Scooter Campbell on CalSavers, Crypto & 401(k) Viability

[0:00] JD: Most of you probably already know Scooter here is a fancy schmancy attorney from Freak. Scooter, how the hell do you pronounce the name of your company? [0:10] Chad: Fakery drinker. [0:11] Scooter Campbell: Biddle of Re. [0:12] JD: Fakery. [0:13] Scooter Campbell: Fakery. [0:13] JD: He's a Harvard graduate. He's known as being from the top cop. Sorry, Top cop of erisa. Holding positions like the head of the Employee Benefits Security Administration and a plethora of other press titles. But what I am always most interested in is the unpublished bits. The stuff that really makes this man tick. His favorite genre of music is EDM and techno. [0:43] Chad: Nice, Brad. [0:44] JD: He was born on December 20, 1972. So for all of you astrology freaks out there makes him a Sagittarius. And this year he's also qualifies for Catcher contributions. [0:54] Chad: Yay. [0:57] JD: Ladies and gentlemen, the president of whatever company I can't pronounce, Bradford Gamble. Welcome, Bradford. Welcome. [1:07] Chad: I just heard this guy in the front go. Didn't we just listen to that fucker for 60 Minutes? Same guy. We're going to play some games today, Brad. And so I want to make sure that you're aware of these games as well as everyone tuning in out here. We're gonna play Chat Bar Champion for the people at home. There will still be a chat Bar [1:23] JD: champion, but who's looking paying attention to that? [1:26] Chad: We just look at it later. [1:28] JD: Makes perfect sense. [1:29] Chad: But as important, we're gonna have an audience champion. Actually, we're gonna have a first place and a second place. And you're gonna get a Amazon gift card and some other retireholic swag that nobody wants. [1:40] JD: What's the value of that? [1:41] Chad: 100 bucks. [1:44] Scooter Campbell: JD3. [1:44] JD: I remember. [1:45] Chad: Where did that come from? So what are the rules to Audience Champion? We have no idea, Kellen. You can't win at the show. We'll vote for the people we like or people we don't like, whatever. And you might win. [1:56] JD: Sean. You keep eyeballing me, Brad. This is the most important part. Listen, saw you looking at your phone. [2:02] Chad: This is the important part. And y' all out there in the audience can help us out. We're gonna be playing Acro sin like we do every week. If you say an acronym or an initialism, my name excluded. You must drink from your penalty drink. If anyone knows, don't tell the people that work here. This is mobile work, okay? [2:19] JD: It is the worst thing on earth. [2:22] Chad: And I got a brand new game that we're gonna release today. We're gonna try something new in front of people. It's probably Gonna suck. But it's called the Arista attorney game. Okay, let's go. Dang, dang, dang, dang, dang, dang, dang. Oh, yeah. [2:37] JD: Starting off early. Great start, buddy. [2:43] Chad: Yeah, great start. It's like lead off beer of the episode. Every episode we have a beer of the episode. That's not really true. I just lied to you. But sometimes we do. And this time it's Scottsdale blonde. Was supposed to be something else, but they gave us this. Thanks guys. At the bar. [2:58] JD: Yeah, thank you. [3:00] Chad: Appreciate you. [3:03] JD: It's delicious, by the way. As is all beer for best the [3:06] Chad: process in deciding this. They told us it's what we have to drink. There you go. Great episode. Let's get right to it, Brandon. Headlines. Let's do this. All right. Mark says it's kind of like a [3:23] JD: actual news headlines of that. [3:25] Chad: Oh yeah, it is. [3:26] JD: Got my papers here. [3:27] Chad: Let's start with an update from Calsavers. Now you might say, well, we're not in California, jd. Why would you care about cowsavers? I think this is relevant for lots of things. You all know we've got these mandates in other states. It's a continuing trend. And so I think it's fun to look at California and see how this stuff has come along. [3:48] JD: Correct me If I'm wrong, 14 states. And it was part of the recent setting every community up for retirement excellence 2.0 where they're talking about a federal mandate for it. So it is relevant. It's relevant for all of us here. [4:02] Chad: Totally relevant. I didn't prep as well as I should. Shocking. Shocking. [4:08] JD: Drank too much last night. [4:09] Chad: I'll go straight to you, Brad. [4:10] JD: Yeah, [4:13] Chad: Riff. No state run plans. Here comes California, here comes all these other states Chad's talking about. Don't things get messy in terms of all these different rules? Like California's got mandates or these size of employees and it's this type of individual retirement account and then another state's got another one. And wasn't this why ERISA was created in the first place? Is get rid of all this hodgepodge patchwork. And does this concern you, someone with your experience in state run. [4:45] Scooter Campbell: Well, the Employee Retirement Income Security Act. [4:48] Chad: Please get over the stand floor. [4:51] Scooter Campbell: You studied for that, didn't you? Thank you. Thank you very much. Yes, one of its purposes was for the uniform administration of plants. So you wouldn't have state by state benefits and a multi state employer wouldn't have to comply with, you know, 50 different versions of things. And this is one of the reasons I was Originally very much concerned about this trend. I was one of the people saying, hey, I'm glad the Trump administration was trying to halt CalSavers through litigation and supporting the litigation of some folks who tried that. I have to confess though, I've. I've turned the corner on this. And as much as it pains me to admit it, I think I was wrong. Because while there is still an issue with that in terms of the different programs operating in different states and that is a problem, at the same time, one of my big concerns was that we would see people not form plans, but instead just use the state payroll deduction irs, which boom, boom. [5:44] Chad: Brad, you can always finish your thought and save them up. Yeah. [5:47] JD: Because this is going to hurt. Just be prepared. [5:48] Scooter Campbell: This, I tasted this. This is vile. This is truly, truly vile. [5:55] JD: The aftertaste is yummy. [5:57] Chad: Stick with you. [5:58] JD: Wait till tomorrow. [5:59] Chad: You turn the corner because you saw the adoption of regular 401k plan. [6:04] Scooter Campbell: What we're seeing is that actually plans or employers who are going to have to do one of these payroll deduction individual retirement accounts is instead realizing the benefits of having a 401k. And so the data is actually saying this is proving to be a good thing. It's reaching some people who would have no other option, but it's causing employers to adopt a better plan in more cases. So it turns out I was wrong and I need to apologize to some better plan. I heard that when this came out [6:31] Chad: originally you guys sell nationally, but predominantly in California. So just share with everyone what gangbusters it's been. [6:39] JD: We've been, we've been tracking. I spent some time with Katie Solinsky who is the director director behind CalSavers. And she said, look, we're not seeing the adoption