offended from time to time because he'd say, I do have a house. I live in a house as well. But we, the retireholics, are convinced that you live on a boat. And even though that you now live not far from me, I still dream of you living on a boat. So we've got a lot of boat themes going on today that you'll see later throughout the show. So if you're tuning in, that's what the boat stuff is all about. [5:01] Mark: Just a little behind the scenes story. There was once a moment where you were kind enough to invite the retireholics to your boat. [5:08] Chad: Yes. [5:09] Mark: And we had every intention of coming there. And then we proceeded to get super drunk that evening. And we're like, how do we get. How we get to the boat? Where are we going to the boat? We can't go to the boat. How are we gonna get to the boat? There's a party on the boat and we never made it. So I think I was super nervous. I felt bad that we didn't make it to the boat. [5:26] JD: Mark doesn't remember that that evening. [5:28] Jason Roberts: Wonder why. [5:29] JD: Let's dive right into it. [5:31] Chad: I just kept swimming. [5:33] JD: There's several topics that I want to talk about today and they're not going to come as a shock. I want to talk the fiduciary rule. I want to talk ESG and I want to talk pep And I know that we've talked about those things before, but the fact that we have Jason on and the fact that he spends a lot of time thinking about these things, I think it would be super lame if we didn't revisit some of these topics because they're in the headlines. They're. They're constantly fluid. It's a big deal. So I do want to touch on that. But. But I want to remind you guys, the retireholics and our audience, kind of why we're here in the first place. We don't talk about this a lot, so a little self promo. We're here to deliver value, to deliver education, 401k topics for 401k pros as well as 401k rookies. And I want us to stick to that today. The idea here is to give people listening in nuggets, concepts, ideas, intelligence that they can bring with them into their practice. Right. So they can use to retain their clients, service their clients, but also win new business. And so if you're in a point of sale and the fiduciary rule comes up, or PEPs comes up, or ESG comes up. Got it. I'll put it on the pause here. The whole point is that we're giving you this information to make you look stronger in those scenarios. So I just want to reiterate that because I don't say it. Enough with that. Let's dive right into it. What is going on? Do we really. Jason, do we really have a new fiduciary R word? What's this exemption kind of thing? Like, what should advisors be thinking about in terms of fiduciary and all these headlines that we're reading? [7:24] Jason Roberts: We don't get to talk about our beers first? [7:27] JD: No, you're the guest, buddy. You can zig and zag any way you want. You want to show us your beer? [7:35] Jason Roberts: Well, I was going to open it here. So it's the KBS Barrel aged imperial stout with some coffee, which should help me get through the show. [7:46] JD: Very nice. Last time Jason was on the show was a couple years ago. And when we did the shows, then we would take time to talk about the beer of the episode, and we'd open the beer of the episode. And it's clear that Jason has not watched a show since because we don't do that. That's all right. That's right. [8:02] Mark: Hey, we were one. We once had beer sponsors. Now we just drink whatever's in the fridge. Or at least that's what I do. [8:10] JD: Jason, what should Advisors, registered reps and or RIAs. And I know that it's a little bit different for the two of them, but what should they know about this fiduciary stuff? Because like I said, it's in all the headlines. [8:27] Jason Roberts: Sure. So the biggest difference between this and the 2016 version, well, there are quite a few differences, but this is only a proposed exemption. And so if you take that on its face, it's not casting a wider net. It didn't change the definition of the phrase investment advice like the 16 rule did. And so what it does, in fact they even say in the preamble that they view it as a deregulatory action consistent with the executive order that was issued suggesting or mandating, I guess that for every new regulation to go away and so they put it out there that this is a deregulatory endeavor in the sense that it allows otherwise prohibited compensation if you comply with the conditions of the exemption. Now that's not quite accurate intellectually anyway. And the reason I say that is there are a couple of significant interpretations that are embedded in the preamble. One of those interpretations that is very significant, for example, relates to the fact or the we have that five part test defining investment advice from 1975. One of the parts of those tests test is that the advice be delivered on a regular basis. And so when we think about IRA rollover recommendations, for example, I view those. [9:57] JD: I'm sorry I said it's a one time kind of thing, right? [10:01] Jason Roberts: Yeah, exactly. You either, if I recommend a rollover, you either take me up on that and we work with you in the IRA or you don't. It's not something I'm going to come back and make ongoing basis. Now that being said, There was a 2005 advisory opinion out there that a lot of plan advisors have some heartburn over because that opinion said that if you were providing services in the risk fiduciary and you used that authority to cause the distribution and then you recommended they reinvest the proceeds in a way that paid you more, you may be violating the prohibition on self dealing. So that one was clear as mud. I think the long and short of it is the interpretation expressly in this new opinion, the new proposal expressly supersedes or overrules that 2006 guidance. And what it says is we're going to look at your pre existing relationship, which is what that advisory opinion sort of did and your post. And if either one of those are fiduciary, either under ERISA or the tax code the recommendation itself will be viewed as a continuation of advice delivered on a regular basis. [11:15] JD: And this is why it's more impactful for an RIA than a registered rep. Because the registered rep would not be acting in a fiduciary capacity currently. Is that what you're saying? [11:29] Jason Roberts: Correct. And I actually authored a column, a guest column for RA Biz, if anybody wants to get these for end of the week on the why. But the short version is that when is an RIA not providing ongoing investment advice or discretion in an ira? And the answer there might be, well, maybe I'm serving as a solicitor, and I don't want to get too far off track here. If I'm soliciting business, let's say, for a turnkey asset management platform, Tammy, and I'm paid as a solicitor, I might meet with that client one day. [12:07] JD: What do we. Does the baby jump out of the crib? What happened there? [12:10] Mark: Earthboard fell? [12:11] Jason Roberts: No, no, that was my makeshift curtain. So we just moved to the top a couple months ago and trying to keep some of the light out, but I think we're okay. [12:19] JD: You still look good, Jason. You still