If you sponsor a 403(b) plan for your employees, you must satisfy the “universal availability” requirement as established by the IRS. According to IRS.gov, all employees of the employer must be eligible to make elective deferrals if any employee has the right to do so, with certain limited exceptions. Certain part-time employees may be excluded from eligibility to make elective deferrals.

The IRS also requires that any employer sponsoring a 403(b) plan must notify all eligible employees of this benefit at least once annually. In doing so, you are providing an “effective opportunity” for eligible employees to participate in the plan.

Top Three Ways to Notify Your Employees

Your plan administrator may provide communication templates you can personalize and distribute to your employees to make the notification process simpler. There are 3 methods by which you can distribute the notices:

  1. Mail. If choosing this method, be sure to retain the list of addresses used and the postage receipt.
  2. Hand Delivery. Prepare a list of employee names and have each employee sign their name to acknowledge receipt.
  3. Email. Strict guidelines must be followed for electronic delivery, but email is permitted.

If you choose to email the Universal Availability notices, this method is recommended in addition to mailing or hand delivery, not instead of. It should not be assumed that all recipients have access to a computer.

IRS Distribution Guidelines

The IRS has indicated they are auditing an increasing number of 403(b) plans, particularly in regards to Universal Availability compliance. An employer found to be non-compliant may have to make contributions to the plan on behalf of any eligible employees who did not receive proper notice. According to the IRS, compliance must be shown on a “facts and circumstances” basis. Treas. Reg. Section 1.403(b)-5(b)(2) stipulates that:

“…An employee is not treated as being permitted to have section 403(b) elective deferrals contributed on the employee’s behalf unless the employee is provided an effective opportunity….Whether an employee has an effective opportunity is determined based on all the relevant facts and circumstances, including notice of the availability of the election, the period of time during which an election may be made, and any other conditions on elections. A section 403(b) plan satisfies the effective opportunity requirement only if, at least once during each plan year, the plan provides an employee with an effective opportunity to make (or change) a cash or deferred election between cash or a contribution to the plan….”

Although the IRS has not provided distribution guidelines specific to 403(b) plans, the “best practice” is to follow the clearer IRS and DOL rules that have been developed for other types of retirement programs. Failure to comply with Universal Availability could disqualify the entire plan, so it’s better to be safe than sorry.

Are you a current MidAmerica client?  You can download Word templates of our Universal Availability notice by clicking on the links below.

Limited Eligibility

For plans which exclude certain employees from participation.

No Exclusions

For plans which allow all employees to contribute.

The Internal Revenue Service recently released the 2018 annual contribution limits for Health Flexible Spending Accounts as well as IRC types 403(b) and 457(b).

Health Flexible Spending Accounts

The annual limit on voluntary employee salary reductions for contributions to a health flexible spending account will be $2,650 in 2018, which is an increase from the prior limit of $2,600. The limit increase will apply when the employer’s FSA plan year begins. For example, if the plan year begins on June 1, the limit increase will kick in on June 1, 2018 during the open enrollment period.

Health Flexible Spending Accounts Contribution Limits
Tax Year Annual Limit
2018 $2,650
2017 $2,600

For more information on the increased Health FSA limits, review Revenue Procedure 2017-58.

403(b) Retirement Plans, Elective Contributions (TSA)

The annual elective deferral limit will be $18,500 in 2018, which is an increase from the prior limit of $18,000.

The following limits will remain unchanged in 2018:

  • If you qualify for the full amount of the lifetime catch-up, the catch-up contribution limit remains unchanged at $3,000. This brings the annual total limit for employees who qualify for the lifetime catch-up to $21,500.
  • The catch-up contribution limit for employees who are age 50 or over remains unchanged at $6,000. This brings the annual total limit for employees who qualify for the age 50+ catch-up to $24,500.
403(b) Plan Contribution Limits
Tax Year Basic Deferral Limit for All Employees Annual Limit if you Qualify for the Full Amount of the Lifetime Catch-Up (15 Years of Service). Total Lifetime Catch-Up Max of $15,000 Annual Limit if You Qualify for the Age 50+ Catch-Up Maximum Annual Contribution if You Qualify for Both the Age 50+ and Lifetime Catch-Ups
2018 $18,500 $21,500 $24,500 $27,500
2017 $18,000 $21,000 $24,000 $27,000

For more information on the increased 403(b) limits, review the IRS article, IRS Announces 2018 Pension Plan Limitations.

