ACES POLICY STATEMENT

Financial services of brokers selling mutual funds to employer-sponsored 401k plans and other defined contribution plans subject to ERISA Employee Retirement Income Security Act of 1974, namely, providing investment-related support and information to the plan sponsor and the plan's fiduciaries with respect to their duty to select, monitor and replace funds in the plan's investment menu, providing financial counseling, financial retirement planning services and asset allocation assistance to plan participants, and partnering with the plan sponsor to promote, facilitate and encourage retirement savings to plan participants

Educational services provided to 401k plan sponsors and plan fiduciaries, namely, training with respect to their investment-related and disclosure-related duties under ERISA, and providing educational services, namely, seminars in the field of investments and retirement planning