IOOF Employer Super. Pension. Product Disclosure Statement. Staff Superannuation Plan. Dated: 31 October a sub-plan of IOOF Employer Super

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1 IOOF Employer Super IOOF Employer Super Pension Product Disclosure Statement Dated: 31 October 2014 Staff Superannuation Plan a sub-plan of IOOF Employer Super Prepared by IOOF Investment Management Limited. ABN AFSL No as Trustee of the IOOF Portfolio Service Superannuation Fund ABN

2 IOOF is proud to have been chosen by Bendigo and Adelaide Bank (the Bank) and its associated employers to provide super services to their valued employees. IOOF s relationship with the Bank spans more than 15 years and has gone from strength-to-strength during this time. We created the Bendigo and Adelaide Bank Staff Superannuation Plan (BASSP), a sub-plan of IOOF Employer Super, with tailored features and benefits to help you achieve your financial needs and goals. We look forward to getting to know you as a member of BASSP. If there is anything we can do to help you on your super journey, please call our client services team. About this Product Disclosure Statement This Product Disclosure Statement (PDS) has been prepared and issued by IOOF Investment Management Limited (IIML) ABN , AFS Licence No IIML is the Trustee of the IOOF Portfolio Service Superannuation Fund (Fund), ABN The Bendigo and Adelaide Bank Staff Superannuation Plan ( BASSP or the Plan ), a sub-plan of IOOF Employer Super is a Division of the Fund. The Plan offers an account-based pension (Pension) product in the Fund. About the Trustee Staff Superannuation Plan a sub-plan of IOOF Employer Super IIML is a part of the IOOF group comprising IOOF Holdings Limited ABN and its related bodies corporate (IOOF group). As Trustee, IIML is responsible for operating the Fund honestly and in the best interests of members. IIML is also responsible for holding the assets of the Fund on behalf of members and undertakes all of the administrative tasks through IOOF Service Co Pty Ltd ABN IIML has investment and service contracts with related parties within the IOOF group, including Perennial Investment Partners Limited (Perennial), ABN , AFS Licence No and IOOF Service Co Pty Ltd. IIML is solely responsible for the content of this PDS. This PDS was prepared by IIML based on its interpretation of the relevant legislation as at the date of issue. Contributions made to, and investments in, the Plan do not represent assets or liabilities of IIML (other than as Trustee of the Fund) or any other company or business within the IOOF group. The terms our, we, us and Trustee in this PDS refer to IIML. Neither IIML, nor any other related or associated company, the fund managers providing the self-selected managed funds, service providers or the related bodies corporate of the parties mentioned, guarantee the repayment of capital or the performance or any rate of return of the investment options chosen in the Plan. Investments made into the investment options are subject to investment risks and other risks. This could involve delays in the repayment of principal and loss of income or principal invested. IIML operates IOOF Employer Super on the terms and conditions outlined in this PDS and in accordance with the Fund s Trust Deed. We may change any of the terms and conditions set out in the PDS at any time where permitted to do so under the Trust Deed and superannuation (super) law. IIML is the responsible entity of the IOOF Balanced Investor Trust, the IOOF Cash Management Trust, the Perennial Trusts, the IOOF MultiMix Trusts and the IOOF Multi Series Balanced Trust (the Trusts), and we receive fees under the Constitutions of the Trusts. These are some of the investment options offered in the Plan (as listed in the Bendigo and Adelaide Bank Staff Superannuation Plan s investment guide (SSB.11)). This product is only available to persons receiving this PDS (electronically or otherwise) within Australia. We may refuse an application to join the Fund without providing reasons for the refusal. You become a member of the Plan when we accept your completed application and record you as a member. IIML may from time to time hold some of the Fund s investments in custody. The BASSP Pension is further limited to: current employees, retired officers and their immediate family members ex-employees and their immediate family members dependants of a member of BASSP Employer, Personal or Pension Divisions who become entitled to receive a pension as a result of the death of that member. About the relationship between Perennial and IIML Perennial, another company within the IOOF group, has been appointed by us to manage the investment assets of the Perennial Trusts. Perennial is paid arm s length asset management fees by us (as the Responsible Entity) for the management of the Perennial Trusts. Who is the IOOF group? For over 160 years, we have been helping Australians, and more recently New Zealanders, secure their financial future. In that time, we ve grown to become a leading provider of financial services and a trusted partner for financial advisers and their clients. Our products and services are designed to accompany Australians from the wealth accumulation phase into retirement and across to the next generation. Investment options offered IIML makes no recommendation regarding the investment options set out in SSB.11. As Trustee, IIML regularly monitors the investment options available to members and provides no assurance that any investment option currently available will continue to be available in the future. We have the right to suspend or cease investments in a specific investment option and if necessary, can redeem and transfer your investments to a similar investment option or your Cash Account in circumstances where the investment option is no longer available and no alternative instructions are provided. We will notify you of any such change where possible before the change occurs. The fund managers have not authorised or caused the issue of this PDS but have consented to the inclusion of statements which relate to their particular self-selected managed fund. In order to choose an investment option for your investment strategy, you should review the information in SSB.11. Before selecting an investment option your financial adviser should provide you with the product disclosure statement for the relevant managed investment or the product guide for the term deposit. These documents provide you with important information to consider and evaluate prior to investing. Product disclosure statements and product guides are also available on our website ( Please note, product disclosure statements and product guides are not available for listed investment options. General advice warning The information contained in this PDS is of a general nature only and does not take into account your individual objectives, financial situation or needs. You should consider the appropriateness of this information having regard to your objectives, financial situation and needs and you may want to seek advice from a financial adviser before making a decision about BASSP. Updated information The information referred to in this PDS may change from time to time. We will inform you of any significant changes that could affect you, or other significant events which may affect the information in this PDS. Any updated information that is not materially adverse may be obtained by: checking our website ( ing us at staff.super@bendigobank.com.au calling us on between 8:00am and 6:00pm Monday to Friday. A paper copy of the updated information will be provided free of charge on request.