rates that we had hoped. And this was when they went in with 100 plus. [6:51] Chad: And I have some of those numbers here now that I found, which are [6:55] JD: super interesting to me. But anyways, I told her we would start tracking the number of opportunities that came in because of Cal Savers. And it was a lot immediately businesses and advisors talking about this as a necessity for these businesses that otherwise avoided it. And when it was 100 plus, these are restaurants, construction companies, I'll call them transient workers, meaning they're moving from a location to location. And that's not a nice thing to say about people. [7:23] Chad: Sorry, go on. [7:23] Scooter Campbell: You're right. [7:24] JD: I'm sure what was interesting to me though, and I agree for 1k better. The stat that they released in the update from 2021, 35% of investors in Cal Savers have invested from more than one company. That was mind blowing to me. That means that they are either working multiple part time jobs and otherwise would never have made eligibility for a 401k or they've left one business and are working at another and they have contributions within. This program has been running for four years. We could talk about the implementation was mostly all within the last 24 months. People have assets from multiple businesses. That blew my mind. [8:02] Chad: The greedy businessman in me is less interested in that much. [8:05] JD: 401k participants don't move around businesses that much. Think of how many rollovers you see from one to the next. [8:11] Chad: You brought that set up before and I don't know, I kind of ho hum about it. I get it. I think that's great for those people that never had access before. But let me, let me share with y'. All. In California, we had our first deadline in 2020, towards the end of the year for employers who had 100 employees or more. Second deadline was in 2021. That was for 51 to 100 employees. And now we've got June looming in 2022 for, believe it or not, five or more employees. You've got the gun to your head. You have to have retirement plans. Like not at the moment. And here's the numbers. Okay, so let me share with you. In that first wave, 1696 employers registered. 5442 were exempt, meaning they already had some type of retirement plan. And so anyways, 91% of everyone out there responded. So 9% of them didn't. And they had these new registered employers of just under two grand. Now check this out. We go to wave two. I would say that was pretty successful. [9:19] JD: Yeah. [9:20] Chad: 91 response. Bunch of new plans. We go to wave two. This is the 51 to 100 and you have a 77% response rate. [9:31] JD: Okay? [9:31] Chad: You, you got three thousand five hundred and eighty new registered employers. Just means they set it up. They did what they were supposed to do. They didn't have a 401k plan or a profit sharing plan or a cash balance or whatever. And they set it up. There were 5203 that were exempt and 8783 total responded to it. So 77% response, 3500 plus new plans. [9:55] JD: Acknowledge that the fines are significant too. [9:58] Chad: Here's the kicker. [9:59] JD: That's my question. [9:59] Chad: And we're not there yet. We're not 2022 yet. It's only April. But in this third wave, which I would argue is the biggest and most substantial wave. Right. To make a difference. You've got 21,000 registered employers, 49,000 exempt. Good for them. 70,000 responded out of a total 267,000 that were mandated to do it. You have a 26% response rate. So people haven't figured out that the guns to their head yet. So it'll be interesting. [10:36] JD: They don't know. I mean we're boots on the ground. Jayden, I'm telling you, the number of employers that we step into, the number of advisors that we talk to that have no idea that this is looming is insane to me. [10:47] Chad: Yeah, they know. They're calling California's bluff like a point. [10:53] JD: Really good delay. [10:55] Chad: Have you done that? Let's move on. Let's move on. [10:57] Scooter Campbell: Well, just one last thing I would point out what you're seeing there is that California is having implementation issues. Other states, Oregon did. [11:03] JD: New York did. Indiana did they all. [11:05] Scooter Campbell: I don't think they all even got theirs up and running yet. [11:07] JD: Despite city. [11:08] Scooter Campbell: Yeah, so. So my point is there are still problems here though. One of which is you have to recreate all this structure we have around our current retirement plan subject to the Employee Retirement Income Security Act. You have to recreate a lot of that. For example, delinquent. [11:22] JD: Save yourself a lot of headaches by saying the acronym. [11:25] Chad: All right? [11:25] Scooter Campbell: Arisa. [11:26] Chad: Nice people. Happy Brad. [11:31] Scooter Campbell: Give them what they want. Fair enough. But my point is things like delinquent contributions, we have a very clear process for dealing with that under our current retirement plans. They have to recreate all that from scratch. I don't even know what happens in California if the mayor doesn't forward the money. [11:46] Chad: Yeah, it's going to be a mess. Well. [11:47] JD: Right. [11:48] Chad: It will happen. Hey guys, guys, can I point? This is headline number one. This is serious problem. Two more. Jd. I'll skip. I'll skip. We're not even in California. We can just move past headline number two. Brandon, just throw it up quickly and we'll move right past headline number. Let me just go through all of them. Nobody cares about this. Let's move on some. You get a Grammy. Brad, can you see the title? We don't have time for this one. Sorry. Yeah, you'll talk too much about Cal Savers. [12:17] Scooter Campbell: Good marketing. [12:18] Chad: I'll read a little bit from it. Plan Advisor magazine recognize Scooter here as a benefits and executive compensation partner. Brad Campbell as the recipient of the inaugural Plan Advisor vision. Please tell me you have that tattooed on you. The Vision Award. [12:36] Scooter Campbell: That might be my first tattoo. [12:38] Chad: Aims to celebrate slow Clap industry leaders who have propelled positive change and contributed to the positive retirement outcomes for the U.S. workforce. Well done. [12:52] Scooter Campbell: Thank you. Thank you. [12:54] JD: JD Inaugural means first, right? Why does it say there's two recipients? [12:59] Chad: I guess it wasn't just Bradley. [13:00] Scooter Campbell: There were multiple visions, but yours is [13:03] JD: the only one that matters, right? [13:05] Scooter Campbell: Well, I'm biased in that respect, but thank you for saying. [13:07] Chad: You're very welcome. Good job. You're a visionary. Let's see. Let's go to our last. [13:11] Scooter Campbell: I will say it does concern me though, because if you watch the Oscars, this kind of sounds to me like a lifetime achievement award. We watch that on the Oscars. Whoever gets it dies two years later. [13:19] JD: Catch up contributions. Yeah. [13:23] Chad: Oh, drink, drink. Why? [13:29] JD: See, that's why we should research. Thank you. [13:32] Scooter Campbell: That's a contender for the audience award. [13:35] Chad: Make it Women in Pension Network. Oh, yeah, you rebranded. I forgot about