Retirement Security: Challenges and Prospects for Employees of Small Businesses
Published: 2013-07-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: About 42 million workers, or about onethird of all private-sector employees, work for employers with fewer than 100 employees, and recent federal data suggest many of these workers lack access to work-based retirement benefits. Despite efforts by the federal government to develop new plan designs and to increase tax incentives, plan sponsorship remains low among small employers. MEPs, a type of arrangement involving more than one employer, have been suggested as a potential way to increase coverage.
This testimony describes (1) the challenges small employers face in helping ensure that their workers secure retirement income, and (2) types of MEPs and their potential to address these challenges. GAO drew from its previous reports related to small employer challenges in establishing and maintaining a retirement plan and recent work on MEPs issued from March 2012 through September 2012.
section_title: What GAO Found
paragraphs: About 14 percent of small employers sponsor some type of plan for their employees to save for retirement and these employers in general can face numerous challenges establishing and maintaining a plan. GAO's March 2012 report found that many of the small employers who were contacted said they felt overwhelmed by the number of plan options, plan administration requirements, and fiduciary responsibilities. For example, some small employers found it challenging to select investment funds for their plans. Small employers also cited other challenges in sponsoring a plan, including a lack of financial resources, time, and personnel. GAO's April 2012 review of select 401(k) plans--the most common type of plan sponsored by small employers--found that some smaller plan sponsors did not know about or fully understand fees they and their participants were charged, such as fees associated with group annuity contracts. In addition to these fees, participants in small plans often pay higher recordkeeping and investment management fees than participants in larger plans. GAO's work demonstrates the need for plan sponsors, particularly small sponsors, to understand fees in order to help participants secure adequate retirement savings. Any fees paid by participants, even a seemingly small amount, can significantly reduce retirement savings over time.
Little is known about the types of employers that participate in multiple employer plans (MEP), particularly because, since 2004, no publically available information has been collected on such employers. MEP representatives have suggested MEPs as a viable way for small employers to reduce the administrative and fiduciary responsibilities that come with sponsoring a pension plan, and for reducing costs, in part through asset pooling. However, GAO found that these advantages are not always unique to MEPs. There was also no consensus on the potential for MEPs to increase plan coverage. During GAO's September 2012 study the Department of Labor (Labor) ruled that some MEPs made up of otherwise unrelated employers did not constitute a single pension plan but an arrangement under which each employer sponsored a separate plan for its own employees. Because this raises significant policy and compliance questions and data are limited, it is important that Labor gather information on participating employers to inform policy and oversight activities on retirement security for employees of small businesses.
section_title: What GAO Recommends
paragraphs: GAO is not making any new recommendations. GAO made several recommendations in prior reports to Labor and the Internal Revenue Service (IRS) to address challenges facing small employers and to improve oversight and coordination for MEPs. The agencies generally agreed with GAO's recommendations. However, Labor disagreed with a recommendation to create a single webportal for federal guidance. GAO believes consolidating information could benefit small employers, mainly because resources are scattered.

section_title: Letter
paragraphs: I am pleased to be here today to discuss retirement security for  employees of small businesses. One-third of all private-sector employees,  about 42 million, work for small businesses with fewer than 100  employees and many of these employees lack access to a work-based  plan to save for retirement. In fact, an estimated 51 to 71 percent of  employees of small businesses lack access to such plans. Over the  years, the federal government has taken steps to encourage small  employers to sponsor some type of plan, and legislation has been  enacted that has established incentives such as plan types with fewer  federal reporting requirements, higher plan contribution limits, and a tax  credit for plan startup costs. Despite such efforts, plan sponsorship  remains low among small employers. One proposed option to address  this challenge is the use of pooled arrangements, such as a multiple  employer plan (MEP), a type of arrangement comprised of more than one  employer. GAO recently examined the characteristics of MEPs and the  ongoing challenges that small employers face in establishing and  maintaining a plan for their employees. My statement today describes: (1)  the challenges small employers face in helping ensure that their workers  secure retirement income; and (2) the types of MEPs and their potential  to address small employers’ challenges. This statement is drawn from  prior reports we issued from March 2012 through September 2012   Those reports contain  regarding small employer plans and MEPs.detailed explanations of the methods used to conduct our work. We  conducted all of our work in accordance with generally accepted  government auditing standards.