 457(b) Retirement Plans, Elective Contributions (TSA)

The annual elective deferral limit will be $18,500 in 2018, which is an increase from the prior limit of $18,000.

The following limits will remain unchanged in 2018:

  • The catch-up contribution limit for employees who are age 50 or over remains unchanged at $6,000. This brings the annual total limit for employees who qualify for the age 50+ catch-up to $24,500.
457(b) Plan Contribution Limits
Tax Year Basic Deferral Limit for All Employees Annual Limit if You Qualify for the Age 50+ Catch-Up
2018 $18,500 $24,500
2017 $18,000 $24,000

For more information on the increased 457(b) limits, review the IRS article, IRS Announces 2018 Pension Plan Limitations.

 403(b) and 401(a) Retirement Plans, Employer-Sponsored
(aka, MidAmerica’s Special Pay Plan)

The annual Section 415(c) contribution limits for 403(b) and 401(a) have increased from $54,000 in 2017 to $55,000 in 2018.

To stay up to date on legislative changes and trends, subscribe to our newsletter.

 

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It’s a never-ending battle.  Healthcare costs continue to rise.  As an employer, how do you cope?  If healthcare costs are rising, that means employee health benefit costs are rising.  You want to provide a valuable benefit for your employees, to retain and attract good talent.  For job seekers, the strength of an employer’s benefits package can be as valuable as the salary, even more so if they have dependents.  Employers have to become creative in their financial strategies to limit benefit costs.

How are employers dealing today?  Here are 4 strategies that some have adopted:

  1. Introduce higher premiums or employee cost-sharing.  This is a short-term tactic which shifts more of the financial burden to the employee.  Although it’s counter-productive for drawing talent, it is still a frequent tactic.  Employee cost-sharing offers several options, including higher deductibles and out-of-pocket maximums, moving from a fixed-dollar co-pay to a percentage-based co-insurance model, increasing employee cost for using non-network providers, and increasing employee cost for using brand name prescription drugs over generics.
  2.  Level-funding company healthcare costs.  You’re probably familiar with the traditional fully insured plan and the traditional self-funded plan.  Level-funding is a hybrid of the two, whereby the plan is filed as a self-funded plan, and the employer pays a fixed and unchanging premium per employee each month.  However, after one or two years, the plan is evaluated to see if the employer qualifies for a refund of premium if claims were lower than expected.  Likewise, the premium may increase at renewal if claims were higher than expected.  With a bit of ingenuity and planning, the employer could simultaneously implement other methods to encourage behavioral changes that lead to healthier lifestyles among employees, allowing the employer to realize premium refunds rather than increases.  Which leads to….
  3. Health and wellness initiatives.  This method of cost containment is becoming increasingly more common.  Employers have realized that improving employee health and wellness is an effective way to lower healthcare costs and improve productivity.  The key to the success of these programs is the use of incentives, such as rewarding employees for participating in a program or attaining certain health-related goals, such as smoking cessation.  Wellness programs should be tailored to the individuals, meeting them where they are in order to realistically assist them in reaching healthy goals.  Another important condition is the need to measure employee engagement.  If you know who is and who isn’t participating in the program, you will have a better understanding of how to implement incentive-based initiatives for the future.
  4. Consumer-driven health plans.  Typically, we are talking about Health Reimbursement Arrangements (HRA), Health Savings Accounts (HSA), and even Flexible Spending Accounts (FSA).  These plans allow employees to access funds to cover higher cost-sharing provisions in exchange for lower monthly premiums.  With employees being more engaged in the cost of healthcare services, they become better consumers.  They may be more inclined to consider the necessity of higher-cost healthcare in certain situations, e.g. going to an urgent care facility vs. the hospital emergency room. Further, this greater insight into how healthcare dollars are spent may also persuade them to make positive behavior changes in their lifestyles, leading to significant reductions in health plan spending year over year.  This is a win/win for both employer and employee.  Below is a breakdown of the differences between the 3 types of consumer-driven plans.