that. My bad. That was cool. Good job. Okay, last one. There's excessive fee suit that was tossed out by the judge. It's Implant sponsor magazine. I think this is important because I think you all know recently we've had two cases in what, the ninth Circuit Court of Appeals that got kicked out and then came back. Right. They reinstated them. And so we're getting a little worried on this whole litigation front of like, wow, these things don't look so good. Well, this one got kicked out. It was Trader Joe's and Salesforce that have now gotten back into the mix. So we'll see how those play out. But I thought this was promising to see they can still amend their. Their case. Right, Brad? And come back. [14:27] JD: This is your expertise. [14:29] Scooter Campbell: Yeah, well, I'm not a litigator, but, you know, but yes. Now this is encouraging because following the Supreme Court, the Northwestern decision, there was a question about how low were pleading standards going to be in practice. In other words, how much do you have to show when you bring one of these class action lawsuits to make it past the very initial review where you try to kick it out at the early stage? And as you say, two cases in California, in applying the new Supreme Court ruling, reach the conclusion that, yes, they should move forward. This one, using that same logic, is saying, no, you didn't show enough. Now they have the right to amend it and try to improve it. But this is an encouraging development because it shows judges are going to be applying these standards in ways that don't just go one direction. They do actually permit these cases to be dismissed. And it's not a one way ratchet in favor of the plaintiffs. [15:14] Chad: I was I was happy to see that the judge said, hey, this case looks a little bit like, recreated like others, like kind of a copy and paste. Two, you're referencing fees for these other plans, like a benchmark that are just kind of randomly chosen. And then three, the judge said, hey, which was. This was a God blessing for me. You're not benchmarking services. Maybe there's more services being provided to this plan and therefore they have a higher fee. And I was like, okay, thank you. Someone said that, you know, that took [15:44] JD: you a while to swear on the show. [15:46] Chad: I think I've swear, so that's cool. [15:49] JD: What, what worried me as you read through that article is that there's some fear that if the liability never goes away when this is dismissed, but they have an opportunity to refile, to set a different stage essentially, then as a. As a plan sponsor, as a fiduciary, your liability on a specific situation never goes away. And it led into some articles of people saying, well, if they fix the issue, if they fix what was seen as an issue, even though that it wasn't enough evidence to prove move forward, then that gives them another opportunity to come back and say, ccc, they had to fix something. That's how we know something was wrong. [16:28] Chad: You don't know if their fix is gonna work to bring it to trial, you know, so. No. [16:33] JD: But if the fix is to lower costs in this specific scenario, to look at record keeping, not investment costs, but to look at record keeping, administrative costs, then then the fix is to find another provider or to get some. Some concessions of those costs. Right? And if the plaintiff then comes back and says, well, see, you acknowledge now that the fees were too high and that's why you went out and tried [16:53] Chad: to get a concession, you're actually tapping into another thing I think you all should check out. There's a white paper which I never heard of this company before, Euclid. So they're a fiduciary liability insurance company, and they came out with a white paper titled Debunking Record Keeping Fee Theories in Excessive Fee Cases. And it's pretty cool and it's pretty bold. It's pretty bold. And it goes into kind of what you're talking about, Chad, where although all the concerns with Schlichter and his peers and the way that they're attacking some of these things and how like you put, what if someone changes a fund and then you're looking and go, oh, why did you. Why did you make that change? Why did you move to a different shared class Must mean that the last nine years you were in some kind of violation and ripping people off. And that's a scary kind of thing. But check out those two things I'm just bringing up as a headline we can move on as like, that was the longest headlines. [17:49] Scooter Campbell: Yeah, 20. [17:51] Chad: Maybe there's some positive stuff and maybe these courts, these judges will start to look at this shit and say, okay, we're not just going to let it go to trial. If you can't come to. To this courtroom with some real, real evidence of some wrongdoing, then we're going to put you back. Because, you know, all they want to do is go to trial. So they can do what, Brad? [18:11] Scooter Campbell: Legalized extortion? [18:13] Chad: Yes, I was going to say, do [18:14] JD: they want to go to a trial? Don't they want to settle outside? [18:17] Scooter Campbell: They want to engage in expensive discovery process and then reach a settlement because business wise, it's cheaper to pay them to go away than to fight. [18:23] JD: Brandon, we need this one. [18:25] Scooter Campbell: It's the evil synergy of the contingent fee and the class action anyway. [18:30] JD: Cash fools everything around me. [18:32] Chad: Queen get the money $$ bill your on topic number 1.401k. We're right on time. Spin the wheel of ices. You want to go so fast? You want to spin the wheel of ice? Might as well, let's spin the wheel of ice. The wheel of ice. The wheel of ice. [18:59] JD: Told you when it was me last night in prep. [19:01] Chad: Okay, well, I do this because it takes me a long time to pound a smear off ice. I apologize. [19:08] JD: You have to hide it. Shh. We didn't bring it came from the bar. [19:14] Chad: Four one K. Friday's podcast. Rick Unser sponsor, David Blanchett now with pjim. He set me up. The title of their podcast, David was a guest on Rick's show is does TikTok have it right on 401k plans? Before I pound my smirnoffice, I just want to say y' all want to listen to Rick Unser and David Blanchett about TikTok, because those are two of the nerdiest fuckers in our industry, period. But Chad, tell me more what they were talking about. [19:47] JD: Well, there's a series of topics. What bothered me most at the beginning of that was the question that Rick asked, if a 401k didn't exist today, what would you invent? And neither of them came up with a damn thing. Like not even an inclination of what they might change. It was just support of the 401k. It was a. Yeah, it was a biased response. But the issue that came from that whole session of 401k Fridays was the younger folks are getting what I will call fiduciary guidance from advisors from people who are willing to go record 60 seconds or 30 seconds on TikTok. [20:36] Chad: Give some context, Raymond. So what they mean by what's happening on TikTok is, and you've seen this in general Internet and social media is there's a lot of people out there saying don't, don't save money in your 401k plan. These are on their little TikTok videos, right? You