look good, buddy. [12:23] Jason Roberts: The. The. If I. If I refer business to a turnkey provider, like a tamper, and I get paid a solicitor fee, I'm still meeting with you once a year. So arguably that would satisfy the one, the regular basis. I have to do that pursuant SEC rules regarding solicitors. But the second interpretation that I believe was significant in the preamble of the exemption is that they re articulated this position that recommending a third party advisor or manager would be considered a fiduciary act. So it is casting a wider net at the end of the day. But that wider net is really only hitting registered investment advisors, maybe bank trust officers, those that would have an ongoing advisory relationship. If I'm a registered representative of a broker dealer, arguably, I could claim that I give sporadic advice, I give advice upon request. I give advice when you call me, things are when I have a hot tip, something like that. And so that's how they've avoided, for the most part, being painted with an ERISA fiduciary brush going back to 1975. [13:37] JD: So now this gets weird. Right. So would you argue then that RIAs are kind of pissed off by this exemption in a way? Like you're kind of letting. I think the whole concept of the first fiduciary rule, right, was like, okay, we're going to force everyone to act in a fiduciary capacity. Which meant the rookie. It's not that every registered rep is a rookie because that's not true. But now you're almost putting them off the hook. Right. And then. But you're forced. Yeah Chad. [14:06] Mark: What that's exactly what I was thinking is I feel like the objective of this I don't have a backup for the rule word. I feel like the objective was to take people who otherwise might not be operating in a fiduciary capacity and bring them into that world. And what we're really doing now is putting more emphasis on the folks who are usually doing the right thing and operating in a fiduciary capacity. We're putting more emphasis on them and taking those that might struggle to give proper prudent advice and we're allowing them to escape. That's what it feels like with the way you described that Jason. [14:46] Jason Roberts: So there's interplay between regulation best interests which specifically applies to broker dealers and registered rep. In fact it exclusively applies on the space it was not written to cover investment advisors or other financial professionals. And there are certainly similarities in what's required when you recommend a rollover as a registered rep. And in the DOL proposed exemption the conditions are very similar. And so one could argue that well the broker dealers were already covered which really then leaves insurance professionals that would would be able to recommend rollovers into an insurance product that might be a one and done. You know, I take my commission up front. I don't it's not a product where there's any management of sub accounts or anything that I'm going to help you with on an ongoing basis. And so that's. That is the group that that sort of escaped the or potentially escapes the rollover piece. If I'm a broker dealer registered rep, my firm may suggest that we don't give rollover recommendation. We only educate in which case I'm still out. I'm out of both groups because both [16:04] Mark: yeah Scott myself he's policing himself. [16:09] JD: That's my problem with a lot of this. [16:12] Jason Roberts: Both regimes have the predicate is you have to make a recommendation. If all I'm doing is educating then neither one of them attach. I don't have to jump through any now the tension there is or I think what will be interesting over the next couple of months. It's one thing to claim to the SEC or FINRA that your registered representatives the policy is and that they're following the policy not to recommend IRA rollovers And if let's say a regulator looks in your files to see and sees communications that look like a recommendation well, the FCC and finra, there's, it's a lot of. It's in the judgment of the examiner. If the DOL comes in and the position is we don't recommend rollovers, and let's say you are an ria, so it's slam dunk, you're going to be considered a fiduciary in the IRA if you recommended the rollover. And let's say that the firm wasn't complying with the conditions because their position was we only provide education. And the DOL finds that systematically that was not the case. Recommendation was being made. The big distinction is in the the bet the company stakes that violating the dol prohibited transactions could lead to, at a minimum, you're disgorging all of those fees since inception. You're probably also paying excise taxes and some kind of a settlement penalty with dol, because how else are they discovering you're not self reporting it, I would think. And then on top of that, I anticipate DOL would try to calculate some degree of losses which you would be liable to restore. And the losses might not be your fees because that stands for disgorgement. It would be maybe higher investment expenses in the IRA versus the plan. And so to roll the dice, if you have, let's say, dozens or hundreds or thousands of advisors, smaller firms can, I think, better manage the onboarding process and maybe have a more credible position when they say we don't recommend rollovers because there's a handful of people involved and they know the rules. When you start to get into bigger firms and you tell them, dol, we don't recommend rollovers, you better be very, very careful that there's nothing in your files to suggest otherwise. [18:48] JD: That is the longest I've ever let a guest speak without interrupting them in the history of the show. Or at least since the last. [18:58] Mark: It was worth it. [18:59] JD: JASON ON I was just gonna say Chad, but the reason I didn't do it was on purpose is. Yeah, no, it was worth it. Those were great points. You put it all together so well. And so there was no reason for me to interrupt you. We're getting tons of value from that. Our audience is digging that. I know Mark doesn't like lawyer corporate speak, but the reason why is, Mark, you could never speak like that. You're not that intelligent. I mean, he was crushing it. They're using big words, but still putting them together in such an eloquent way. And I think you're just jealous. Mark is what that really is. [19:34] Chad: Well, first off, don't put words in my mouth. [19:38] Jason Roberts: Okay. [19:38] Mark: Secondarily, we have to. [19:41] Chad: I don't hear much of what Jason is saying because it's not because he's sitting so far away from where he's talking into that it sounds kind of muffled. I won't point that out, but it's because when I look at him, I just get lost in his eyes. [19:57] Jason Roberts: I know, I know. [19:59] Mark: That's why your saddy's sitting so far away. You connected those two dots rather well. [20:03] Chad: Yeah. [20:03] Jason Roberts: You did that on purposely. [20:05] JD: I want to give the live audience kudos. You guys are becoming. You guys and girls are becoming part of this show. The intelligence, the comments, the comedy, too. But there's a lot of 401k pros that are in that chat bar, and I'm trying to keep my eye on