To encourage employers to provide retirement benefits for their  employees, the federal government provides preferential tax treatment  under the Internal Revenue Code (IRC) for pension plans that meet  certain requirements. In addition, the Employee Retirement Income  Security Act of 1974 (ERISA) sets forth certain protections for  participants in private-sector pension plans and establishes standards of  conduct for those who manage such plans and their assets, generally  called fiduciaries. To the extent they qualify as fiduciaries under the law,  plan sponsors assume certain responsibilities and potential liability under  ERISA. For example, a fiduciary must act prudently and in the sole  interest of the plan’s participants and their beneficiaries. Responsibilities  of plan sponsors and other fiduciaries may include reporting plan  information to the federal government and to participants, selecting and  monitoring investment options the plan will offer, and ensuring that the  services provided to their plans are necessary and that the cost of those  services is reasonable.
Defined benefit plans are plans in which employers generally maintain a fund to provide  a fixed level of monthly retirement income based on a formula specified in the plan.  Defined contribution plans are plans in which retirement income is based on employer and  employee contributions and the performance of investments in individual employee  accounts. tend to have higher contribution limits for employees than employer- sponsored IRA plans. However, DC plans are also subject to more  reporting and other requirements.
A MEP is a type of arrangement involving more than one employer, and  can be structured as either a DB or a DC plan. A MEP is distinct from a  single employer plan that is established and maintained by one employer  for its employees.  MEPs are also distinct from multiemployer plans that  are also maintained by more than one employer, in that MEPs need not  be established by one or more employee organizations pursuant to a  collective bargaining agreement.in a MEP, they legally adopt the plan as their own as participating  employers. A participating employer may sign an agreement that serves  to identify the plan terms that will apply to its employees.
When employers decide to participate  Some MEPs were formed long before the enactment of ERISA in 1974.  Our September 2012 report identified four types of MEPs: association,  corporate, professional employer organization (PEO), and open MEPs.  MEPs maintained by most associations we interviewed included over 100  participating employers and were often organized around a common  trade or industry that served smaller employers. However, the majority of  the largest 25 MEPs are corporate. These sponsors tend to be large  Fortune 500 or Global 500 corporations with few participating  employers.sponsored a traditional DB plan, while the other types generally  sponsored DC plans only.
Of the association and corporate MEPs we interviewed, all  Other types of MEPs appear to have become popular more recently and  are often structured as DC plans. These include MEPs sponsored by  PEOs, which are firms that provide payroll and other human resources  services to clients, and so called “open” MEPs sponsored by firms that do  not purport to employ plan participants. Employers in these “open” MEPs  are related solely by their participation in the plan.
To operate an employer sponsored plan, employers may hire companies  to provide services, such as legal, accounting, trustee/custodial, record  keeping, investment management, investment education, or advice.  These companies, typically referred to as plan service providers, can  assist with administrative functions associated with establishing and  maintaining a plan, including, for example, any required testing, plan  audits, or filing of government reports, chiefly the Form 5500. Service  providers are compensated for their services generally in the form of fees  charged to the plan, which may be passed on to plan participants. Plan  fees, even seemingly small ones, can significantly reduce a participant’s  retirement savings over the course of a career. Service providers charge  an array of fees depending on the type of product and arrangement the  provider may have with other entities that provide plan services. Some  investment fees may be paid by third parties in connection with  investment-related services, also known as revenue sharing,ultimately indirectly paid for by the plan or its participants.
To respond to concerns about the lack of access to employer-sponsored  plans for employees of small businesses, legislation has been enacted to  lower costs, simplify requirements, and ease administrative burdens. For  example, the Revenue Act of 1978 and the Small Business Job  Protection Act of 1996 established the SEP (Simplified Employee  Pension) IRA plan and the SIMPLE IRA plan, respectively, featuring  fewer compliance requirements than other plan types. The Economic  Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) also  included a number of provisions that affected small businesses. For  example, EGTRRA eliminated top-heavy testing requirements for safe  harbor 401(k) plans, increased contribution limits for employer- sponsored IRA plans and 401(k) plans, and created a tax credit for small  employers to offset startup costs, including the cost of educating  employees about a new plan. EGTRRA also created a tax credit for  individuals within certain income limits who make eligible contributions to  retirement plans. The Pension Protection Act of 2006, among other  changes, made these EGTRRA provisions permanent and established  additional provisions that support plan participation by rank-and-file  employees, such as automatic enrollment. Despite these incentives and  legislative efforts, the percentage of the U.S. workforce that participates in  a pension plan remains around 50 percent.