should not be putting money in your foreign. You should be doing something else. You can make a lot more money somewhere else. Crypto. And it's a trend on TikTok. You know, amongst the. [21:00] Scooter Campbell: You, it's. [21:01] JD: It's been a trend though. Let's not act like this is normal. YouTube has this. It's been there for years. It's been on other social sites. There are folks who don't believe that the 401k is a proper resource. I mean, listen to these two talk more. [21:15] Chad: It's getting more visibility. [21:16] JD: It is for sure. When you listen to them talk and you dive in a little bit to who the folks are, they're either, sorry, but folks who don't understand our space or folks who are trying to sell insurance. [21:27] Chad: They're always selling something. [21:28] JD: They're always selling. [21:29] Chad: They don't say, they're just trying to get more followers. [21:32] JD: It is [21:36] Scooter Campbell: selling insurance. I'd say it's folks who are selling bitcoin or services to invest in fractured shares. One thing I've noticed is when I'm playing like I'm at the airport killing time playing one of those games that has free. A free game, but it has advertising. A surprising number of these games are now including advertisements for crypto and other investing things. [21:55] JD: Whoa, whoa, whoa. [21:56] Scooter Campbell: I'm looking at that saying, when I'm mowing fake grass with the lawnmower, why is somebody selling me cryptocurrency? [22:02] Chad: Why are you playing games? [22:04] Scooter Campbell: Because I have a lot hourly billing, [22:06] Chad: some clients or some shit. I think anytime someone, I've never billed [22:10] Scooter Campbell: clients for mowing me along. [22:12] Chad: I think anytime, anytime on social media someone's telling you not to participate in your 401k plan. It's not like they're saying, well, just don't do anything. They have an ulterior motive. It's you should be doing real estate through my, you know. Yeah, three part course. You should be in crypto through this thing, it's always this other thing. And so we won't go too deep in that table. Let me ask Brad, Let me ask Brad. [22:35] Scooter Campbell: All right. [22:36] Chad: Ted Benna was quoted on this podcast, Chad and Ted Benna said, if we did not have 401k today in this current moment, it is not what we would invent. That is not the right solution. So you've been in government, you worked hard behind regulations, pension protection acts, qualified default, investment alternatives. Look at you. So do you think right now, if we had a blank slate, does a 401k a shitty like invention, should it be something way different? [23:12] Scooter Campbell: Well, first of all, 401k is not by any means a bad invention. And I agree that it is shitty, certainly not a shitty invention. It has saved, it has in many respects it saved our retirement system. Because the defined benefit plan simply is not for the vast majority of workers, viable going forward, either for the plan sponsor or frankly for the worker. Nobody wants to work at the same place. [23:34] Chad: Look at it last time benefit like you had carbon launch, you could do something new. [23:39] Scooter Campbell: So would I. Would you invent exactly the system we have now? If you were starting from scratch, I would agree. No, you wouldn't. Our system is a hodgepodge of responding to different things over the last 40 years and it kind of grew and we've cobbled it together. But there are some core decisions you'd have to make that are actually really tricky if you wanted to build something new. One is, is the thing you're going to build voluntary or not? And that's a pretty fundamental question. We have an employer based system because employment is a reasonable nexus for a lot of these benefits. But it doesn't have to be. We could have some sort of government run system which personally I would not be in favor of. But that is an approach that could get universal coverage and have some benefits. I think it would have bigger drawbacks than it would have benefits. But we have the reality, which is this is a system we've got and because of all the vested interests, you're not going to be able to create a whole new blank slate. So it's an interesting intellectual question, but it's not the question we ought to ask, which is how do we make the system we have function more efficiently and better? [24:37] Chad: That was not the question, Mr. Lawyer Guy. [24:40] Scooter Campbell: Well, I'm going to buy into your question. Come on, I got to come up. [24:44] Chad: I thought that was, well, well said. Of course it was. I educated guy over here. Smooth, very, very smooth stuff. Very classy. I'M learning a lot from you right now, dude. I personally, I learned something. Every time I think that the crack on 401ks is the negative opinion is. It's so complicated. [25:04] JD: Right. [25:04] Chad: All these rules, I won't go into all the acronyms. And it is. There's a lot of. [25:08] JD: Not for the average investor, it's not. Hang on. [25:11] Chad: There's a lot of moving pieces. I disagree with Brad a little bit in that I'm kind of a fan of mandates. Like on a federal level, like we have in California, like have plans. And maybe that wasn't specifically what you meant because you run. [25:25] Scooter Campbell: There's a difference between a mandate to have a private sector solution and a government imposed solution. I'll give you that. [25:31] JD: I'll give you. [25:31] Chad: Yeah. Versus like a mandate to have an employer contribution or who knows what. But mind you, all these complications, what they allow for is flexibility. So because you have actual deferral percentage test. [25:47] JD: Wow. [25:49] Chad: Because you have cross testing, because you have cash balance plans, because you have different eligibilities, because you can do all these intricacies, it allows you to create things for people that they want right from one business to another. If we push that aside and we start to go towards kind of a wider brushstroke to make things simpler and get rid of all these rules and all these details, then you just end up with a lot less happier people that don't get things built the way they want. So I say yeah, it's complicated, but it's complicated because we want that freedom and that flexibility to do all different kinds of design. [26:28] Scooter Campbell: Or put another way, Arista's flexibility. [26:31] Chad: Oh, if you had enough. [26:37] Scooter Campbell: Is its blessing and its curse. [26:39] Chad: Okay, yeah, I said it in three minutes. [26:43] Scooter Campbell: Two drinks of this God awful drink. [26:45] JD: But let me say JD though, if we have an opportunity to change, I think where we're changing is the right place, which is we need to find a way to customize solutions for the investor, the participant. And we're looking at that as far as decumulation goes, as far as what the investment options are. Automatic enrollment. Part of that article was re enrollment. I think if we continue to look at how, and I hate this term, but the greater good, if we continue to look at the greater good of getting more people involved, which is what some of these federal mandates or state mandates are doing and I