it. You guys are bringing up great points, and I'd love to dive down some of those paths once in a while, but it's a little hard. But I just want to let you know that I'm so proud of the people that show up to these suckers. And you really are becoming part of the show, so keep chiming in. Brad brought up a concept of, you know, I like this kind of simplicity of man. We should just, like, have a. A fiduciary title or a designation that you have to have, and if you have it and it's like, you know, we've worked on stuff like this. Planners have the cfp, which I think has gotten to a pretty big place in terms of branding. But I think what Brad's touching on is, like, you go to a doctor to get medical services, right? You don't. When you go to your doctor, you don't have to ask yourself if they're operating in the right way. It would be so cool if you could look at a retirement plan advisor and think the same way. And unfortunately, I think the way we try to tackle that is with designations, and I just don't know if those really translate to the marketplace. Any quick thoughts on that? [21:27] Mark: I've always been wondering, why does anyone [21:29] Jason Roberts: else have a different standard of care, if you will, for talking doctor speak? [21:32] Mark: It makes no sense. You're helping people with their retirement. You're helping people set up a plan no matter what. [21:38] Jason Roberts: Why? [21:38] Mark: Just because how you're licensed, why does [21:40] Jason Roberts: that dictate what you are and how you can provide advice? [21:43] Mark: Obligations. Yeah. [21:46] Jason Roberts: I've never understood that. [21:48] JD: I think most people are going to not do their client wrong on purpose. I think they're gonna do it through Irresponsibility, you know, they're just gonna get big in their day to day and what they're doing and therefore if they're not acting as a professional, that's why you need these kind of rules and laws. It's not like people are out to hurt other people. They fuck up. [22:11] Mark: And I'll also add to that, JD that I think many folks don't want to operate in a fiduciary capacity. Justin. Like they look at their business model and they say, why do I need to. I don't want to get myself in that area of risk so I can skate these lines real well and not be there. [22:29] JD: Chad, can I ask you, do you think that means the actual individual advisor or, or is that more decision happening at the broker dealer level? [22:37] Mark: Like I, I think both are true, but I really think it's more of an individual advice. But at the end, I mean, you're still doing the same thing. It's not true though. Josh. [22:49] Jason Roberts: What's that? I've even heard RIAs tell me that. Individual advisors with RIAs tell me that, hey, I, you know, I just want to show up and do the education. I don't want, I don't want to be painted with and generally it's more self preservation. The penalties, they're not experienced enough to know what's inbounds and out of bounds and they just are scared of the penalties. Jason the general rub is the forms of compensation which heretofore have been for the most part prohibited. So if you look at the three prohibitions that apply to only to ERISA fiduciaries, one of them says you can't get paid by a third party when you're providing investment advice or exercising discretion, you need to be paid directly by the client. And so if your compensation is solely commissions, trails, solicitor fees, 12v1 fees, that's, you know, it just didn't lend itself to serving in a risk fiduciary capacity. One thing that'll be interesting, I don't see there being a stampede to go this direction. But broker dealers, for example, under the prior regulation, when it said, you know, basically one time advice can be fiduciary in nature, they changed their 408 disclosures. And a lot of them said, and even the big company in Boston, if you recall the guidance that they were giving to participants previously was considered non fiduciary. And when that regulation went into effect, they came out and said we're giving now point in time advice. And so what will be interesting here is whether any of those firms will allow registered representatives, let's say serving plans, to operate under this exemption. [24:48] JD: Mark. [24:48] Jason Roberts: And I don't think that's why it was designed. So I don't think it would do a good job of mitigating conflicts. It was really designed. [24:57] JD: Mark, I need you to do two things for me. [24:59] Chad: Yeah. [25:00] JD: I want you to host the show from here on out because I really want to get involved in the chat bar, like there's some dope stuff going on in there. And then two, if Jason goes beyond 30 seconds, I need you to stop him. [25:12] Mark: Create a new chime. [25:13] JD: No, Jason brought up the fact I always got frustrated with the fees in terms of, oh, someone's getting a commission or a 12B one. And in my 401k world, what's the difference between if when you throw on a wrapper or, you know, 20 basis points, I don't care if you get 25 basis points in a 12B one or you get 25 basis points as an RIA wrapping it on top of it. I mean, as long as you're disclosing and you're transparent. I've never dug that argument. It never makes any sense to me. 401k. And I think it gets muddied up. But let's move on to a fun game. [25:48] Mark: Can I ask one, one last question? [25:50] JD: No, I just want to play a fun game. But you can keep boring us with this. Go ahead. I hate playing by your rules, Chad. [25:58] Mark: Jason, you mentioned self reporting and that in all likelihood the real risk comes from audit or perhaps your governing body, whether it be a BD or cracking down on you. Where's the real risk exist with this is it folks that are fearful because I don't hear any real penalty coming down unless you're caught randomly. [26:22] Jason Roberts: Well, and I think that's going to be it for the most part because the exemption, the proposed exemption has some conditions are part of those apply to the advisor and his or her notes. They have to analyze the plan versus the ira. There are certain data points that they have to address. They have to document the basis upon which they believe the recommendation to be in the client's best interest and so forth. And then there are firm requirements, part of the firm requirements that are new anyway is this retrospective review or compliance vis a vis that in particular exemption. So for example, there's annual testing requirements for both broker dealers and RIAs today under their current rules regime. This is testing specific to the conditions of that exemption. And so I don't think I can answer this. It's going to go over 30. [27:20] Mark: Yeah, well I was bringing you 15 more seconds for the R word. [27:25] Jason Roberts: What's going to happen for the most part is either DOL comes in and investigates or there is an information sharing arrangement between the SEC and dol. So perhaps SEC comes in and sees that it's an investment advisor. They're not technically subject to revvi, but they're doing rollovers and they don't have any compliance procedures for the exemption. Then they can refer that to DO sounds. [27:56] Mark: What I heard there is, it