3 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS What is inside? Introducing the Bendigo and Adelaide Bank Staff Superannuation Plan 2 Why invest in the Plan? 2 A snapshot 3 How does your pension account work? 5 Your initial contribution 5 Investing your initial contribution into your pension account 5 What are conditions of release and how do they affect the commencement of your pension? 6 Dependants paying benefits if you die 7 Making investment choices 7 Managing your pension account 9 Using Bendigo and Adelaide Bank Staff Super Online 9 Your investment instructions 9 Changing your investment options (switching) 10 Your Cash Account 10 Pension options explained 12 How is the minimum annual pension calculated? 12 Selecting your annual pension payments 12 Frequency of pension payments 13 What is the transition to retirement pension option? 13 Can a lump sum withdrawal be made? 14 Fees and other costs 15 Additional explanation of fees and costs 17 What are the risks? 20 What taxes apply and how do they work? 21 Contributions to commence your pension 21 Tax on pension payments and lump sum withdrawals 21 Tax on benefits paid as a result of death 22 Tax file numbers 22 Centrelink/Department of Veterans Affairs information 22 General information 23 Cooling-off period 23 Your instructions and communications 23 Keeping track of your investments 24 Electronic communications 25 Appointment of representative 25 What if you have a complaint? 25 Your privacy 26 Anti Money Laundering (AML) and Counter Terrorism Financing (CTF) legislation 26 How to apply? 27 Application procedure 27 How to find your way around this PDS This PDS is important because it will help you decide whether the Bendigo and Adelaide Bank Staff Superannuation Plan will meet your needs. You can use it to compare this pension product with any other pension product you may be considering. This PDS describes the key features, risks and purpose of the Plan. It also contains some information we are required to include by law. You will see the PDS refers to the Bendigo and Adelaide Bank Staff Superannuation Plan general reference guide (SSB.13) and the Bendigo and Adelaide Bank Staff Superannuation Plan investment guide (SSB.11) these contain statements and information we are required by law to disclose to you. The contents of the guides are classified by a unique identifier and a description of what is covered. You can then use this description to decide whether to read the information. By law the statements and information in these guides are taken to be included in the PDS. This PDS and the guides can be downloaded from our website ( or you can contact us and we will send you a paper copy at no charge. Key words There may be words in this PDS and the guides you may not be familiar with. To help you understand these terms, we have defined them in the Key words explained section of SSB.13. 1

4 Introducing the Bendigo and Adelaide Bank Staff Superannuation Plan Why invest in the Plan? The Plan offers a range of super products designed to support the financial goals of Australians at every stage of life. You can select from a large range of investment options including listed investments and term deposits or choose to let us do it all for you. You can select your investment strategy using one convenient administration facility. This includes having access to: an all-in-one lifetime portable super solution with an Employer Division (for current employees), a Personal Division (for retired officers, ex-employees and immediate family members) and a Pension Division (for retirees and pre-retirees) an extensive investment choice (ready-made portfolios and self-selected managed funds, as well as listed investments and term deposits). Our ready-made portfolios are multimanager trusts providing blended exposure to Australian and international fund managers across multiple asset sectors secure online access to your account details with the ability to switch your investments and adjust your investment strategy consolidated reporting. Divisions The Plan has three divisions as follows: Employer and Personal Divisions offer a portable, super plan suitable for: Choice of Fund compulsory employer contributions government super co-contributions personal and spouse contributions rollovers. Once you reach your preservation age, you can convert your accumulated super in the Employer and Personal Divisions into an income stream in the Pension Division. Pension Division offering an account-based pension with a transition to retirement (TTR) pension option. An account-based pension is required to make a minimum payment at least annually (maximum payments only apply to transition to retirement pensions). This makes it very simple for you to manage your retirement goals. The value of the investment options you hold forms part of your pension account. You do not directly invest into (or hold an interest in) any investment option. This means investing in the Plan is not the same as personally investing in managed investments, listed investments or term deposits. 2