hope it will become federal is trying to accomplish. But then we get granular and we change the way we can buys the average investor that is truly customized based upon the data that we have for Those individuals, that's when we'll start to make an impact on the ratio that they need to. [27:35] Chad: Do you think when you do that less people will on Tik Tok? [27:39] JD: Hell no. [27:40] Chad: No. [27:41] JD: The people that on Tik Tok are going to continue to. And actually catch me outside. [27:45] Chad: How about that? Yeah. No, no, no. Look, I just. [27:48] JD: That's not what I'm saying. Not what I'm saying. [27:52] Chad: I love you, but I disagree with you. I actually think it's more on a macro higher level. That's what we're talking about Here is the 401k plan as a designed vehicle for people to save, of course is not wrong. We can give participants more shit. I don't think they really want it. I don't think. [28:10] JD: I don't want to give them more shit. I want to give them shit that fits for them. Customize solutions based upon their age, their income, what their needs are. [28:18] Chad: We'll go to target day funds and we'll talk about that. [28:20] JD: That's not customizing solutions for people. [28:22] Scooter Campbell: People. [28:22] Chad: Scooter. Scooter, you wrote me an email. Oh boy. And you said, quote, I'm reading from here, I'm fired up right now about the Department of Labor. He used the acronym but I'm smarter than that. Very concerning guidance on cryptocurrency and brokerage windows. The implications go beyond. The real issue is the fate of brokerage account. So and you probably talked about this earlier today. I'm assuming the government came out, gave us this. What did we call it? [28:51] Scooter Campbell: They called it a compliance assistance release. Which is only the second time they've ever invented that term. [28:57] Chad: Right. [28:57] Scooter Campbell: And the first time was in a. It was structured differently. So this is some new form of what I'm going to call a glorified press release. [29:04] Chad: I like it. Glorified press release. And it was about crypto you've all heard about. Y' all know about. It was basically like don't do it. But you're saying, okay, crypto, interesting. But brokerage accounts. Now you're freaking me out. Yeah. [29:18] Scooter Campbell: And we alluded to this a little bit earlier. But here's the real issue. Yes, Everything they said was in the context of crypto. They gave a bunch of reasons why they don't like crypto and have concerns about it and have. Or one you should be. I think it's extreme caution as to whether it's prudent for a plan. But what they were really concerned about was direct investment in crypto related investments by participants, either as a designated investment Alternative. A core menu item. [29:42] Chad: Nice work. [29:43] Scooter Campbell: Thank you. Or through a brokerage window. And the problem with the brokerage window issue, and why this is a bigger issue is we have traditionally not had the same fiduciary duty in selecting what's available through the window. So DOL has now set this up so that without considering. Without considering the broader issues, without considering the broader issues of what this means for brokerage windows. What's my fiduciary risk in offering a brokerage window if DOL is now saying at least one type of investment through it has the same fiduciary duty as a designated investment? [30:21] Chad: Can I ask you, have you ever ate shit on that scooter before? [30:24] Scooter Campbell: No, but we might tonight if I haven't. [30:29] Chad: Let me ask you. So you see, bottom line is you're [30:32] Scooter Campbell: creating risks and problems that didn't exist before for brokerage windows as a whole. When brokerage windows, I think have a role to play for participants who want and should have access to beyond the plan menu. [30:44] Chad: Right. [30:44] Scooter Campbell: You know, if you listen to Shlomo Bernardi and folks like that, you talk about, okay, you got people you do it for. You have people, you have a select menu for and then you have people who can do it themselves. And the plan uses a brokerage window to address that last category in many cases. Deals throwing. [31:01] Chad: All right, I'll take one for you. [31:04] JD: You. Oh, fair enough. [31:05] Chad: Yeah, he does that for me. [31:06] JD: Kind guy. [31:08] Chad: I. I'm gonna sound naive here. [31:11] JD: So Good. [31:12] Chad: Which is. Okay. Like do we have clear guidance? Like I've got pushing a thousand clients. What do you think? How many brokerage accounts do we have, Chad? [31:22] JD: Leveraged or in the plan offering? [31:27] Chad: Both. Like, I mean but I'll bet you we have about 75. [31:32] JD: No, I'd say a little bit more. [31:33] Chad: 75 total or percent. Self directed broker. [31:36] JD: Jenny's been trying to get rid of the trust. [31:37] Chad: Anyways, it doesn't matter. The numbers don't matter. What matters is Brad, I. I was never sure that those clients were totally safe by doing that. That they did not have a responsibility in that matter. I was also worried when 445. I just have an why probably we have our brokerage. I was worried when 404A5 came out and the participant fee disclosures and like how do you do that in a brokerage account world? But. But are you saying no, we were pretty safe and cushy in that world until some of this. This weird. [32:12] Scooter Campbell: There was ambiguity about the full scope of the fiduciary obligation you have about Selecting what's available through the window. There is clearly some fiduciary obligation. It's not as though it's just, you know, he ha wild west. the same time it's not the same duty as selecting a designated investment alternative. [32:30] Chad: Because it's not a diagnosis. [32:32] Scooter Campbell: Because it's not. Because it's not one of those. Yes. And DOL tried shenanigans. [32:40] Chad: That's your word. [32:43] JD: No, Mark, let him go. Entertaining the department. [32:48] Scooter Campbell: I tried shenanigans on this back in 2012 when they put out guidance in a field assistance bulletin that tried to make the case that the brokerage window only planned was a violation. And they raised the same issue. Everyone pushed back and said your own regulation, the 445 regulation states that the brokerage window is not. That the window is a dia. But not. [33:12] Chad: Not doing that one. [33:14] JD: You know what they say? [33:15] Scooter Campbell: Dol had to rescind the guidance and come out with assistance bullet. [33:21] JD: Brad. I'll get one. [33:22] Chad: There's three more there. [33:24] JD: Brad. Oh. What? [33:27] Chad: Oh hey. [33:29] Scooter Campbell: What? [33:29] Chad: There's. There's more where that came from. Scooter, we got you just cuz you finish your cup doesn't mean you're done with the game. You're done. That's not how it works. Okay. He's a lawyer for sure. [33:41] JD: There's a legit fear there though, right? [33:44] Chad: Brad, don't drink that. [33:47] JD: There's a legit fear that if it is designated as a designated investment alternative they now have to issue 404 A5. Yeah, it has to be part of the 482. The. The brokerage account providers are not going to do so. The ones that are