To help encourage plan sponsorship, federal agencies conduct education  and outreach activities, and provide information about retirement plans for  small employers. The Department of Labor (Labor), the Internal Revenue  Service (IRS), and the Small Business Administration (SBA)—which  maintains an extensive network of field offices—have collaborated with  each other and with national and local organizations to develop  information on small employer retirement plans and conduct outreach  with small employers. For example, Labor, IRS, SBA and the U.S.  Chamber of Commerce partnered to create the Choosing a Retirement  Solution Campaign, which targets small employers and their employees.
Labor’s Employee Benefits Security Administration (EBSA) is the primary  agency responsible for protecting private-sector pension plan participants  from the misuse or theft of their pension assets, among other things, and  carries out its responsibilities through such activities as issuing  regulations and conducting investigations of plan fiduciaries and service  providers. EBSA also issues advisory opinions in which it facilitates  compliance with ERISA through interpretative guidance.
subsections: section_title: Small Employers Face Challenges Helping Their Workers Save for Retirement
subsections: section_title: Complex Rules, Resource Constraints, and Financial Instability Contribute to Low Rates of Plan Sponsorship by Small Employers
paragraphs: As we reported in March 2012, retirement plan sponsorship is low  among small employers, which may reflect the challenges employers face  in establishing and maintaining a plan. Our analysis of available Labor  and IRS data found that about 14 percent of small employers sponsored  some type of plan in 2009. As shown in figure 1, the smallest  employers—those with 1 to 4 employees—had the lowest sponsorship  rate at 5 percent but even employers with 26 to 100 employees had a  sponsorship rate of 31 percent. To put this in context, about 50 percent  of the private sector workforce at any one time participates in an  employer-sponsored pension plan. Also, small employers paying average  annual wages of $50,000 to $99,999 had the highest rate of plan  sponsorship at 34 percent while small employers paying average wages  of under $10,000 had the lowest sponsorship rate at 3 percent.
When we met with small employers and other stakeholders, they  identified a variety of factors as challenges to sponsoring retirement plans  or as reasons for terminating existing plans. One commonly cited  concern focused on the multiplicity of plan types and the burden of  paperwork and administration. For example, some small employers and  retirement experts said that the broad range of plan types and features  made it difficult for small employers to compare and choose plans.  Another small employer who previously sponsored a 401(k) plan with a  company match said the amount of required plan paperwork, including  generating annual reports, was a key reason he terminated it.
Other areas of concern for small employers centered on a sponsor’s  fiduciary responsibilities with respect to managing or controlling plan  assets. Specifically, some small employer sponsors found the fiduciary  responsibility of selecting investment fund choices for their plans  particularly challenging. A small employer with a 401(k) plan described  the difficulties of selecting investment options with an appropriate balance  of risk for a workforce that includes both younger and older workers.  Moreover, a number of stakeholders said some small employers may not  have an adequate understanding of their fiduciary duties and are not  always aware of all their legal responsibilities. One service provider  explained that some small employers mistakenly believe that all fiduciary  responsibilities and liabilities are transferred to a service provider when  they are hired. Another expert noted that some small employers have an  exaggerated sense of the possible liabilities that being a fiduciary carries,  and may avoid sponsoring a plan out of fear of being sued by their  employees.
In addition to these challenges, smaller or newer firms may be unwilling  or unable to sponsor plans because they lack sufficient financial  resources, time, and personnel. For instance, smaller employers noted  that startup and ongoing costs involved with maintaining a plan, costs  associated with reporting and testing requirements, administrative fees  paid to an outside party, and any employer requirements to match  employee contributions were barriers to plan sponsorship. Small  employers also expressed the need to reach a certain level of profitability  before they would consider sponsoring a plan and that general economic  uncertainty makes them reluctant to commit to such long-term expenses.