 

Health Care FSA HRA HSA
What is it? It’s an account to help employees pay for eligible medical expenses. It’s an account to help employees pay for eligible medical expenses. It’s a personal bank account to help employees save and pay for qualified medical expenses.
How do you get it? Enrollment is through the employer if they offer an FSA.  There is no need to enroll in a health plan. It’s usually connected to a health plan.  If the employer offers an HRA, enrollment is automatic when signing up for the health plan. Requires enrollment in a high-deductible health plan that meets a deductible amount set by the IRS.  Other IRS guidelines must be met in order to be eligible.
Who contributes to it? The employee.  The employer can also contribute if they choose to. The employer.  Employee contributions are not permitted. The employee, their family, the employer, and anyone else that chooses to.
How is the money put into it? The employer will deduct money from the employee’s paycheck, before taxes, and put it into the account. The employer may contribute on a monthly basis, or may fund the entire contribution amount at the beginning of the plan year. The employee can make deposits just like a personal bank account.  Family & the employer can also contribute.  Employee may be allowed to deposit pre-tax money from paycheck.
What happens if I don’t spend all the money in one plan year? The employer may choose to allow a carryover up to the IRS limit of $500. The employer may allow a certain amount to be carried over into the new plan year. Since the employees owns the account, the money will remain until they choose to spend it.
Can I keep the money if I leave my job? No.  The employer keeps the money. No.  The employer keeps the money. Yes.  The employee owns the account.
When can I start using the funds? The employee can start spending down the FSA on the first day of the plan year. Different types of HRAs each have their own rules as to when funds can be accessed.  The employer will set the rules. The employee can start spending down the HSA once enrolled in a high-deductible health plan and has opened the account.
Do I have to pay taxes on the money? No No No
What can I pay for with it? Medical expenses that are determined by the IRS & the employer.  This includes dental, vision, and many other health care services and supplies as listed under Section 213(d) of the Internal Revenue Code. Medical expenses that are determined by the IRS & the employer.  The employer may only allow the HRA to pay for services covered by your health plan.  Some HRAs can be used to pay for dental, vision, & other services/supplies listed under Section 213(d) of the Internal Revenue Code. Qualified medical expenses, including services covered by a health plan as well as expenses listed under Section 213(d) of the Internal Revenue Code.
Can I have other accounts with it? Yes.  The employee can have an HRA or a dependent care FSA. Yes.  The employee can have a healthcare FSA and/or dependent care FSA. Yes.  The employee can have a limited-purpose FSA or limited-purpose HRA, which can only be used for eligible dental and vision services.

While health insurance premiums will continue to rise, employers have options to potentially reduce escalating costs while still providing a valuable benefit to their employees and encouraging employees to become more invested in their own healthcare.  If you’d like to learn how FSAs and HRAs can help you achieve your financial goals, contact us today at accountmanagement@midamerica.biz.

 

MidAmerica Administrative & Retirement Solutions has been providing retirement solutions since 1995, and health and welfare programs since 2002.  Our goal is to maximize benefit dollars for both the employer and the employees.  Our staff of highly experienced subject matter experts, ease of technology, and streamlined administration enable us to reach this goal.  Please contact us if you’d like assistance in reaching your goals.

 

The average American spends 20 years in retirement¹

That’s a long time! Make sure you’re ready by saving now for the retirement you’re envisioning.

Waiting to contribute could cost you

What difference could 10 years make? Over $250,000. If at age 25, you started with a $1,000 investment earning 10% annually and contributed $100 a month, you will have earned a total of $415,466 by age 60. If you waited ten years to start saving at age 35, you would only earn $145,846 by your 60th birthday.

Baby Boomers and Millennials contribute the most

According to the 16th Annual Transamerica Retirement Survey conducted by the Transamerica Center for Retirement Studies, Baby Boomers (those born between 1945 and 1964) and Millennials (those born between 1980 and 2000) contribute 8 percent of their annual pay, while Generation X (those born between 1965 and 1980) only contributes 7 percent.²

Prepare to hit the open highway

TransAmerica Center for Retirement Studies and the Global Coalition on Aging found that, despite travel ranking as one of the top dreams for life after retirement, only two in every ten Americans have actually factored this dream into their retirement savings strategy.³ Want to take that trip to Europe? You can! Don’t just dream about it. Make it a part of your retirement goal and be sure your luggage is packed for those golden years.