sounds like the likelihood of being caught and I'm not saying this changes anything, but the likelihood of being caught is incredibly minimal in the space that the people are going to be making mistakes because the plans that are going to be randomly audited by the departments that you're talking about are large plans and most have advisors who are operating in a fiduciary capacity and are making decisions in the best interest of the the client because they're really good at what they do. I think the bigger risk, like I mentioned earlier for the people who don't focus in this space and are doing it by a byproduct of relationship who end up making themselves a fiduciary versus with the advice they're giving and have no oversight on this. So I think again I think the people we're targeting are the people who are doing the right thing and the people who escape by are those who are questionable. [28:51] Jason Roberts: I don't think this one though is going to come up in the context of planned investigation by the time that unless it is the incumbent plan advisor and that's where the IRA rollovers are going. But if it is, if these are third party retail advisors soliciting participants out of these plans, that money's gone by the time the DOL gets through, right? So these would be financial service, financial institution investigations by dol, the other things. [29:23] JD: Let me wrap this. Lauren brings up a perfect advisor perspective. Here he goes and this is just a guy out there in the world says it sounds like I should just oh the chat bar flew me by. It sounds like I should just recommend individuals like the one that called me today, a termed participant in the 401k plan to go set up an IRA with TD or E Trade or Schwab or Vanguard because taking the risk to do the right thing isn't worth it. And that's a shame that advisors feel that way. Like there's, there's all this, this regulation over them that they can't help the right people. You guys Are having a very great conversation. But I want to have some fun. I came here to drink some beer, a little bit of vodka and play some games. So. Chad, Jason, shut the fuck up for a second. Let's play a game. Brandon, we're gonna go straight to your. Who is that? Game. If you're ready. If you're not, I'll toss it to Mark. [30:17] Mark: Might have fallen asleep. [30:19] JD: Brandon, you there? [30:21] Mark: He's drunk. [30:22] Jason Roberts: Yeah, no, I have myself on mute. Sorry. [30:25] JD: Let's go straight. Jason, we're gonna play a game. We're gonna play you some audio clips from movies. I'm gonna give you a small hint. All of these movies have something to do with nautical or boats or something in that vicinity. You make your guest go ahead and wait till the end of the audio. [30:43] Jason Roberts: And let's be fair. Just the scene does the scene. [30:47] JD: Fair enough. Always with the specifics. The scene does. I don't want to mislead you. All right, Play that first one. [30:54] Jason Roberts: And my son Ben. Hey, say swap, man. [30:58] JD: What happened to your eyes? [30:59] Mark: Waiting. [30:59] Jason Roberts: That's rude. [31:01] JD: Ah, that's all right. Shark attack. Swap. A shark ate your eye? Yeah, it happened when I went down off the coast of Australia. [31:11] Mark: Your boat sank? [31:12] JD: No, no, no, no. It's not my boat. That's my boss's boat. [31:16] Jason Roberts: Yeah, we hit this reef huge son of a. [31:19] JD: Ran the whole coast. [31:20] Jason Roberts: Wait, the Great Barrier Re. [31:23] JD: You heard of it, huh? [31:25] Jason Roberts: Smart lady. [31:29] JD: That's a tough one. That's a tough one. That is Kurt Russell to give you a little help. Kurt Russell in a. What's that? [31:37] Jason Roberts: Overboard? [31:39] JD: No. Good guess. Brandon's gonna throw that. It's Captain Ron. [31:44] Mark: That was the only one [31:47] Jason Roberts: I really was gonna say. I didn't know that was Kurt Russell. [31:50] JD: Ah, that's all right. [31:53] Mark: All right. What's the young man in the background there? [31:57] JD: Yeah, it happened when I went down. I gotta get me one of those beanies. That beanie looks okay. Let's play the next one. [32:02] Mark: Brandon, it looks like your hacky sack. [32:05] Jason Roberts: JD Here goes the next one. We hit this review. So you were saying. [32:10] JD: Hey, Gilligan, did you eat the skipper? You better pray to the God of skinny punks that this wind doesn't pick up because I'll come over there and jam it ore up your ass. [32:26] Jason Roberts: Creepers, those guys keep interrupting us. I'm sorry that you were saying about. [32:31] JD: Rest in peace, my fat guy in a little coat. Any guess? Jason, [32:38] Jason Roberts: Tommy boy. [32:39] JD: There you go. Correct. We're one for two. Very good, very good. Much better than Nevin Nevin. Was like, oh, for 10. Okay, next one. [32:51] Jason Roberts: Do you want to see it at all or just move on? See it? [32:55] JD: Let's see. Tommy boy. He's fine. [32:58] Jason Roberts: You were saying? [32:59] JD: Hey, Gilligan, did you eat the Skipper? You better pray to the God of skinny punks. If this wind doesn't pick up, cuz, I'll come over there and jam it ore up your ass. [33:16] Mark: Too good. [33:17] Chad: Too good. [33:18] JD: All right, Jason's one for two. Next one. [33:22] Jason Roberts: Can you say that again just the way you said it? Just the same way. I don't know what you're talking about. Oh, come on, you know what I'm talking. [33:36] JD: I didn't say the same thing. [33:37] Jason Roberts: I think what Jordan just did is he. I'm not mistaken. You just tried to bribe a federal office. [33:42] JD: Well, technically, I didn't bribe anybody. That's no quote. According to the U. S. Criminal code, [33:48] Chad: there needs to be an exact dollar [33:50] JD: figure for the exchange of services. [33:51] Jason Roberts: That would not hold up in a court of law. That's the truth. [33:57] JD: But think, Leo, that was Leonardo DiCaprio. And think, think. You know, investment and financial services. [34:06] Jason Roberts: Any guesses, Wolf of Wall Street? There you go. [34:11] JD: Maybe I'm giving away too many clues. Freaking clues. All right, two for three. [34:19] Jason Roberts: All right, I'll go to the next one. [34:20] JD: Yeah, play the next one. This video clips the same way. Stop, stop. Okay. Hey, you scratch my ankle. [34:56] Jason Roberts: No. [34:56] JD: No tips, no clues. Any gas? [35:00] Jason Roberts: That sounded like something from the 60s. [35:03] JD: It's Caddyshack. It's Caddyshack. That's. Why not? Go ahead, play the video. Brandon, if you can't, can. [35:08] Mark: Yeah, I can hear RDF in there. [35:13] Jason Roberts: What the hell are you. Oh, yeah, [35:23] Mark: Jason's a perfect blend between both of. [35:33] Jason Roberts: Them. [35:35] JD: Hey, you scratch my ankle. FYI, I chose to wear this hat before Brandon showed me any of those clips. I literally showed up. So it's just great minds thinking alike, my brother and I on the same page. So anyways, that was fun. Well done. Two for four. And you crushed Nevin Adams. So like I said, Nevin went over 50, I think is what happened on. On his episode. He went over 50, over 75, something like that. [36:10] Mark: Like five times. Yeah, over 75 is right. [36:13] JD: Let's dive into ESG. We had on Bonnie Trico here last week and had a good discussion. That was last week, Right. And had a good discussion around ESGs. These letters that are coming from the Democratic Washington D.C. peeps are a little upset with this. There seems to be a push in a poll on ESG and the rules around Them. What can you tell us? I know you've put out a few things and comments. Oh, geez. Yes. I'm gonna go straight to the vodka now. None of the mixer. Jason, update us on esg. What's going on? [36:55] Jason Roberts: That proposal is actually going to. What that proposed regulation is attempting to do is change the duty of prudence. So you have erisa, that has the broader brushstrokes, like any piece of legislation, and they're implementing regulations that the department and the IRS promulgate to implement certain portions of that. So one of those implementing regulations digs into more detail about meeting your duties under ERISA. 