Low employee demand for an employer-sponsored plan may also be a  challenge for small employers. For example, a number of small  employers stated that employees prioritized health care benefits over  retirement benefits. One small employer thought that, given the limited  funds available to contribute towards benefits, his employees would  prefer those resources be applied toward lowering the employees’ share  of health insurance premiums. Small employers emphasized that offering  health care benefits was necessary to attract quality employees.  Additionally, some small employers, such as those who described having  a younger workforce, stated that their employees were less concerned  about saving for retirement and, as a result, were not demanding  retirement benefits. Other small employers told us that employees,  particularly those with low pay, do not have any interest in retirement  benefits because they live paycheck to paycheck and are less likely to  have funds left over to contribute to a plan. For example, one small  employer discontinued his plan when too few of his employees—most of  whom he described as low-wage—participated in the plan. Another small  employer noted that even senior-level managers in his business did not  participate in the plan. However, a retirement expert stated that while  some employees might not be interested in participating in a retirement  plan, he believed the perceived lack of demand to be exaggerated. He  added that he believed some businesses may use lack of employee  demand as an excuse when the small employer was not interested in  sponsoring a plan.
In March 2012, we made a recommendation to Labor to convene an  interagency task force with the Department of the Treasury, IRS, SBA,  and other appropriate agencies to review, analyze, and address the  challenges small employers face in helping ensure retirement security.  The agencies generally agreed with this recommendation, however,  Labor disagreed with one aspect of our recommendation, which was for  the task force to create a single webportal for federal guidance. We  believe consolidating plan information onto one webportal could benefit  small employers, mainly because federal resources are scattered across  different sites. We also made a recommendation to the Department of the  Treasury to collect additional information on IRA plans.
section_title: Participants of Small Employer 401(k) Plans are Likely to Pay Higher Fees
paragraphs: Small employers are more likely to sponsor 401(k) plans and participants  of these plans tend to pay higher fees than larger plans. According to our  analysis of Labor and IRS data, out of slightly more than 712,000 small  employers that sponsored a single type of plan in 2009, about 46 percent  sponsored a 401(k) plan, 40 percent a SIMPLE IRA, and the remaining  employers sponsored other types of plans, including DB and non-401(k)   Experts have identified low contribution rates as a  profit sharing plans.key problem facing workers seeking to secure an adequate retirement  income. In 2011, the average account balance of 401(k) plans with 100 or  fewer participants was about $59,000. This may reflect the challenges  facing participants in small plans of not only contributing faithfully, but  also investing prudently and avoiding high fees.
Regarding fees, plans with fewer than 100 participants account for the  majority of 401(k) plans, and these plans usually pay higher fees.  According to industry experts and research, plans with fewer participants  generally have lower plan assets, and therefore pay higher fees as a  percentage of assets than plans with more assets or older plans that have  grown their assets over time. Service providers and an industry expert we  met with noted that administrative fees to start a 401(k) plan can be  significant for small plans. Additionally, representatives of a retirement  industry organization said that it may be difficult for sponsors of small  plans to negotiate for lower fees because assets in these plans are  modest.
In April 2012, we reported that participants in smaller plans typically pay  higher fees than participants in larger plans. Specifically, our nationally  representative survey of plan sponsors found that participants in plans  with fewer than 50 participants paid an average of 0.43 percent of their  plan assets annually, while participants in larger plans—those with more  than 500 participants—paid 0.22 percent for record keeping and  administrative services. On top of these fees, participants likely paid  other plan fees. For example, according to survey results, in about 69  percent of small plans, participants paid all of the investment fees (see  fig. 2 for additional details), which ranged from less than 0.01 percent to  3.24 percent of assets.
32  disclosure of service providers’ direct and indirect compensation; and before regulations to  disclose certain plan and investment-related information, such as fees, to participants and  their beneficiaries in participant-directed individual accounts were in effect. 29 C.F.R. §§  2550.408b-2 and 2550.404a-5 (2012).