ACA Employer MandateComprehensive healthcare reform legislation was signed into law by President Barack Obama on March 23, 2010. Known as the Patient Protection and Affordable Care Act, it was nicknamed the ACA or Obamacare. The ACA stipulates “employer shared responsibility rules” which require applicable large employers (ALEs) to offer affordable, minimum value health insurance coverage to their full-time employees or pay a penalty. These rules apply to employers with at least 50 full-time employees during the preceding calendar year. The employer shared responsibility rules are also known as the “employer mandate” or the “pay or play” rules. An “ALE” may be penalized if one or more full-time employees obtain a subsidy through the healthcare exchange because the employer did not offer health coverage, or the coverage offered is not affordable or does not provide minimum value.

The ACA Is Questioned

Upon his inauguration as President on January 20, 2017, Donald Trump signed an executive order to minimize the economic burden of the ACA until the law can be repealed and replaced. The order did not provide specific guidance related to any particular provision or requirement of the ACA, and appeared to be more of a mission statement for the President’s administration going forward. Further, only Congress is authorized to make changes to the ACA, i.e. through the legislative process. The President is not empowered to alter legislation. Nevertheless, business owners took notice of this executive order and began to wonder if the employer mandate would go away, along with any associated penalties.

The IRS Responds

The President’s executive order created confusion when it directed the Department of Health and Human Services and other federal agencies to “waive, delay, or grant exemptions from ACA requirements that may impose a financial burden”. In response, the Office of Chief Counsel within the IRS issued Letter numbers 2017-0010 and 2017-0013 on April 14, 2017, to clarify the impact (or lack of impact) of the executive order on the employer mandate rule. These letters confirmed that the pay or play rules continue to apply. Taxpayers must still adhere to the ACA requirements, including paying any penalties they may owe.

Where Do We Stand?

For the time being, it’s business as usual. Although both houses of Congress challenged the ACA between May and September 2017, all efforts failed to repeal and replace the law. The result is that the ACA is still in effect until the Senate and/or House, both Republican-led, can craft a viable alternative that will garner sufficient votes to proceed to the President’s desk for signature. In the meantime, ALEs must continue to comply with the employer shared responsibility rule as well as any other reporting requirements.

In fact, The ACA Times has reported that “all signs point to the IRS being prepared to enforce the employer shared responsibility mandate of the ACA”. The website suggests that by December 2017, “the IRS could be sending enforcement notices to inform businesses with 50 or more employees what they owe for failing to comply with the employer shared responsibility mandate”. These notices will serve to enforce the ACA compliance mandate starting with the 2015 tax year. The IRS website does not contradict this opinion and provides a lengthy Q&A dedicated to the employer shared responsibility provisions under the ACA, including information on how employers will be notified of any penalties assessed and how payments will be collected. Now that the myth of the employer mandate waiver has been dispelled, employers would be wise to ensure they have filed all necessary documentation with the IRS to minimize any potential penalties, and then revisit the status of their health insurance offerings and prepare to be ACA compliant, to avoid possible penalties in future tax years.

Where Can Employers Find Help?

MidAmerica’s TotalCare product, offered in conjunction with MyBenefitsChannel, is not just ACA compliance software, but a total ACA consulting service. It enables schools, government, and mid to large employers to reduce potential liability and internal ACA compliance workload, while keeping clients audit-ready. For a low Per Employee Per Month (PEPM) fee, the employer will receive a “Do It For You” (DIFY) solution that:

  • Ensures 95% certainty of compliance
  • Automatically rolls data into IRS reporting
  • Auto generates required notices
  • Tracks for audit preparation
  • Provides optional audit management
  • Is accessible via a mobile application

Despite a series of attempts to repeal the Affordable Care Act, the law is still intact. As your benefits compliance experts, MidAmerica will continue to monitor the status of any potential healthcare reform and ensure you are aware of any effects new legislation could have on your clients’ retirement and healthcare benefit plans. We are committed to providing quality benefits solutions to public sector employers while meeting their budget objectives. This commitment drives us to meet changes in the benefits environment with products that will ensure employers are compliant while receiving the best value for their money.

If you would like to learn more about the TotalCare product, please visit http://www.mymidamerica.com/acatotalcare/.

The fate of the Affordable Care Act, aka ACA or Obamacare, has been uncertain in 2017. Republicans in Congress have been determined to find a suitable replacement, but it has been a struggle. For months now, Republican legislators have taken turns drafting new bills, both in the House of Representatives and in the Senate. Each new version has faced opposition not only from Democrats, but even within the Republican Party.