5 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS A snapshot The following table provides a snapshot of the key features and benefits. Investing Investment options Investment strategy Cash Account Investment income Features Bendigo and Adelaide Bank Staff Super Online Super consolidation service Movement between the Employer, Personal and Pension Divisions Transition to retirement (TTR) pension option Estate planning Pension payment options Ready-made portfolios a range of IOOF multi-manager trusts. Self-selected managed funds a range of sector or asset class specific managed funds including specialist, regional and diversified funds. Listed investments access to the full constituent list of the S&P/ASX 300 index (plus any other securities approved from time to time by the Trustee). Term deposits a range of term deposits. When you apply for membership of the Plan you are required to make an investment choice as part of your application. If you have not made a decision about your future investment strategy, you can choose to invest in the Cash Account until you make another investment choice. The Cash Account records all transactions and aims to generate a competitive investment return on the part of your member account that is required to be held in cash. Investment income varies in accordance with the particular investment option. Income will normally be credited to your Cash Account for investment in accordance with your investment strategy. View your account details and adjust your investment strategy online, normally 24 hours a day, seven days a week with secure access to your account over the internet. We can help you transfer your super balances into one account which may reduce fees. The value of your account will not be reduced by the impact of buy-sell spreads if you maintain your investment options when transferring between the three divisions. A capital gains tax event will not arise if you transfer the same investments between the three divisions. You can use the transition to retirement pension option to commence a pension once you have reached your preservation age, regardless of your employment status. Choose from the following estate planning options: Reversionary Pensioner. Binding Death Benefit Nomination. Non-Binding Death Benefit Nomination. Under the Reversionary Pensioner option, we are bound to pay your remaining account balance as a continuing pension to your nominated Death Benefits Dependant after your death. However, the Reversionary Pensioner may choose to make a lump sum withdrawal rather than continue to receive pension payments. Under the Binding Death Benefit Nomination and Non-Binding Death Benefit Nomination options, we retain the flexibility to pay your benefit as a lump sum or pension. You can choose to receive your pension payments: monthly quarterly half-yearly annually. All pensions are reviewed annually on 1 July. We withhold any PAYG tax liability on gross pension payments, as required by law. Page Page

6 Minimum amounts Page Initial contribution $30,000 per pension account. 5 Investment options and switching instruction 1 Ready-made portfolios and self-selected managed funds no minimum applies. Listed investments a minimum parcel of $3,000 is required per share trade. Term deposits $20,000 per term deposit. 10 Cash Account Initial balance 1.5% Minimum ongoing balance 0.5% Maximum ongoing balance 2.5% 10 Pension income Your annual pension payments are subject to a minimum level set by the Commonwealth Government. Annual pension payments made under a transition to retirement pension option 2 are also subject to a maximum level set by the Commonwealth Government. 12 Lump sum withdrawals 2 No minimum applies. 14 Fees Exit Fee Administration Fee Nil for the first partial lump sum withdrawal per financial year other than your regular pension. Thereafter, $ will be charged per additional withdrawal. Current employees, retired officers and their immediate family members 0.20% of account balance. Ex-employees and their immediate family members Account balance Cash Account % pa All other investments % pa First $250, Next $250, Amounts above $500, Page Member Fee Current employees, retired officers and their immediate family members $0.89 per week. Ex-employees and their immediate family members $0.77 per week. 16 Indirect Cost Ratio This is the cost charged separately by the fund manager of each managed investment. 17 Switching Fees 3 Performance fees Member advice fees Managed investments nil. Listed investments brokerage charges apply. Term deposits nil. We do not charge any performance fees for this product. A fund manager may charge a performance fee for a particular managed investment. You and the financial adviser selected by you have the flexibility to nominate an amount (if any), within limits that are set by us. If you do not have a financial adviser, these fees are not charged Additional fees may apply to your pension account. For full details of the fees and costs associated with your account please see pages 15 to The maximum overall combined investment weighting that you can hold in illiquid investments, listed investments and term deposits is 80 per cent. 2 Commonwealth Government regulations impose restrictions on when you can make lump sum (cash) withdrawals where you have selected the TTR pension option. 3 When you move money in or out of a managed investment (including when you make a switch), you may incur a buy-sell spread which is included in the unit price of the investment option you choose (see Transaction costs on page 18 for details).

7 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS How does your pension account work? Commencing an account-based pension is easy. As long as you have met a condition of release such as retiring after reaching your preservation age or turning age 65, you can make an initial contribution and start receiving your pension straight away. Your initial contribution can include the transfer of benefits from the Employer or Personal Divisions to the Pension Division. You must be a member of the Bendigo and Adelaide Bank Staff Superannuation Plan to commence an account-based pension. If you have reached your preservation age but you have not retired, you can commence an account-based pension using the transition to retirement (TTR) pension option but the amount of cash you can withdraw will be limited until you retire or reach age 65. The access rules are set out on page 13. Your initial contribution You can commence your pension by transferring from your current Bendigo and Adelaide Bank Staff Superannuation Plan Employer or Personal Division account or from another super fund. You or your spouse can also make a contribution to commence your pension account. The minimum contribution (including any transfers) required to establish a pension account is $30,000 per account. You will need to complete an Application form located in the Bendigo and Adelaide Bank Staff Superannuation Plan Pension forms booklet (Forms booklet). If you are making the contribution by cheque, the cheque should be made payable to: IPS BASSP [your full name or member number] Please forward your cheque or money order with your Application form to Bendigo and Adelaide Bank Staff Super. If you are transferring your super benefits from another super fund, please complete the Request to Transfer form located in the Forms booklet. If you are transferring your benefit from another member account within the Fund, please indicate the transfer amount on the Application form. Please note, no additional contributions or transfers can be made to an existing pension account once your pension has commenced. If additional amounts are received after pension commencement, a separate pension account that meets the minimum amount of $30,000 must be established. Please note, if you wish to make additional contributions or transfers to a TTR pension that you have started, a $10,000 minimum applies. Investing your initial contribution into your pension account For new members, your initial contribution is credited first to your Cash Account. This contribution (less any nominated Member Advice Fee Upfront 4 and applicable taxes) will be invested in accordance with your investment instructions on your Application form. You may need to retain part of your contributions in your Cash Account to satisfy the minimum holding requirements. Information on how your Cash Account balance is invested is contained on page 10. For existing members, transferring from the Employer or Personal Divisions to the Pension Division is simple. You can maintain your existing investment strategy if your current investment options are available in the Pension Division. The value of your account will not be reduced by the impact of buy-sell spreads if you maintain your investment options, nor will it create a capital gains tax event. You are required to make an investment choice as part of your application. If you have not made a decision about your future investment strategy, you can choose to invest in the Cash Account until you make another investment choice. You may also request your existing investment options be aligned (or re-weighted ) to your new investment strategy. What can the initial contribution be made up of? We can accept a wide range of contributions to commence your pension. These are: personal contributions, you make yourself which are not tax deductible spouse contributions made by your spouse (legal or de facto) for your benefit transfer of super or pension benefits from other super funds, ADFs or superannuation annuities transfers from other super or pension accounts within the Fund. If you commence a pension with other types of contributions (for example if you are self-employed and want to make tax deductible personal contributions), you will need to make this contribution to an accumulation super account (such as an account in the Employer or Personal Divisions), accompanied by the ATO approved form Notice of intent to claim or vary a deduction for personal super contributions. Once this has been processed, you can then transfer your benefits to start a pension. 4 For more information regarding the member advice fees available, refer to page 18 of this PDS. 5