attached. [34:03] Chad: Why can't they make them? [34:05] JD: I don't think that they will from an overhead perspective. Why they're providing perspectives. [34:12] Chad: Everything has to start from somewhere. [34:14] JD: Justin asks the question so who does it fall on that. [34:17] Scooter Campbell: Well so if I'm the fiduciary. [34:19] Chad: That question I did. [34:20] Scooter Campbell: So if I'm the fiduciary who selected the brokerage window and I say okay, we'll have a menu of 3,000 mutual funds or Beautiful. Okay, well maybe my risk there is somewhat mitigated because those are diversified funds by themselves. [34:32] Chad: Right. [34:32] Scooter Campbell: On the other hand, why did I exclude ETFs? Why did I exclude collective investment trusts? Better should I allow individual securities, you know, operating companies to be. You've now raised questions here about a risk that I thought I was fairly comfortable not having. Now DOL has introduced that risk. [34:55] Chad: You love Department of Labor, Brad. That's your word. No, I. You've dipped your toe. Like a lot of things. You dipped your toe in and so now you're in there and then it opens up all kinds of issues. [35:08] JD: Can I ask you, though, should it be the Department of Labor that makes these statements? Well, are they the body that should be releasing this? [35:16] Scooter Campbell: What the department should be doing is using the regulatory process to make regulatory pronouncements, not issuing guidance that they just make up out a whole cloth with no input from the regulatory. [35:27] Chad: They are improperly regulating through non regulatory means. [35:32] Scooter Campbell: Exactly. [35:33] JD: I believe I said that. [35:34] Chad: No, he wrote that. [35:35] JD: Yeah, I was like, that's a big statement. Was saying it. [35:41] Chad: It's like I went to Harvard. [35:43] Scooter Campbell: Was surfing, reading this. [35:44] Chad: Let's. Let's mix it up. Let's play a game. You guys want to play a game? Let's play in for. All right, we're going to play the Arista attorney game and got a jingle. So listen to this jingle. It's the E to the R to the isa. Erisa attorney. Wow. [36:13] JD: Okay. There's no. There's no loopholes here, buddy. [36:15] Chad: Okay. All right, we've got some. Some attorneys, all of which have been [36:21] JD: on the show on that group. J.D. [36:26] Scooter Campbell: i hear. It was Jason. Robin. [36:28] JD: It was Jason. [36:30] Chad: Okay, we'll get there. We'll get there, we'll get there. We're going to do a few different ways, Brad. First, we're going to start with you. We're going to put up an attorney and someone else, and you need to guess who is older. Okay, we got Mr. Frederic and Alice Cooper. [36:52] Scooter Campbell: I got to go with Alice Cooper. [36:54] Chad: Alice Cooper is older. Drake, that's your buddy. When you email Fredericch and ask him for his birth date, it's awesome. Awkward. He's like, why? What is going on? I need to know. I need to know, is it your password for your. [37:12] Scooter Campbell: Well, I never asked Fred, but he did tell me once he was taking RMDs, so [37:18] Chad: goodness gracious. [37:20] JD: I think he likes me. [37:21] Chad: I think he loves. Let's move on. Let's move on to the next one. You're over one, Brad. Now you've got Jason Roberts, the real slim Shad. Oh, did you forget a Y, Brandon? I was drinking when I made this slide at Eminem. Eminem. [37:43] Scooter Campbell: I'm going to go Jason as older. As older. [37:46] Chad: Yeah. Oh, wow. You're doing good at this game. [37:52] Scooter Campbell: Yeah. [37:53] Chad: Clearly doing great at this game. Let's go to the next one. [37:56] Scooter Campbell: I'm also depressed to find out Jason's younger. [37:58] JD: Oh, well, this. [37:59] Chad: This Is Mark. I'm gonna go to you on this one instead of Brad, we got Brad and we got the Rock. [38:07] JD: Who is older? [38:08] Chad: Who's older? Any guesses out here? You can shout them out. I'm going with the Rock. The Rock. [38:15] JD: Adam, why'd you cover your mouth when you said that? [38:17] Chad: All right, Brandon, who we got here? Oh, you look as good as he does. When it came up, I'm like, I'm going with it. Trick question. They're tied. Makes it a little fun. [38:29] JD: Little Joseph. [38:30] Chad: We got one more. We got one more. Got Mr. Thomas Clark. That's the same person. We got Mr. Thomas. That's the same person. We got Mr. Thomas Clark. And then we got Yeezy. [38:43] JD: Yeah, tell me I'm wrong. [38:44] Chad: Brad. [38:44] JD: Same person. [38:45] Scooter Campbell: I gotta say, Tom Clark's older. [38:47] Chad: Tom Clark's older. [38:48] Scooter Campbell: That's what I think. Well, we'll see. [38:50] JD: I would agree disagree. [38:52] Chad: Oh, so that's a hat trick for Scooter. [38:55] Scooter Campbell: Yeah, I think at least he's consistent. [38:59] Chad: That's a hat trick for Scooter. I was gonna say well done, but no, not well done, Brad. [39:04] JD: More like medium rare. [39:06] Chad: Did pretty shitty at that game. I got a second part to this new game. There's more? Yeah, yeah, yeah. Why not? Why not? Great. [39:13] JD: Yeah. [39:13] Chad: It's so good. Why not continue, Mark. [39:16] JD: Oh, [39:19] Chad: who would you rather I'm out. You are going to let me set the stage for you. Yeah. You're going to a two day, two night, or let's say three day, two nights Las Vegas excursion. You're going to stay in like the hangover suite, you know, there's going to [39:40] JD: be what excursions exist in Las Vegas. [39:43] Chad: Vacation. Mike Tyson's Tiger is going to be there. All kinds of stuff. [39:47] JD: Great. [39:47] Chad: You're going to have a just blow it out. Two nights. Vegas, crazy time. Been there, done that. Which of these recommend it? Erisa attorneys will you choose to hang out with? It's you and him. And why? [40:05] JD: Oh, you know the answer to that, do you? Oh yeah, for sure. Robert. [40:11] Chad: I'm not a kiss ass so I'm [40:13] JD: not gonna pick you. I just met you. [40:16] Chad: Spare my father and his scooter would be an impediment. Fred has an aura of him that I feel like. Like if we went to a club or a bar they'd be like, you can't come in. So they deny Frederic. [40:30] Scooter Campbell: Yeah. [40:31] Chad: Tom Clark like the glasses that don't do it. [40:34] JD: So I'm going Jason Roberts. Because he has a boat. And he has a boat. [40:37] Scooter Campbell: He has a boat. I agree. That's. [40:39] JD: I would think Jason. [40:40] Chad: I think it's an obvious. [40:42] JD: And we saw him in Oregon. He knows how to party. [40:45] Chad: Justin, I'm going to say this guy knows how to party, but I can't. I feel like I get booed if I said you. [40:50] JD: Okay. [40:51] Chad: So secretly, I would pick you. [40:54] Scooter Campbell: Why, thank you, Justin. I would pick Jason. [40:57] Chad: Justin, same question to you. [40:59] JD: It depends on the night we're having. Are we. Are we having the hangover night? [41:02] Chad: Yeah, it's a. I mean, Roberts is [41:05] JD: going to give you that, but I think Roberts is. [41:08] Chad: Roberts has a newborn child. He's married. [41:11] JD: But still. [41:12] Scooter Campbell: Still. [41:13] JD: But I think Clark. He knows some secret shit that we saw his basement on one of our shows. He's gonna scare. He's gonna show some shit we've never seen. [41:20] Chad: I don't want to. Okay. All right, one more. Chad, you. [41:26] JD: You know where I'm going. We know his answer already. [41:28] Chad: You are going to an association of pension professionals. [41:34] JD: It doesn't matter. Even if it was in Vegas, I'd be like, what do you think about this, Craig? What do you think about that, Chad? [41:39] Chad: Chad, what do you think about this? It's going to be in Iowa. You're going to spend three glorious days listening to industry leaders give PowerPoints. PowerPoint. It's your dream come true. Excel. Listen. One hotel room. It's a king bed. And you're going to spend three days with this person studying, writing notes, learning about Arisa. Who do you choose? Who would you rather. [42:11] JD: Sorry, Brad, but Fred doesn't move in bed. He stays very still. And I'm going to be asking questions. How do you. [42:19] Scooter Campbell: About that information? 