While pressure mounts, mainly from the President, to put a bill up for vote, the lack of a consensus in our legislative houses is quite evident. A number of key senators have expressed specific requirements and provisions that must be included in a new healthcare law and have vowed to vote against any bill that fails to include their desired provisions. While the debate in Congress continues, we are providing you with an outline that illustrates the sequence of events that has taken place since early May, leading up to the latest developments. Since this situation is very fluid and the news reports seem to change almost daily, a timeline may help to clarify what the stumbling blocks are and why the healthcare issue presents such difficulties.

  • On May 4, 2017, the U.S. House of Representatives presented their version of a healthcare bill, known as the American Health Care Act (AHCA). While preserving many aspects of Obamacare, the AHCA presented some clear changes to tax incentives, mandates, and certain public health policies. The House-approved bill was sent to the U.S. Senate for a thorough review.
  • The Senate introduced their own rendition of a healthcare bill on June 22, known as the Better Care Reconciliation Act of 2017 (BCRA). The Senate bill immediately lacked enough Republican support to garner the required number of votes.
  • In response, the Senate unveiled a revised version of their BCRA on July 13. With hopes of satisfying concerns from both political parties, this new version included the Cruz Amendment* and additional funding for opioid treatment.
  • By July 18, the BCRA was still failing to attract enough followers for a vote. Senate Majority Leader Mitch McConnell now focused on swaying senators to vote on a bill that would repeal the ACA within two years, allowing Republicans not only time to write a more thorough and considerate healthcare law, but the time to transition the country to a new healthcare system.
  • The President hosted a luncheon on July 19 for GOP senators, urging them to repeal Obamacare, certainly, but preferably to repeal AND replace. He recommended they cancel their August recess and remain in Washington until a reform bill was finalized.
  • On July 20, Republican senators reopened negotiations on their BCRA legislation, resulting in a second revision which removed the Cruz Amendment* and retained some tax measures included in the Affordable Care Act. Still failing to attract the 50 Republican votes needed to bring the BCRA to the floor for debate and a vote, Senator McConnell announced there would be no replacement in the coming days, and the Senate would proceed to vote on repealing the ACA with a two-year delay. This latest piece of proposed legislation became known as the Obamacare Repeal Reconciliation Act, a repeal-only bill.
  • July 25 and 26 saw marathon debating in the Senate over whether to disassemble Obamacare completely, resulting in the Senate’s rejection of a full ACA repeal without replacement. At this point, Senator McConnell needed to round up 50 Republicans that would back a final bill in some shape or another.
  • On July 27, a “skinny repeal” was debated in the Senate. This legislation, also known as the Health Care Freedom Act, would have repealed the individual and employer mandates contained within the ACA, as well as the medical device tax, and cut off funding to Planned Parenthood. With enough support behind the skinny repeal, Senator McConnell would have been able to introduce a repeal and replace bill to a conference committee with the House, where a more comprehensive proposal could then be negotiated with House Republicans.
  • In the early morning hours of July 28, the Health Care Freedom Act failed to acquire the necessary number of votes, with Senator John McCain (R-AZ) being one of its most vocal opponents. McCain is now urging his colleagues to send the bill back to committee, listen to feedback from both sides of the aisle, as well as our nation’s governors, and “produce a bill that finally delivers affordable health care for the American people”.

With the failure of this latest bill, it appears that Obamacare will remain in effect for now.  However, the President is still hopeful that the Affordable Care Act will be repealed and ultimately replaced. Only time will tell what sort of legislation will be crafted by Congress and presented to the President for signature. As your benefits compliance experts, MidAmerica will continue to monitor the status of healthcare reform and ensure you are aware of any effects new legislation could have on your retirement and healthcare benefit plans.

MidAmerica’s focus is on public sector employers and their ability to provide quality benefits solutions to their employees while meeting their own budget objectives. We provide the guidance, tools, and resources that our clients and partners require in order to effectively administer their retirement and health and welfare plans. We are committed to keeping you informed, and we will provide updates on this topic as they become available.

 

*The Cruz Amendment, spearheaded by Senator Ted Cruz (R-TX), would allow insurance companies to sell plans that do not meet minimum ACA coverage requirements, provided there is at least one plan offered that will meet coverage requirements.