8 Are there restrictions on when particular contributions can be made to commence the pension? The table below shows when contributions can be made to commence a pension. For information on preservation age and conditions of release, see page below. Your age Under age 55 Age 55 to 64 Age 65 to 74 Age 75 or more Contributions we can accept to commence your pension If you have met a condition of release, such as permanent incapacity: Transfers from other super or pension accounts in the Fund and other super funds. Personal and spouse contributions. OR where you have not met a condition of release: Transfers from other super or pension accounts within the Fund and other super funds which are wholly unrestricted non-preserved benefits. If you have met a condition of release such as retirement after preservation age: Transfers from other super or pension accounts in the Fund and from other super funds. Personal and spouse contributions. If you have not met a condition of release, you can only commence a pension using the TTR pension option. Transfers from other super or pension accounts in the Fund and from other super funds. Personal contributions if you have met the work test 5. Spouse contributions cannot be accepted once you turn age 70. Transfers from other super or pension accounts in the Fund and from other super funds. Are there any limits on the amount of personal and spouse contributions that can be made to commence the pension? A maximum of $540,000 applies to personal and spouse contributions that you can make to commence your pension. If you are aged 65 or more, the maximum is $180,000. Any personal or spouse contributions over this amount will be refunded. Personal and spouse contributions used to purchase your pension (including the TTR pension option) are called non-concessional contributions. The Commonwealth Government sets an annual cap on the amount of non-concessional contributions that can be made to your super each year before additional tax is payable. For the caps on these contributions and the tax payable if you breach the caps see the How super is taxed section in the Bendigo and Adelaide Bank Staff Superannuation Plan general reference guide (SSB.13). What are conditions of release and how do they affect the commencement of your pension? Super funds can only release benefits, such as commencing a pension or paying a cash lump sum, in certain circumstances. Benefits in super are preserved 6 until you meet a condition of release. Once you have met a condition of release, your super benefits become unrestricted non-preserved and you can commence an account-based pension. The main conditions of release are: permanently retiring after reaching your preservation age (see below) leaving employment after reaching age 60 reaching age 65 permanent incapacity. Once you have reached your preservation age but have not retired, you can access your preserved benefits by commencing an account-based Pension using the TTR pension option. Preservation age Preservation age is currently age 55. However, if you were born on or after 1 July 1960, you will have a higher preservation age as follows: Date of birth Preservation age Before 1 July July June July June July June July June From 1 July Before the contribution is made, you must have worked at least 40 hours in 30 consecutive days in the financial year in which the contribution is made. A personal contribution must be received within 28 days after the end of the month in which you turn age Benefits that are preserved also include restricted non-preserved benefits. However, restricted non-preserved benefits have an additional condition of release which is termination of employment with an employer who has contributed to the super fund.