GAO-12-325. This work was conducted before Labor finalized regulations regarding  33 For further details on the design of our 401(k) plan sponsor survey on fees, see   GAO-12-325.
section_title: Little Information Available About Current MEPs and Their Potential to Increase Small Business Sponsorship
paragraphs: As we reported in September 2012, little is known about the employers  that participate in MEPs, or even the number of MEPs by type, in part  because the federal government no longer collects these data. As of  2009, the most recent data available for our September 2012 report,  MEPs represented only a small portion of the pension universe.  Specifically, DB MEPs represented 0.7 percent of all DB plans, about 6.0  percent of all DB assets and 5.0 percent of all DB participants. DC MEPs  represented about the same percentage of all DC plans, assets and  participants. In our September 2012 report, we found smaller employers  in MEPs were mainly participating in association-sponsored MEPs. Two  associations told us their participating employers averaged between 20  and 60 employees. However, one MEP sponsored by a PEO reported  that the typical participating employer in its plan was small as well. In  particular, little data exist on the current number of PEO or open MEP  plan types, their asset size, the number of participants, or the  participating employers. Relative to other MEP types, PEO and open  MEPs are the newest, and may be the only types actively marketing their  MEPs to participating employers.
MEPs have been suggested by PEO and open MEP representatives as a  viable way for small employers to reduce their administrative  responsibility for their pension plans. Several MEP representatives said  MEP administrators can complete the record keeping and the annual  testing, and can submit required filings such as a single Form 5500 for  the MEP on behalf of all the participating employers. Furthermore,  employees can more easily move among employers in the plan. For  example, in a DB MEP sponsored by an association, as long as a  participant remains an employee of an employer within the association,  participants can change employers and continue earning vesting service  credit in the same plan. A small employer sponsoring a single employer  plan can also contract with a service provider to perform administrative  functions, but a couple of interviewees said employers not already  offering plans might find it easier and faster to join a MEP than to create  their own single employer plan. MEPs have also been suggested by  some as a possible means to lower the costs of plan sponsorship, since  participating employers can pool assets to obtain lower pricing available  to larger plans. One expert we spoke with said that certain association  plans have been very effective at offering efficient, cost-effective  retirement options for their members. Furthermore, a couple of  interviewees said MEPs may also reduce costs for employers since they  will not need to spend money to create an initial plan document, as they  would in establishing a new single-employer plan.
As we found in September 2012, another possible benefit of MEPs,  according to some MEP marketing material, is reducing participating  employers’ fiduciary liability since the MEP administrator takes on some  fiduciary duties. However, it is not clear how much relief from fiduciary  liability a MEP can provide to participating employers, and it is not clear  that such relief is unique to MEPs. For example, small employers may  also be able to receive a similar degree of reduced fiduciary liability by  using a service provider to administer the employer’s own plan. Because  small employers may not be familiar with how to manage a plan, reduced  fiduciary liability may be an attractive feature for them, and, in our March  2012 small employer report, small employers identified possible  fiduciary responsibility as a barrier to sponsoring a pension plan.  However, while MEP representatives and MEP marketing materials  sometimes stated otherwise, participating employers retain some  fiduciary responsibility, according to Labor officials. At a minimum,  participating employers must still select a MEP to join and monitor a  plan’s investments and fees, which Labor considers a fiduciary function.
Overall, no consensus existed among MEP representatives and pension  experts on the potential for MEPs to substantially expand coverage.  Large associations can provide the option of joining a MEP to their  members. That option is unavailable to small employers not part of a  membership organization looking out for their interests. The extent to  which small employers can join a MEP may depend on whether a MEP is  actively marketed and sold, since one pension expert observed that small  employers do not extensively research pension plans or actively seek  them out. Additionally, employers who choose to become part of a MEP  for the first time may already have been providing a plan for their  employees. While a couple of the MEP representatives we spoke with  specifically targeted employers without plans, several targeted  businesses with existing plans.
From Labor’s perspective, their primary regulatory concern centers on  one type of MEP, the open MEP. During our review for our September  2012 report, Labor issued an advisory opinion stating that one particular  open MEP did not constitute a pension plan under ERISA because it was  not established or maintained by an employer or an employee  organization. Labor determined that, in the case of this MEP,  participating employers did not constitute a bona fide employer group or  association, sufficient to be considered an employer sponsoring the  arrangement, because, among other things, they did not exercise  sufficient control over the plan. As a consequence of this guidance, the  participating employers in that open MEP were instead determined to  each be the sponsors of their own, individual plans. Association MEP  representatives told us Labor’s guidance had no affect on their plans.