1 and 2. I would pick Alice Cooper. That's just Brad. [42:24] Chad: You. Brad, you work at Fred's office. And I've been known to sift through his garbage cans on occasion at his house, but. You're looking for recycling. Laguna. I just want to ask you at the office, is there like a reception or security. [42:39] JD: Don't answer that question. [42:41] Chad: Can you make. Where is his office located? And if I got into the front, can I get there like ocean. Does your office have a view of his? Where I could just peer and watch him do his thing throughout the day? Or I thought. [42:54] JD: Hold on. How does he not have. [42:59] Chad: Hold on. I thought we decided last night. The word. His first name was an Ackerson. We did. [43:05] JD: And that was like his name. [43:07] Chad: You better take that. Sorry, Brad. [43:10] Scooter Campbell: So you're saying Fred is an acronym for Frederick? [43:14] Chad: No, they're just against you on that one. I just Want to know. Can you see Fred's office from your office? [43:20] Scooter Campbell: Well, since he's in LA and I'm in dc. No. [43:22] Chad: No. Well, how good's your. All right, let's move on. Let's move on. [43:26] JD: That's an accuracy. [43:27] Chad: When we do a webcast, let's talk about some 401k shnet, shall we? Do we still have time, Brad? Yeah, we're good. Right. Brad, you remember that Plan Advisor Vision Award you recently got? [43:43] Scooter Campbell: I heard about that. [43:44] Chad: It said that you led the effort to draft and issue final regs establishing a qualified default and investment alternative. Can we all agree that this was a godsend for Target Date Funds? A literal tidal wave of money for them. Has the whole qualified default investment alternative and Target Date Fund success gone according to plan to the government version of you? Like you look back now, did that work the way you thought it would? [44:20] Scooter Campbell: Yes and no. And the reason I say that is we intentionally set it up so that there were three drinking primary options and we didn't identify any particular products. We described three mechanisms. The first was an individually targeted product. The second was a group targeted product. The third was an individually targeted service. And that. And it happens that, you know, Target Date Fund spit that first prong and became the most popular. But we weren't trying to pick a winner and loser. We were trying to. [44:49] Chad: Yeah, but when you guys came out and said, what was it, you could have your options? [44:54] Scooter Campbell: People thought of it as Target Date Fund, Balanced Fund, and Managed accounts. [44:57] Chad: Fair enough. And I went, Target Date Fund, blah, blah, blah, blah, blah, blah. And everyone felt the same way. We all went targeted. [45:04] Scooter Campbell: But what I think we've been seeing in recent years is the managed account approach. You know, allocating among the existing alternatives on the menu has been increasingly popular. And I think that what we were trying to do was put a regulation in place that would stand the test of time and not pick a winner and loser and not be out of date shortly. And I feel like we achieved that. In general, we didn't try to pick Target Date Funds. The market kind of picked them as the winner in the short term. We'll see how that works out over the long term. [45:34] Chad: Well, in your defense, if you would have picked any of the others, I would be ripping on you harder. It was the right choice. [45:41] JD: I mean, but going back in time, is that what you would pick between those three? Because Managed Accounts is getting heavy favor lately. [45:49] Scooter Campbell: Well, part of the difference, I think, is at the time we did it, the assumption was that Managed Accounts would be significantly More expensive than targeted. [45:56] Chad: And it was. [45:57] Scooter Campbell: And it was. It's no longer the case necessarily that that's true. And that's a change in the market which fiduciaries can respond to. The biggest issue at the time was would we allow stable value funds to be a standalone qualified default investment alternative? And we decided not to do that. And that was the big issue. In fact, I had a CEO, you keep saying. [46:22] Chad: Oh. [46:24] Scooter Campbell: Of a major insurance company try to get my nomination frozen because I wasn't allowing the. [46:30] JD: There's a lot of people in this room that probably don't like you for making that decision. [46:34] Scooter Campbell: Well, and that's a fair call. I still say though that you can't take a 25 year old and default them into a stable value fund and [46:40] JD: call that the right answer. Not disagreeing in any way, shape or form. But that's where the largest spread comes in our space. And I'm not criticizing you. [46:47] Chad: I feel like it was the right. It was the right call and I think it's done a lot of good. I feel like. I don't feel like. I know I did a little bit of research. Where are my notes? Vanguard, Fidelity have gotten. And I think next is. Is it American bonds or someone have like the bulk of the target date assets? Vanguard. Come on JD there was $170 billion in 2021 that flowed in to target date funds. 