404. And so I think the most significant takeaway from the proposal is it's not guidance. It's a typical ping pong match or tennis match. Every administration, when you go red to blue, they have a different take on those types of issues. And they generally issue interpretive bulletins, field assistance bulletin, something like that. Here they're actually going in, trying to rework the regulation itself. [38:05] JD: It sounds like they're cognizant of this push towards sri, socially responsible esg. And there's a pretty hefty push back with this to say, no, no, no. It's laws of erisa. You need to choose your funds based on proper, prudent metrics that we've always used. And then now the Dems are pushing back, saying, whoa, hey, shit, what are you doing? Like, we want to move this forward. This is the right thing. That letter we talked about last week even talked about systematic racism, I believe, and like, you know, the new push of the world. So, yeah, there's definitely a fight. My problem with it right now is I mentioned this last week. I never thought that ESG was such a controversial thing. I always saw it as this, like, really positive, like, hey, what a great. What a great way to. [39:03] Chad: Because you're a hippie, dude. [39:05] JD: But I'm really not. I just look like one. And I'm more of a conservative than people would guess. And. But. But now I also understand this fight. I understand this pushback of. We talked last week. I don't know if you saw it, Jason, but it was Phil Troyer, a peer of yours, who said, well, if you can choose to have ESG funds. I'm not quoting him here, but he's like, well, then I could have similar things to say. I only want MAGA funds and investments. I only want things that are good for the United States. And obviously, if you read an opinion like that, your jaw hits the ground. He was doing it on purpose. He was trying to incite debate. So we're in a tough spot right now where the true tree huggers, sorry to call them that, that believe in making the world a better place. Now their only defense is to say, oh, no, no, our funds meet the normal IPS requirements. We're not choosing them because they're making the world a better place. We're only choosing them because their standard deviation is A. Okay. And their 3 year, 5 year, 10 year is good. And I think that's a bummer. Chad shakes his head no, [40:18] Jason Roberts: it's more than that, I think. I mean, obviously those are the outliers and I probably had, I could count on one hand the conversations I've had over the years with plan sponsors tend to be very regional specific. You know, you can probably guess some of the hotter spots where they're really, you know, looking to have a whole and all ESG menu. [40:41] JD: We're not just hot. We're not just hot on Covid here in California. We're hot for other things too. Go on, Jason, Idaho. [40:48] Jason Roberts: Well, and I know in particular a couple in the Bay Area, one in LA that I had to talk to about, you know, sort of not pushing their views on their employees. Now, most employees, they know their, their pushback. There was. Well, people work here because they believe in what we do. And I get it, I get it. But you gotta strike a balance. And that was before that was even under the Obama interpretation. So those are very few environmentalists. And I just really don't feel like that. [41:24] JD: Keep going, Chase. [41:26] Jason Roberts: Then. It may be a solution in search of a problem. Where I worry is think about just let's focus on the G and ESG per minute. If you're looking at fixed income and the governance of that company and its ability to pay its debt, that is, it's a governance factor. It's lumped into esg. But I mean, who's not looking at that from a fixed income perspective? So I think it's just the danger I see is firms going the other direction because they're so afraid of being viewed as having picked up this fund for ESG purposes and having to defend that and so forth. So I don't think it's a bright line. It's not always just save the trees or this or that. There's a lot of traditional ESG baked into analysis today. [42:25] JD: I hope so. [42:27] Mark: We've seen metrics change in an IPS for different types of investments. Why can't we see a sliver for ESG or SRI why can't we see different metrics and it have its own spot in a prudent core menu? [42:45] JD: Well done, Chad. That seems like the logical thing to do. But the hard right would say we can't allow you to do that because we need you to stick, stay the course and analyze and review your funds prudently. And it's not okay for you to have a sliver that's done a different way. [43:04] Mark: But you are, you're just creating your own analysis, your metrics. As an industry, we create our own metrics for those funds. In order to be qualified as an sri, it has to have a certain amount of specific types of investments or meet certain requirements. And then the metrics for reviewing who's performing well is not against another actively managed fund. It's against other sri's like we did for Target Date funds. Target Date funds was a brand new type of analysis that we didn't have in the past for traditional IPFs. [43:39] JD: Look at Greg Greenfield. He's to the right. Greg Greenfield says so you have to have ESG funds now even if they're not clearly performing well. So no, this is funny. It's like CNN and Fox. [43:52] Mark: But you don't have to have specialty funds either. You can. And those specialty funds can be categorized in that area and stacked up against other specialty funds doesn't have to be stacked up against a large blend fund. [44:07] JD: Jason, go ahead and Justin, you can give them 45 seconds. [44:11] Mark: Okay, sounds good. [44:12] Jason Roberts: Well, I think this is, it's important to keep in mind that this is a proposal and it is a proposal very much, you know, to the. Just call it what it is. It's a proposal firmly to the right. And the whole comment process is I will bring it back towards center. How much towards center will be to be determined. But I think to your point earlier, there is some middle ground, you know, that where you're not filtering first esg, but it's not as you don't get to the point where they're economically