9 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Dependants paying benefits if you die If you die while you are a member, super law requires we pay your Death Benefit (the remaining balance of your pension account) to one or more of your dependants and/or your estate. To provide greater certainty as to who will receive your benefit in the event of your death there are three estate planning options (only one option can be selected): Reversionary Pensioner option. Binding Death Benefit Nomination (Binding Nomination). Non-Binding Death Benefit Nomination (Non-Binding Nomination). The most appropriate nomination will depend on your personal circumstances. Any person you nominate must be a dependant as defined by super law or your Legal Personal Representative. Dependants include your spouse, de facto spouse, same-sex partner and children. If you choose to make a Binding Nomination or Non-Binding Nomination, you can nominate one or more people and allocate a percentage of your benefit between them in any proportion. A short description of how each form of nomination works follows: Reversionary Pensioner option If you nominate a Reversionary Pensioner, in the event of your death, we must continue to pay the remaining balance of your pension account (if any) to your nominated Reversionary Pensioner. The pension will automatically continue to be paid until the account balance is exhausted. The nomination of a Reversionary Pensioner must be made before your pension commences and the nomination cannot be changed once your pension has commenced. If the nominated Reversionary Pensioner can no longer receive a Death Benefit (for example if your nominee dies before you), you cannot nominate a new Reversionary Pensioner. However, you can make a Binding Nomination or a Non-Binding Nomination in favour of another dependant(s). Not all dependants can be nominated as a Reversionary Pensioner. See the Death Benefit Nominations section in SSB.13 for further details. Non-Binding Nominations Your nomination is not binding on us but we will take it into account when we determine to whom to pay your benefit. You can amend your Non-Binding Nomination at any time by sending us a new Non-Binding Nomination. No nomination If you do not nominate a Reversionary Pensioner or make a Binding Nomination or Non-Binding Nomination, we must pay your Death Benefit to your Legal Personal Representative, unless your estate is insolvent. As there may be taxation and other implications to consider, we recommend you seek professional advice before making your nomination. Important note Unless you have nominated a reversionary pensioner, when we receive evidence of your death, we have discretion to sell your investment options and put your money into the IOOF Cash Management Trust until the Death Benefit is paid. We would normally exercise this discretion unless advised otherwise. See the Death benefit nominations section of SSB.13 for further information about dependant nominations and the available payment options. Making investment choices Your investment strategy The Plan provides access to a range of managed investments, listed investments and term deposits. With so many investment options, you can construct a portfolio to help achieve your retirement goals. Your investment strategy should be a reflection of your attitude to investing, the level of risk you are comfortable accepting and your investment timeframe. Binding Nominations If you have a valid Binding Nomination in effect at the date of your death, we must pay your benefit to the dependant(s) and/or Legal Personal Representative you have nominated in the proportions that you have set out in your nomination. A valid Binding Nomination remains in effect for three years from the date it was first signed, last amended or confirmed. You can amend your Binding Nomination at any time by sending us a new Binding Nomination. 7

10 What investment options can you choose? You may choose from a range of investment options within the following sections. Section Ready-made portfolios Self-selected managed funds Description Offers you access to a spread of different asset classes designed to meet particular investment objectives. IOOF s range of diversified and single sector multi-manager trusts simplifies the investment selection process by blending some of the best available managers to suit your investment objectives. This is where you and your financial adviser can tailor the investments to suit your investment strategy. Self-selected managed funds comprise a wide range of managed investments across different asset classes to meet particular investment objectives. Listed investments The full constituent list of the S&P/ASX 300 index (plus any other securities approved from time to time by the Trustee). Term deposits Managed investments A range of term deposits. The managed investment options available vary in risk, investment objectives (goals), strategies (ways of achieving those goals) and the types of assets in which investments are made. This allows you to invest in a range of managed investments, which may be diversified across different asset classes, fund managers and investment styles. You can normally switch between different managed investments at any time. We carefully research leading Australian and international fund managers before developing ready-made portfolios or choosing self-selected managed funds to be part of the investment menu. We also monitor and review the fund managers and managed investments on an ongoing basis and may add or remove managed investments from time to time. Where we have suspended or stopped investments in an investment option or where an investment option is redeemed in full, income distributions received from that investment option will be retained in your Cash Account. The list of managed investment options is set out in SSB.11. The list may change from time to time. You can obtain the most current list of investment options from our website ( or request a copy free of charge by calling our client services team on Listed investments You have the option to invest in various listed investments through your pension account. The Plan provides you with access to the full constituent list of the S&P/ASX 300 index plus other listed securities approved by the Trustee from time to time. You can view the current list on our website. This list may change from time to time. Information on how you can invest in listed investments is set out in SSB.11. Term deposits Terms and conditions relating to an investment in a term deposit are contained in the relevant term deposit product disclosure statement or product guide and the Investing in a term deposit section in SSB.11. Important note More information about each investment option is detailed in SSB.11, the product disclosure statement issued by the fund manager for the particular managed investment and the product disclosure statement or product guide for the particular term deposit. The information relating to investments in SSB.11 may change between the time you read the PDS and the day the Application form is signed. The most recent updates appear on our website. Product disclosure statements include information about performance, asset allocation, costs and the risks associated with investing in a particular managed investment and must be read and considered before selecting a managed investment. Before investing, you should consider the product disclosure statement for the managed investment(s) and the product disclosure statement or product guide for any term deposit(s) you have selected. You can obtain a copy free of charge by requesting it from our client services team or directly from our website ( It is recommended you consider consulting a financial adviser prior to selecting the investment options that you would like to invest in. Please note, listed investments do not have product disclosure statements. The maximum overall combined investment weighting that you can hold in illiquid investments, listed investments and term deposits is 80 per cent of your account balance. Default investment strategy Unlike the Employer Division, the Pension Division does not have a default investment strategy. When you apply for a pension in the Plan, you must nominate an investment strategy, which may include the Employer Division MySuper default strategy. 8