6 Retirement Planning Mistakes to Avoid

Posted on July 14, 2017

When you hear the words “retirement planning”, do you experience feelings of excitement, or dread? For most individuals, it’s probably the latter. That’s unfortunate because retirement planning is a financial goal that most of us have to face, and its importance cannot be overstated. When it comes to planning out the financial state of your golden years, you’ll want to make sure you get it right, because there are no “do-overs” in retirement. The outcome may mean independence and financial freedom if you’ve done your homework, or poverty and financial stress if you haven’t.

Much has been written about the basic principles of Retirement Planning 101, such as:  Have a Plan, Be Sure to Save Enough, Be Sure to Save Early Enough, and Don’t Rely on Social Security. Let’s focus here on some other pitfalls that you’ll want to avoid falling into:

  1. Spending instead of rolling over. A very basic rule of financial planning is to never withdraw money saved in a tax-deferred account until after you retire. Unfortunately, many workers who switch jobs early in their careers cash out their 401(k) plans rather than rolling them over to an IRA, meaning they are paying taxes on the money as well as a 10% penalty for being under age 59½. What may seem like a negligible amount of money will actually compound over many years into a significant savings. Cashing out early eliminates this compounding opportunity.  You can see for yourself by trying this free compound interest calculator provided by FinancialMentor.com.
  2. Taking advice from friends and family on how to invest. You trust your friends and family members for advice on many different topics, such as the best new restaurant in town or where to spend your next vacation. But when it comes to money matters, you’re better off consulting with a certified financial planner and registered investment advisor. Not that your friends don’t have your best interests in mind, but they probably aren’t aware of the many tax laws and retirement investment strategies that need to be taken into consideration when handling your personal financial situation. It’s best to leave that to the experts.
  3. Believing you’ll want to work forever. When you’re in your 40s and 50s, enjoying good health and vitality, it’s easy to predict that you’ll want to continue working into your 70s. However, circumstances can change and health conditions can emerge, causing you to rethink that plan to keep on working. Working part-time or even launching a second career after retirement are great ways to feel productive and engaged, but this earned income should be considered a bonus to your lifestyle, not a necessity.  It’s problematic to plan your retirement security on earned income such as this, because you may realize you don’t want to work as long as you once thought you did.
  4. Ignoring inflation. Costs continue to rise, so the money you have today will buy much less 10 and 20 years from now. It’s important that you take the rate of inflation into account when forecasting your budget and managing the distribution of your retirement assets, to ensure that you calculate a realistic amount of income to sustain you years from now. Try out this inflation calculator, provided by Prudential, to see how inflation will affect your spending dollars over time.
  5. Starting Social Security too early. Early retirement benefits are available at age 62 but there is a financial bonus for collecting Social Security later rather than sooner. The earlier you begin collecting benefits, the less you can expect to receive. Waiting until you reach the full benefit age – which depends on the year you were born but let’s say age 66 for the sake of argument – will ensure an additional 8% benefit for each year you delay collecting benefits. If you wait until age 70, your benefit will be 32% higher because of that delay. It may be tempting to begin your Social Security benefits early to guarantee a source of income, but it may be wiser to start spending down your retirement savings first, and thereby delay taking Social Security. Of course, this is dependent upon how much of a nest egg you have accumulated.
  6. Spending too much early in retirement. You have your freedom now to spend your days as you choose, enjoying your hobbies and not having to cram your vacation into a one week window. But here’s a word of caution – your money has to S-T-R-E-T-C-H and you have no way of knowing for how long. When you’re in the early stages of your retirement, any assets still invested have time to continue to grow. Overspending at this time creates two issues – the loss of the money for one thing and the potential returns that money would have garnered over the next 20 years or so. It’s important to consult with a financial planner long before you retire, to formulate a budget that accounts for your projected pension, retirement accounts, and Social Security. And then stick to it.

When it comes to your retirement planning, prepare yourself to face it head on. Become financially educated so you have the confidence to make sensible decisions. Consult with a professional and make a prudent game plan. There is too much at stake to not take this seriously. All the years you worked and saved depend on the decisions you make as you enter this stage of your life.  Having the financial skills to make wise choices puts you on the road to the financial security you deserve.

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