identical. Right. Because what is economically identical? But I think there is with proper communication and performance filters first, there still is an ability to offer ESG in a responsible way where you're not pushing it on the participants, you're making it available for those who would, you know who that fits their agenda. But so I looked at. I expect to see this come a little bit more back towards. [45:24] JD: Continue to love the chats, bro. Sometimes the chat is better than our show. [45:29] Mark: I want a breakdown. I've asked a few times, post a show like you can get it breakdown of the chat. I just want all the write up on the chat. [45:37] JD: We can get a breakdown of it. We can get a breakdown of it. By the way, I don't think anyone who's pro ESG doesn't think their ESG fund should meet the requirements of a typical investment policy statement. Like they want to run it through the rigors and make sure that it's right. It's just the problem is like Jason said, you may not choose first. Well, actually, no, that's probably what they would want to do is like, well, we're only going to choose ESG that meet these requirements. And the people on the far right are saying you can't fucking do that. It's not okay. You can't insert your own beliefs into a 401k plan. But I just wanted to chat a little bit about it. What is. He's got guests coming. I love TPAs. Go fund my529. Hashtag smartycawesome. [46:27] Jason Roberts: Wow. [46:28] JD: We want to see the kid. [46:29] Mark: There it is. Oh my gosh. [46:32] JD: Wow. So cool. Oh, no. We welcome this. [46:39] Mark: All right. Yeah, fill us in. Fill us in now. I heard a name there. Jason. We didn't catch it earlier. So fill us in. [46:45] Jason Roberts: Lola. Lola and Valentine. [46:50] JD: Well, I think they should stick around for just our next game. If they don't mind, they can play our next game. And the guy in the robe runs the game. So guy in the robe, what's the game? [47:03] Jason Roberts: Well, you know what they say. [47:06] Chad: Got a new game. [47:08] JD: What? You can't do new games. You don't have that power. [47:12] Chad: I have a break. [47:13] Mark: Those rules. [47:14] Chad: Mark changed our game. I felt like the lamer game game was lame. I. I gave myself the quiz and [47:23] JD: I told myself, I'm so sad. [47:26] Chad: And Nevin tried to name it. I'm like, if Nevin's trying to name my game, it's done. Retired, it's gone. It's an. It's Antonio Brown Its way out of here. [47:35] JD: Taking a lot of heat tonight. [47:37] Chad: Yes. So what I've come up with is, you know what they say, that's my game. [47:44] Jason Roberts: Okay? [47:46] Chad: The rules are pretty simple, guys. And I'm GLAD we're at 5:20 because this is going to take a while. So hopefully everyone's ready for the end. [47:54] JD: Hey, we might not have time for PepsiPs sucks. [47:58] Chad: Lola is gonna rock this game. Okay? That's what I got to say about that. So here's the rules, guys. I've picked song lyrics from recognizable songs, but I'm not picking the Hook or the chorus or the line? Everybody knows I've just picked some lyrics. I'm going to read them to you in maybe an accent or maybe a funny way, and you need to guess the song. [48:24] Mark: Okay? [48:24] Chad: Okay. It's pretty simple. This is going to be an ongoing, tracked performance for all of you. So it'll be like comparing ESG funds for all of you guys. [48:33] JD: Can I ask. [48:34] Chad: No. There's no questions. [48:35] JD: Okay. [48:36] Chad: So I will read the lyrics. You can either tell me the name of the song or who sings it. I'll give you some leeway there. Okay. If Jason, our guest today and future guest, gets it right. Why are you laughing? [48:51] Mark: Tony just said your rules take longer. [48:53] JD: He's wearing a polo. He's wearing a polo. Do you really think he's gonna get music questions right? I don't think so. [49:00] Chad: If Jason gets it right, he gets to assign his points to one of the retireholics. [49:04] Jason Roberts: Okay. [49:05] Chad: And also, if somebody gets it right quickly enough, then everyone else has to drink from your. From your penalty drink. And, yeah, you. I get forced to drink smearing off ice. So you guys all get forced to drink more. Boom. Okay, Done. All right. Everything makes sense. [49:24] JD: No, not really. [49:26] Jason Roberts: Once again. [49:27] Mark: Oh, Jason. [49:29] Chad: All right, here is song lyrics number one. Okay. Don't forget I'm reading this. [49:36] Mark: All right. [49:37] JD: We're not gonna sing it. [49:38] Jason Roberts: No. [49:40] Chad: Who's hot? Tell me who rock? Who sell out the stores? You tell me who flopped? Who copped the blue drop? Whose jewels got rocked? [49:53] Jason Roberts: Dr. Seuss. [49:55] JD: Fuck, I know that song. But. But who. Who do you go to? I don't understand. Like, we all just get a chance. [50:03] Chad: No, you just go. [50:05] Jason Roberts: You get. There's just one trifold left. [50:07] JD: Tell me who's who. [50:08] Jason Roberts: What's that Tribe Called Clef. [50:11] Chad: That's a great guess, but you're wrong. [50:14] JD: Tell me. [50:14] Mark: I don't even know who that is, [50:16] JD: so I'm gonna go with Greg in the chat bar and say Q Tip. Puffy. Puffy. No, that's his sidekick. Is that Puff? [50:34] Chad: Okay, next. Next song. [50:36] JD: Negative. [50:38] Mark: Don't you have to give us an actual answer? What's his real name at that. [50:43] Chad: Oh, that's. [50:43] JD: That was Mace. [50:45] Chad: That was Mo Money. Mo problems by Notorious B.I.G. [50:47] Jason Roberts: duh. [50:48] Chad: Okay. [50:48] JD: Oh, shit. Okay. [50:50] Chad: All right, next one. I'll never miss a beat. I'm lightning on my feet and that's what people don't see. Mm. That's what they don't see. [51:04] JD: I hate this game. [51:06] Jason Roberts: What? [51:06] Mark: Justin T. Swift. [51:09] Chad: Correct. [51:11] Jason Roberts: Wow. [51:12] Mark: That's the one Justin gets right. [51:15] Chad: All Right. [51:15] JD: Does Brandon have the music queued up? Yeah, we do. So you and Brandon got together on this? [51:23] Jason Roberts: Oh yeah. [51:24] Mark: I'm getting in trouble on that one. [51:28] JD: J.D. [51:29] Chad: yacht owner and Jason Roberts all have to drink now. And you're awarded 38 points. [51:35] Mark: Yeah, modern day who's. Who's line is it anyway? [51:39] Chad: I just give random points, by the [51:40] JD: way, by how impressed. [51:42] Chad: All right, next one. We're no strangers in love. You know the rules and so do I. A full commitment to what I'm thinking of. You wouldn't get this from any other guy. Countdown starts now. [52:02] JD: I'm gonna say Bieber. [52:05] Mark: Any other guy. I'm gonna say tlc. [52:09] Chad: Jason. Any guesses? [52:11] JD: Game's hard. Oh, that's an old guy gas. That's like. That's 80s. Oh, but close. Yeah. What? ZD. [52:28] Chad: Okay. [52:29] JD: Sorry, Maya. Shit. [52:31] Chad: The very last one is meant to be for Chad. Every time. Because I'm. He's never gonna get anything right. [52:37] Jason Roberts: Ever. [52:37] JD: This game sucks. [52:39] Chad: All right, here's my last one. Pay attention. Baby shark. Doo doo doo doo doo doo. [52:47] Mark: Baby shark, baby. All right, Grandpa shark. [52:55] Chad: That worked out perfectly by the way. And I didn't know that was gonna happen. Chad, you get negative. Hey, you know what they say. [53:09] Jason Roberts: You know what they say. [53:11] JD: Okay, I'm with Lauren and everyone look lame. Lame. Josh says lame. Tony says lame. I thought Lola was going to experience the lamer game game which is really cool. But instead you got this new version which sucked. But Mark, I appreciate you trying to evolve. Wow. [53:31] Chad: I'm just gonna say I'm highly disappointed in our audience today. I mean, talk about people who can't adapt to change. That's pretty, pretty sad. [53:41] Mark: They all loved you. They all loved you before that game, Mark. Now we all are in competition. [53:47] JD: We got five minutes for PEPS. We got five minutes for PEPs. And you know what? Peps suck. So that's all they deserve. Bye, Lola. It was so nice. Look, she is out. Is your baby alive? Is she alive? [54:01] Jason Roberts: It's a pink one. [54:02] JD: Hey, I'm gonna come over. I'm not far from you guys. I'm gonna pick some citrus from your trees. [54:08] Jason Roberts: Yeah, come. Come by. [54:10] JD: All right. She have an accent? [54:16] Jason Roberts: She's French. [54:17] JD: Oh my gosh. [54:19] Mark: It makes perfect sense. Perfect. [54:26] JD: Okay, let's real quick JD before we go to fiduciary. Yes, Justin. [54:32] Mark: There was a question from Greg a while ago. [54:33] Jason Roberts: A few other that. [54:35] JD: I like it. It'll leave less time for Paps. Good. [54:39] Mark: You're welcome. [54:39] Jason Roberts: So as a fiduciary. [54:41] Mark: If an Employee is asking for esg, [54:43] Jason Roberts: but they are proven not to outperform other options. What do you do? Like, where are you at as an [54:50] Mark: advisor in that role? [54:51] Jason Roberts: Like, what should you do for. [54:54] JD: I'm going to answer in 10, 5 seconds, and then I'll let Jason throw in her chat. Employees don't determine how you run a plan. They don't have a say in the matter. But I'll let Jason and Chad chime in. [55:11] Jason Roberts: I didn't get the question. So if, as an advisor, if an [55:17] JD: employee says, hey, I want to have [55:18] Jason Roberts: ESPs in my core menu, but you know that, hey, they aren't performing as [55:23] Mark: well as your current menu lineup or whatnot, you know, what type of, you know, what conflicts do you have in duties of erisa? [55:30] JD: Well, Nevin's getting nuts. [55:31] Mark: He is. Nevin. [55:32] JD: I love it. We're a bad influence on Nevin. He goes, if they. If they want you to buy bull testicles. So Nevin agrees with me. That's not their choice. [55:43] Jason Roberts: Well, I think maybe the question was if the employer asked you because. Yeah, let me find it again, as a fiduciary. That's what they said. Not. Not an advisor. [55:54] JD: Okay, so not the employee. [55:57] Jason Roberts: And this happens all the time. The employers that are pushing an advisor to recommend esg, or at least factor in esg, and you've got a couple options. I think it's pretty difficult as a 338. Right? It's a 338. You have discretion. The buck stops with you if you're 321, at least. Again, none of this is accounting for this proposed regulation that. That hasn't been finalized yet. But if the client is giving you the instructions and you are then applying those instructions and making recommendations that line up with what they wanted you to look for, and you're doing that in a prudent fashion, the buck still stops with them. Now, if you know they're doing something that is way over the top and they're sacrificing performance for ESG in a significant way, then under ERISA 405, you could actually still be held responsible for that. But I think generally speaking, there's been a way to do that. Without having the advisor be at significant risk. But I think that could go away. [57:16] JD: I also think in practice, it's. Hopefully I'm not. I probably am stating the obvious, but it's definitely the advisor's job to control that committee and let them know that, hey, there's an investment policy statement, and we have these qualitative and Quantitative metrics. And this is why we do things. So I mean that's why we're having these conversations today is to empower advisors to make sure they've got the intel that they need. I mean you need to teach and educate your committee so they know that they can't just willy nilly decide they want to do something. And that then takes us right back to the core of this ESG argument. So in a sense. Great question. We've got one minute for PEPs, which is solid because I think PEPs suck. Jason, I don't know if you've seen this. I've been on a huge anti just slamming campaign against PEPs and I actually don't really feel that way. But I thought it's been a lot of fun. I don't like them. My biggest argument has been that there's nothing. I don't feel like all the bullet points on a PEP brochure are nothing that you couldn't offer in a regular 401k. You know, minus coming together on the audit. I get that concept. But the low fees, the shifting, the responsibility, these are all things that can happen outside of a pep. What is your vibe? Let me ask you the question, just straightforward. Do you, Jason Roberts, and this will be on record all over the Internet, do you believe that PEPS will take over in some significant way in our, in our industry, in our marketplace? Yes or no? With an explanation? [59:02] Jason Roberts: I don't believe they will. I don't believe they'll take over. I think there will still be individual plans. I think we'll see Pepsi regain momentum in certain markets with certain advisors and certain plan sponsors. But I think the point you made earlier is this. The PEP structure will shift the most risk in a concerted way away from the employer. And the reason I say is that carefully is yes. You can hire a 316 plan administrator to do a lot of things that the poor plan provider would do today in an individual plan. But it the devil's in the details. I've never seen two 316 contracts that say the same thing. So there's always certain things that are described as discretionary in terms of administration. Hiring and firing service providers is never in there. Right. If you think about a 316 TPA, where do they a lot of times where do they get their leads advisors? They're not gonna hire and fire advice. [1:00:04] JD: Are you about to tell me that you think the difference will be the ppp? That that's this extra layer. Is that what you're is that what you're going at, Jason, or. [1:00:15] Jason Roberts: No. The pep, that whole model, it shifts the risk away from the employer, leaves them with either one or two decisions as a fiduciary. One is to hire the ppp. Is this a good PEP and a good ppp. And I have to periodically monitor that. I knew it was coming. We're going to see a lot, I think, of PDPS rollout where they don't manage the investments. And so now as an employer, I'll have two decisions. I'll need to select the investment professional or 338, or maybe I select the investments myself. I doubt that's going to be the case because, you know, if a plan sponsor is inclined to join a PEP and turn everything over to the ppp, why do they want to still hold? But