11 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Managing your pension account This section provides you with instructions about how to select and maintain your investment strategy and manage the operation of your Cash Account Using Bendigo and Adelaide Bank Staff Super Online Functions available online Managing your pension online is convenient and easy. With a comprehensive range of online tools, you can choose how much or little you view or manage your super online. If you are interested in managing where your pension is invested, there are transaction options available which can help. By using your online access, you can view your: account balance transaction history investments held death benefit nomination investment strategy portfolio reporting, including account return information across any period and detailed transaction listing. Using your online access you can also: update personal details buy and sell listed investments buy and sell managed investments switch your investments adjust your investment strategy elect to receive and view the Trustee s communications electronically. How to register for online access You can register for online access once you have received your member number. Simply apply online at com.au and you can create your own password. Your investment instructions Your investment instructions outline how you would like us to: allocate your contribution across the various investment options top up or sell down your Cash Account to meet the ongoing balance requirements redeem from your investments to fund your pension payments process a withdrawal request by telling us which investment options we should redeem from. You can provide your initial investment instructions on the Application form contained in the Forms booklet. Please note, illiquid managed investments, listed investments and term deposits cannot form part of your ongoing investment strategy. To confirm your allocation to each managed investment, you can view your current investment strategy via Bendigo and Adelaide Bank Staff Super Online or you can call our client services team on You can also provide us with a specific instruction concerning a particular initial contribution that differs from your ongoing investment strategy by making this clear on an Additional Lump Sum Contribution form for that particular contribution. This form is available from our website ( You are required to make an investment choice as part of your application. If you have not made a decision about your future investment strategy, you can choose to invest in the Cash Account until you make another investment choice. Please note, we may need to retain all or part of any contribution in your Cash Account to satisfy the ongoing holding requirement. Withdrawals If you make a lump sum withdrawal, you can indicate the investments to be redeemed on the payment form. If you do not provide specific instructions, we will draw from the investments according to, and in the same proportions as, your investment strategy. If the balance in these investments is insufficient to cover the amount requested, other investment options within your portfolio will be used. Investment income Investment income varies in accordance with the particular investment option you are invested in. Where income is not reinvested it will be credited to your Cash Account for investment in accordance with your investment strategy. Changing your investment instructions You can update your investment instructions using Bendigo and Adelaide Bank Staff Super Online or by completing a Switching Instructions form available from our website. We may need to amend your investment strategy on your behalf where we have suspended or stopped investments in a managed investment or where a managed investment is redeemed in full. In that case, the investment option will be removed from your investment strategy and your instructions will be re-weighted. Whenever you request a change to your investment strategy we will confirm to you when the change has taken place. 9

12 For example Maria submits a request to fully redeem her investments in investment options Y and Z. As a result, Maria s investment strategy is automatically updated to remove investment in those options and to re-weight the remaining investment options. Investment option Existing holding % Redemption request % Investment strategy before % Investment strategy after % Option W Option X Option Y Option Z If you choose a single managed investment as your investment strategy for redemption requests, and that investment option has an insufficient balance to fund the request, other investment options within your portfolio will be used. Changing your investment options (switching) The Plan gives you the ability to change your selected investment options. This usually involves redeeming units from one or more of your existing investment options and purchasing units in one or more investment options selected by you. Importantly, you must complete a redemption transaction before you can purchase units in a new investment option. This process is often referred to as a switching instruction. You can switch your managed investments using Bendigo and Adelaide Bank Staff Super Online, by completing a Switching Instructions form available from our website ( or by calling our client services team on Product disclosure statements for managed investments may be updated or replaced by the fund manager from time to time. Similarly, we may update SSB.11 from time to time. This means you may not always have the most recent information regarding an investment option before making your switch request. We provide electronic versions of these disclosure documents on our website. You can also obtain a copy free of charge by contacting a financial adviser or by calling our client services team. Important note A buy-sell spread may be incurred when switching between managed investments. See Transaction costs on page 18 and the Performance Report of Underlying Funds on our website for details. Listed investments Brokerage applies to any listed investment trades (buy or sell). See Transaction costs on page 18 for more information. See the Investing in listed investments section in SSB.11 for more information. Your Cash Account 7 Why do you have a Cash Account? Your Cash Account is used to process all cash transactions that occur within your pension account. For example, all money paid into your account and any earnings from investment options go through your Cash Account; and all fees, withdrawals, pension payments and taxes are paid out of this account. Competitive investment returns from your Cash Account The Cash Account provides you with exposure to a mix of Australian short-term money market securities and cash. Interest generated by these investments (less bank fees and charges) is calculated daily and credited monthly to your Cash Account. The Cash Account provides competitive returns when compared to cash funds. If your Cash Account goes into a negative balance, a fee will be charged for the period that your account has a negative balance. The fee equates to interest charged at the daily rate applicable for the Cash Account, for the period that your Cash Account has a negative balance. Transactions including switches, partial withdrawals and other payments (including fees) may result in a negative balance Please note that on some of the communications you receive from us your Cash Account may be referred to as Cash at bank.