As a practical matter, Labor’s ruling is being treated by many as meaning  that individual participating employers in an open MEP have to comply  with any reporting, auditing, and bonding requirements on an individual  rather than aggregate basis. In our September 2012 report, we noted that  a number of compliance-related questions were left unanswered for open  MEPs. treatment, IRS might still consider an open MEP to be one plan rather  than a series of individual plans. In an effort to remove confusion for plan  sponsors, we recommended Labor and IRS coordinate their  interpretations and develop compliance-related guidance. Labor and IRS  generally agreed with our recommendations on coordination.
Additionally, we noted that, for purposes of preferential tax  Labor’s expectation is that the recently issued opinions on open MEPs  will serve as guidance to the pension industry at large. However, despite  the ruling on open MEPs from Labor, pension experts and MEP  representatives told us that broader policy questions remain. The opinion  did not provide Labor’s view on the potential of open MEPs to lower plan  costs or expand coverage, but we were told by MEP representatives and  pension experts that open MEPs will continue to receive the attention of  policymakers for that reason. At this time no one knows for certain how  many open MEPs there are, who is in them, or how they may affect future  pension coverage. Pension experts cautioned that any legislative change  allowing certain open MEPs should ensure that there are appropriate  safeguards to protect plan participants.
GAO-12-665.
Labor officials said the potential for inadequate employer oversight of a  MEP is greater than for other pension arrangements because employers  pass along so much responsibility to the entity controlling the MEP. Labor  officials noted that potential abuses might include layering fees, misusing  assets, or falsifying benefit statements. One pension expert agreed that  there is potential for MEPs to charge excess fees without the enrolled  employer being aware. While Labor officials acknowledged that single  employer plans could be subject to similar abuses, they cautioned that  the way a MEP is structured and operated could make it particularly  susceptible to abuses.can be important. Representatives of MEPs maintained by associations  we interviewed said they had an appointed board made up of association  members who served as the named fiduciaries of the plan. Most of these  associations required board members to also participate in the MEP.  However, the extent to which open MEPs have or would have such  structures in place is unclear. Given the limited knowledge some plan  sponsors have of the fees they pay and their fiduciary responsibilities, it  would appear that some such governance structure or related safeguards  is warranted to protect employer and participant interests.
For this reason, the structure of a particular MEP  Labor’s lack of data to identify different MEP sponsor types or any  employers participating in MEPs limits the agency’s ability to protect MEP  employers and participants. To ensure Labor has information needed to  oversee MEPs, in September 2012, we recommended that Labor gather  additional information about the employers participating in MEPs,  potentially through the Form 5500, which is the primary source of pension  plan information for government oversight activities. Labor officials said  the number of participating employers or the names of participating  employers could be useful oversight information. The agencies generally  agreed with our recommendation on gathering additional MEP-related  information and said they will consider MEP-related changes to the Form  5500 as part of their regular evaluations. We consider this an important  first step, and await any proposed or scheduled changes to data  collection.
section_title: Concluding Observations
paragraphs: For workers at small employers, building an adequate level of income for  retirement is becoming increasingly challenging. Particularly for small  employers, the low level of plan sponsorship means that many of their  workers may enter retirement with little or no income outside of Social  Security. Small employers also face some greater challenges to  sponsorship than larger employers and they often have less time, fewer  resources and personnel to handle them. The potential advantages of  multiple employer plan design are appealing in this context, however,  current data and information, as well as other safeguards, will be  necessary to ensure that small employer interests are protected and  promises to participants are not broken.
Chairman Harkin, Ranking Member Alexander, and Members of the  Committee, this completes my prepared statement. I would be pleased to  respond to any questions that you may have at this time.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact and Staff Acknowledgments
paragraphs: For  further  information  about  this  testimony,  please  contact  Charles  A.  Jeszeck at (202) 512-7215 or jeszeckc@gao.gov. Contact points for our  Offices  of  Congressional  Relations  and  Public  Affairs  may  be  found  on  the  last  page  of  this  testimony.  Tamara  Cross,  Assistant  Director;   James  Bennett,  Edward  Bodine,  Sarah  Cornetto,  Patrick  diBattista,  Chuck Ford, Gene Kuehneman, David Lehrer, Ted Leslie, Sheila McCoy,  Thomas  A.  Moscovitch,  MaryLynn  Sergent,  Roger  Thomas,  Frank  Todisco,  Kathleen  van  Gelder,  Lacy  Vong,and  Craig Winslow  were  key  contributors to this testimony.
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