if they're working, let's say they're working with a large RIA that's sophisticated in this space and that RAA is going to be the 338, then they have to prudently select and monitor that RAA, and they have to prudently select and Monitor the PPP. And what I'm saying there is the statute makes, requires it to be that way. Whereas now when we look at individual plans that are contracting with the 316, it's all about the contract, right? And those contracts very rarely will cover the selection and monitoring of service providers, which is part of the role. [1:01:42] JD: That's actually the best and most fairest point I've heard. Trying to create more value for the PEP in a fiduciary process versus the non pep. But again, I would, my argument would be, well, if I have a good contract and a good 316 and a good 338, and I, and I dot those eyes and cross those T's and I still am equivalent to your Pap. So, but, but that's, that's fair and that's, that's one of the better comebacks I've heard. [1:02:09] Mark: And you know, you know, my bickering with this topic is that there's a difference. Jason, every time you talked about the outsourcing responsibility, you talked about decisions, not operations. And I feel like even if you can outsource decisions, you still have the biggest part of the functionality of the 401k, which is processing the contributions, calculating them accurately, following the direction of the participants as to what they want deducted and when they want it deducted. That's where the majority of plans are making mistakes. [1:02:42] JD: Nevin average, [1:02:47] Jason Roberts: all of those bucks stop with the ppp. [1:02:50] JD: I think. I think Chad responsibility. Yeah. We got Nevin chiming in saying, hey, there's all kinds of people looking to steal your 401k. The kind that want to take away the tax incentive, the kind that actually try to steal your money, and the kind that look to steal your money by convincing you to move it from that protection. I look at the PPP and the more I start to learn about it, I know we're still putting questions out there to the government and we still need clarity on this, but the PPP actually scares the shit out of me. That makes me feel like you're giving a lot of power to someone that to me, you have to really trust. And it concerns me. I kind of like the more unbundled approach where I feel like the PPP seems like a far dangerous step to absolving yourself of all that responsibility. But. But anyways, I. I think we can all agree, and I think the entire world can agree that PEPs just aren't worth. So. So. [1:03:54] Mark: Hey, JD, I forgot to tell you. I'm leaving Plan Design to go start my own ppp. Jason and I teamed up. Everything's great. We'll see you later. [1:04:02] JD: No, no, no. I wish we could talk longer. Maybe we'll chat a little bit with Jason as we formally close the show and we could talk more Pepsi. But I do try to keep this sucker to about an hour and we've gone over it, so. For another time. For another time. Jason, we appreciate you muddying your very clean and spotless reputation by joining us once again on the retireholics couch. We really appreciate it. And. [1:04:32] Chad: And, oh, oh, having your family on, that was. [1:04:35] JD: Yeah, that was cool. And I also want to let us leave that. [1:04:42] Jason Roberts: And I moved this over here just for you guys. [1:04:46] JD: I love this. [1:04:47] Chad: No, no. [1:04:47] JD: White. [1:04:47] Chad: It's making me want a White Russian real bad. [1:04:50] JD: It looks just like Chad. It looks just like Chad. I. I also want to let the audience know that I've had an epiphany. I've always felt that Nevin Adams is someone that you should follow on LinkedIn. Lots of great articles, lots of great links. You should definitely do that if you're an advisor. I also believe now that. Check out Jason's stuff. And I'm not just saying this because he's on the show. In my research and my prep for this episode, I went through your history of posts, and if you're a 401k pro, you should be following Jason and engaging with that content because you put a lot of great stuff out there. And I even shoot. What was the article? I love the article. Was it on Ria Biz where the woman said they wrote an article, you then wrote them and said, hey, I think your article is good, but it's a little off. And then you wrote something for them over the course of two or three days. And I thought that come across really well and I enjoyed reading that. So anyways, if you're out there, make sure that you're following Jason. And then I don't know if. Is Michael Webb on Today, Justin, but Michael Webb's got some good stuff. That Guy is a 401k nerd in the highest form. And I mean that with all the positivity in the world. Check out Webb because that guy is putting out stuff on the regular that is educational and good and on point. So anyways, Jason, thank you so much for being with us. We appreciate it. I hope to mosey my way over to your place kind of post Covid and tell me about your land a little bit. Tell me about the citrus trees that you have and we'll end it with this exciting topic. Tell me about the citrus on your plot of land, Jason Roberts. [1:06:41] Jason Roberts: Well, we moved to the farm. So we've got 300 citrus trees, 250 Eureka lemons that we actually harvest and sell. And then we've got oranges that we. We actually donated 5,000 pounds of oranges this year already to produce. Good. They do lunches for kids that aren't in school anymore. And we've got some Mexican limes we've got. You just have to come by. We have pomegranate, apricots, nectarines. [1:07:11] Chad: Peace. [1:07:12] JD: He's got a painting of the dude. He's got surfboards in his. In his little space there. He's on this place with hundreds and hundreds of citrus trees. I mean, if you just lose the polo shirt, the guy's a straight up hippie in my book. I mean, I don't know what's going on, bro. And the French wife says Tony. Yes, and a French wife. I mean, what a combo. Anyways, I hope to come over and visit you soon, buddy. And likewise, you guys are invited to come hang out with us at my house too. So we'd love to. Can't wait to watch that kid grow up. Lola. Chad's daughter Maya sends us off on every show. [1:07:51] Mark: Whoa. [1:07:52] JD: I screw that up. What? [1:07:54] Mark: My daughter Maya. Chad's daughter Maya. [1:07:57] JD: Oh, Mark. Sorry, I'm looking at Mark saying Chad. Mark's daughter Maya sends us off every show. You know what? You guys are just employees to me. You all blend together. I really don't understand. Maya, don't touch your face. Ding. [1:08:11] Jason Roberts: Now. [1:08:11] JD: Thanks, Maya. All right, everybody. Thanks for tuning in. It's been an hour. [1:08:15] Mark: Thank you, Jason. Thank you. Fun as always, man. I wish I could get fun. [1:08:21] Chad: Congrats, man. [1:08:22] Mark: Enjoy it. [1:08:23] Jason Roberts: Thank you. [1:08:25] Mark: Night, everybody. [1:08:35] Jason Roberts: Sam. [1:09:01] JD: Wanna hold me Tell me that you wanna for me Tell me that you gotta show me Tell me that you need to slowly Tell me that you're burning for me Tell me that you can't afford me Time to tell your dirty story Time over and over time Turning fully global.