13 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Minimum Cash Account requirement Your Cash Account must begin with a balance of 1.5 per cent of your pension account balance. If your Cash Account balance falls below 0.5 per cent of your pension account balance, we will restore the balance to 1.5 per cent by redeeming your investments in the proportions according to your investment strategy. If your Cash Account balance exceeds 2.5 per cent of your pension account balance, we will invest the excess in the proportions according to your investment strategy to restore the balance to 1.5 per cent. Cash Account (sub-account of pension account) Initial balance 1.5% Minimum ongoing balance 0.5% Maximum ongoing balance 2.5% Ongoing balance We will normally review the ongoing balance of your Cash Account at least twice each week. Please note, illiquid managed investments, listed investments and term deposits cannot form part of your ongoing investment strategy and are therefore excluded from the sell down and top up process. Please note that if there are not sufficient assets available from your elected investment strategy your cash levels will be restored at our discretion. Flexibility We have the discretion to alter your Cash Account balance to suit your circumstances subject to a recommended minimum balance of 0.5 per cent and a maximum balance of 99.9 per cent. 11

14 Pension options explained The Plan s pension is an easily understood and very flexible retirement product. It provides an account-based pension with a TTR pension option, increasing your financial planning alternatives as you near retirement. How is the minimum annual pension calculated? The Commonwealth Government has set a minimum annual payment that you must withdraw from your pension account each financial year based on your age. The minimum is a percentage of your account balance and is measured at commencement and on 1 July each year. You are able to select any amount of pension payments above this minimum that you require. If you select Minimum in the Pension amount section of the Application form, the minimum level of payments as per the following table will apply to your pension for the remainder of the financial year unless you notify us otherwise when submitting your application. Age Minimum annual payment % 55 64* * This minimum also applies to payments made under the TTR pension option. For Reversionary Pensioners, the minimum applying to the original pension applies for the remainder of the financial year. On 1 July, following the death of the original pensioner, the minimum pension will be calculated using the Reversionary Pensioner s age. The percentage factor is determined by the age of the account holder on 1 July of a financial year or the date of commencement of the pension in that year as shown in the table directly above. Selecting your annual pension payments You can nominate your annual pension payment to be either: your age-based minimum annual payment, in the table, rounded to the nearest $10 a fixed dollar amount. If you have nominated a fixed dollar amount, you can also elect to automatically index your pension by the consumer price index (CPI) or a fixed percentage each year, provided the pension meets the Commonwealth Government s regulated pension payment limits. If your needs change, you can increase or decrease your selected pension payments at any time provided they meet the minimum annual pension payment. You can request a change to your selected pension payments at any time in writing. However, any lump sum withdrawal requests will not be treated as a change to your pension payments unless you specify otherwise. For Reversionary Pensioners, the current pension payments will continue in your name, however you can choose to change the current pension selection (subject to meeting the Government minimum). Depending on your selection, your annual pension payment will change over time. Please consult a financial adviser about how to select your required annual pension payment. Important note Your first year s pension payment amount will be reduced in proportion to the number of days between the date your pension account was established and the following 1 July, unless you request otherwise. Example age-based minimum payment as a percentage of your account balance Diana (age 60) invests $200,000 in a pension to commence on 1 July She nominates her pension level to be her age-based minimum annual payment as a percentage of her account balance, which (as per the table on this page) is four per cent. Consequently, her annual pension payment is $8,000. On 1 July 2015 we will assume Diana s pension account balance is $204,000, after allowing for her pension payments, account fees and growth in the value of her investments 8. As she has not elected to change her level of pension, based on her age-based minimum payment percentage of four per cent, her new annual pension will be $8,160 (four per cent of $204,000). Where you nominate a fixed dollar amount, which does not meet your age-based minimum annual payment, your pension will be adjusted upwards to meet the minimum Depending on your investment selection, nominated level of pension payments and the amount of any lump sum withdrawals, your pension account balance may rise or fall. This example is for illustrative purposes only and does not in any way indicate an expected level of performance.

15 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Example fixed dollar nomination Graeme (age 64) invests $200,000 in a pension to commence on 1 July He nominates a fixed dollar annual pension payment of $20,000, to be indexed by five per cent per annum. This figure exceeds Graeme s age-based minimum payment percentage of four per cent required to be paid for the financial year (as per the table on page 12). Graeme receives an annual pension of $20,000 during the first year of his pension. On 1 July 2015, Graeme s annual pension payment is automatically indexed to $21,000 ($20,000 plus five per cent of $20,000). This increase occurs irrespective of changes in Graeme s account balance, provided this revised annual pension payment exceeds Graeme s age-based minimum payment. Frequency of pension payments You may elect to receive your annual pension payment as one annual payment or in installments based on one of the following frequencies: monthly quarterly half-yearly annually. Irrespective of the frequency you select, where necessary, we will withhold any PAYG tax liability on the gross pension payment for that frequency as required by law. For more information, see What taxes apply and how do they work? on pages of this PDS. We will deduct the required pension payments from your Cash Account and credit them electronically to your nominated account with a financial institution. Payments are made by the 7th day of the month where a pension payment is due. What is the transition to retirement pension option? Can someone receive a pension while still working? When you reach your preservation age (see page 6), you can acquire an income stream under the transition to retirement (TTR) pension option without having to permanently retire, change employment or reach age 65. This means you can continue working while receiving an annual pension. There is no cap on the amount of benefit you can transfer from your super fund in order to commence a pension using the TTR pension option. You can commence your TTR pension with preserved benefits, restricted non-preserved benefits and unrestricted non-preserved benefits. To commence a TTR pension, you may simply roll over some or all of your super benefits to a pension in the Plan. The minimum investment is $30,000. If you decide to add to an existing TTR pension, a minimum of $10,000 applies. To add to an existing TTR pension, the new contribution is added to the current pension account balance, to commence a new TTR pension. Advantages and restrictions of the TTR pension option An advantage of using an account-based pension for TTR purposes is that the investment strategy you choose for your personal super account can normally be transferred directly into your pension account in the Plan without being redeemed and without having to incur any capital gains tax liability. On transfer, you can either retain your existing investment strategy or provide us with new investment instructions to change your investment strategy. If you choose to transfer only part of your benefit from your personal super account in the Plan to a pension, a minimum balance of at least $1,000 must remain in your personal super account to allow for further contributions to be made and to meet the cost of fees and any insurance premiums. Where higher fees and insurance premiums are required to be paid in respect of your personal super, the minimum balance may be higher. A TTR pension has the following restrictions: A maximum of ten per cent of the account balance may be paid to you in pension payments each financial year. This means your nominated pension payments need to be within the minimum four per cent and maximum ten per cent limits. Cash lump sum withdrawals can only be made in very limited circumstances (see the Can a lump sum withdrawal be made? section on the following page). Once you meet a condition of release, such as retirement or turning age 65, these additional restrictions will no longer apply. In this situation, if you have been receiving the maximum pension payment, we will convert your current annual pension payment to a fixed dollar amount and continue to pay the amount of pension until you advise us otherwise. How the preservation components of your TTR pension option are treated Your components will retain their existing status where you have selected the TTR pension option. Your pension payments and lump sum withdrawals will reduce each component in a prescribed order. Payments will be made first from your unrestricted non-preserved benefits, then from your restricted non-preserved benefits; and lastly, from your preserved benefits. Investment earnings will be allocated to the preserved component. 13