55 billion went into Vanguard. Wow. 45 billion went into Fidelity. And yes, the surfer remembered 26.2 billion went into American funds. I mean those companies love the government. You from how many years ago was. [47:46] Scooter Campbell: Was a while. Yeah, 2008, basically. [47:48] Chad: I mean they're rushing it because of all that stuff. And again, I know that was not your guys mo. That's not what you were trying to do. But they were the benefactors. I will say this. [47:59] Scooter Campbell: I still think that if you're looking at this as what can we do that approximates not to use your phrase, but the greatest good for the greatest amount of folks. The approach we took I think does that. And target date funds have been selected by a lot of plans and their advisors because they fit that. Now is this perfect for every person? No. Is it rough justice for the majority of participants in a given plan? [48:23] JD: Probably. [48:23] Scooter Campbell: I mean that's a plan by plan determination a fiduciary has to make. But by and large, target date funds have been pretty efficient for most participants who are defaulted into that. [48:33] Chad: Let me put some numbers in front of you guys. I want your honest opinion and I want you all to think what your opinion is too. We're good on time, Mark, relax. [48:40] JD: We ran out of beer early. That's why really have to go to the bathroom. [48:46] Chad: Slide under. We did a show. Once you left the show, I had to go. Yeah. There was no ifs, ands or buts about it. That's not going to happen about it. I got some numbers for you. And I know it's very childish of us to look at performance. But let me take Vanguard Fidelity and let's look back 3 year, 5 year, 10 year at the performance. I want to get your guys insights on whether you think this is good returns. If this is okay. And we're going to look at the 2045 fund specifically because. Why? I don't know. It's what I decided this morning in my hotel. Let's look at that one perfect three year return for Vanguard 2045, 11.07%. For the Fidelity Freedom Fund 11.71%. And because we know better than to compare to the standard and poor's 500. Good job. But the general world, that's what they compare it to. The Standard Poor's 517.16. I'm not saying that in any bad way. You know, it's 6% higher 5 year for Vanguard 10.50. 10 year for Vanguard 10.19. Fidelity Freedom in the 5 year 10.67 and Fidelity Freedom in the 10 year 9.99. Let's call it 10s and P5 [50:15] JD: in [50:15] Chad: the 5 year 15.53. And I know we've been in a bull market for a time but then in the 10 year the standard importers 514.54. So basically the target day funds. I should have just said this in about 10%. Are you cool with that, Brad? Has that succeeded for them? [50:37] Scooter Campbell: I think it absolutely has. Because you can't compare the performance of funds that are intended to approximate the risk for a person of a particular age against an index of all of the 500. [50:49] Chad: I think I stated that before. [50:51] Scooter Campbell: I use that as the go is not to say what could you have done compared to what happened? [50:56] Chad: But rather was it proven, Brad, they all do that. So you wake up and see reality. Like what they do. No, that's what they do. [51:04] Scooter Campbell: The fact that they all do it is not the same as saying that's the metric by which we just judge success. [51:10] Chad: I know it's improper, but it is what everyone does. They all look at that, the general public and says well if I was in the Santa Force 500. I wouldn't have made it, by the way. I agree with you. I think the 10% is just fine, [51:24] JD: but I think it's good. And I whispered in Brad's ear, like two things. Number one, that's not what it's about. [51:30] Scooter Campbell: I did romantic. [51:32] JD: That's not what it was about. Target date funds were not necessarily about, in my opinion, the rate of the rate of return. It was about having the appropriate risk based upon your age and time horizon. And it was about what else are we comparing this to? What's the alternative? And the truth is the majority of investors were not making good decisions. And this is grabbing. What's the stat? 70% of all dollars going into new plans are going into these asset allocation funds, whether it be target data, restaurants. That's a really good damn thing. A really greater good. Really good damn thing. [52:05] Scooter Campbell: Well, let me ask, I mean, there are a lot of advisors in the audience. I'm 49, almost 50. Should I be 100% in these standards and poor 500? Would any of you advise me to do that? Well, then why are we comparing it to that as saying that's the benchmark for success? It's not. It should be. The benchmark should be. What's a prudent. [52:22] Chad: You know why, Brad? Because I don't want to compare it to MorningStar's target date, 2045. Like, so I'm going to go, there's [52:31] JD: no real good alternative. [52:32] Chad: And I'm going to say I want to look at this, which is fine. And I know I'm wrong in this argument. I totally know I'm wrong. Let me give you some Context on a 2045 Target Date Fund in terms of how it's spread out. It's 52% in U.S. equity, United States equity. It's 33% in international, which was actually kind of a shock to me to touch back in on that. And then it's 15% in fixed income cash with just sub 3% in cash. And I know we have two verse through, but I'm looking at the Vanguard fund that we talked about. So that's what you're comparing it to. Okay, I agree with Brad. You really shouldn't be comparing it to Standard Poor is 500, but it's not the worst kind of thing to look at as a general consumer, Brad. And again, I back it up and say, no, you shouldn't have been in the S check swing and you shouldn't have got 14.54% over the last 10 years because that was not the Appropriate place for you. But you should celebrate the fact that. That you got 10 by being in a diversified smart portfolio. [53:45] Scooter Campbell: Yeah, doubling my money every seven years is not a bad outcome. [53:48] Chad: No. Okay, let's wrap it up, Mark, because I know you want to do that. You want to go to the bathroom, and we got to work some winners. Chop our champion out there. Don't know who you are. [53:58] Scooter Campbell: Internet. [53:58] Chad: We'll figure you out. Don't you worry about it. Mike Webb, Greg Greenfield, all good buddy here in the audience. We didn't have a lot of standouts. Justin, your vote for audience champion. You know, I'm gonna piss off the conference here. We're just gonna go one winner. We're not gonna play this like snowflakes. [54:17] JD: Did they get both? [54:18] Chad: One winner, 200 bucks. Amazon cards. Fuck their shoes. [54:22] JD: One winner. [54:24] Chad: I don't have the right to make that decision, but I'm gonna make it anyways. Who's your vote for the winner out here? [54:29] JD: Who wants to buy my drinks tonight? [54:31] Chad: Keeping your wife's name out of your. There you go. Him. That was the last you've won. You will also get a signed retireholics poster back there. Two Smirnoffs if they're left. I'm sure people have been grabbing them left and right. I'm sorry. Use it for kindling for your fireplace. Works good at the bottom of your litter box and maybe even come up. We got some schwag up here, but definitely get the 200 bucks in Amazon gift cards. Thank you out there on the Internet, you 401k freaks, you, for tuning in to our live show here in Arizona. We appreciate you and we love hanging out with you every Thursday night. Thanks to all you for sticking around. Even you in the back who are paying attention. Yeah. At all. Just talking. Hey, they're at the bar, though. They're at the bar, though. And thanks to the conference, the Western Pension and Benefits Council 2022 Spring Conference for having us. We are the retireholics. [55:31] Scooter Campbell: Wait. Thanks so much. [55:32] Chad: Thank you to Brad. [55:33] Scooter Campbell: I appreciate it. [55:34] Chad: Yeah. [55:34] Scooter Campbell: And Scooter. [55:35] Chad: I forgot Scooter. [55:37] JD: Scooter. Done. Thank you. [55:40] Chad: We are the retireholics. And we are just, like, changing the retirement. We're fucking up the retirement plan industry [55:51] JD: one beer at a time. [55:53] Chad: All right, we're out.