16 Can a lump sum withdrawal be made? Generally, you can make a full or partial cash lump sum withdrawal from your pension account at any time, except where you have selected the TTR pension option. Under the TTR pension option, the following restrictions apply to cash withdrawals. No lump sum cash withdrawals are permitted except: to give effect to a Release Authority under the Income Tax Assessment Act 1997 to cash unrestricted non-preserved benefits to give effect to a payment split under the Family Law Act Once you meet a condition of release, such as permanently retiring from the workforce or reaching age 65, the withdrawal restrictions cease and you can make cash withdrawals at any time. You can transfer your benefit at any time: to a personal super or pension product in the Fund to a personal super or pension product in other super funds or to purchase an annuity 9. If you make a withdrawal, either as lump sum cash or as a transfer, part of the withdrawal may be paid to you as a pension payment. This will apply if you have not already received the minimum pension payments specified by the Commonwealth Government for the current year and the amount remaining in your pension account after the withdrawal would be insufficient to allow the minimum level of annual payments to be made, taking into account any payments made before the withdrawal. Withdrawal requests will be treated as a lump sum withdrawal unless you specify that the payment is a pension payment If you have a TTR pension and have not met a condition of release, you can only transfer to another income stream that also applies restrictions on cash withdrawals.

17 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Fees and other costs Consumer advisory warning DID YOU KNOW? Small differences in both investment performance and fees and costs can have a substantial impact on your long-term returns. For example, total annual fees and costs of 2 per cent of your account balance rather than 1 per cent could reduce your final return by up to 20 per cent over a 30-year period (for example, reduce it from $100,000 to $80,000). You should consider whether features such as superior investment performance or the provision of better member services justify higher fees and costs. TO FIND OUT MORE If you would like to find out more, or see the impact of the fees based on your own circumstances, the Australian Securities and Investments Commission (ASIC) MoneySmart website ( has a superannuation fee calculator to help you check out different fee options. This document shows fees and other costs that you may be charged. These fees and other costs may be deducted from your money, from the returns on your investment or from the assets of the superannuation entity as a whole. Other fees, such as activity fees and advice fees for personal advice, may also be charged, but these will depend on the nature of the activity or advice chosen by you. The fees quoted in this section may be different from the amounts deducted from your account as the amounts deducted will include the effects of any applicable reduced input tax credits (RITCs). Taxes are set out in another part of this document. You should read all of the information about fees and other costs because it is important to understand their impact on your investment. The fees and other costs for each investment option offered by the entity appear, on our website under the Performance Report of Underlying Funds and in the relevant PDS for each managed investment. 15

18 Fee Table Bendigo and Adelaide Bank Staff Superannuation Plan Pension Type of fee or cost Amount How and when paid Investment Fee Nil. Not applicable. Administration Fee Administration Fees Current employees, retired officers and their immediate family members 0.20% of account balance. Ex-employees and their immediate family members Account balance Cash Account % pa All other investments % pa First $250, Next $250, Amounts above $500, The Administration Fee is the percentage-based component calculated daily on your account balance 10. It is charged monthly in arrears and is deducted from your Cash Account 11 at the end of each month. Buy sell spread Member Fee Current employees, retired officers and their immediate family members $0.89 per week. Ex-employees and their immediate family members $0.77 per week. The buy sell spreads vary across the managed investments available. Please refer to the Performance Report of Underlying Funds appearing on our website or the relevant product disclosure statement for specific details. The Member Fee is the dollarbased component charged monthly in arrears and is deducted from your Cash Account at the end of each month. Where you are only a member for a portion of the month, the Member Fee will be charged on a pro-rata basis. A buy sell spread is added to, or deducted from (as applicable), the unit price of the relevant managed investment. Switching Fee Nil. Not applicable. Exit Fee Advice fees Relating to all members investing in a particular investment option. Nil for the first partial lump sum withdrawal per financial year other than your regular pension. Thereafter, $ will be charged per additional withdrawal. Member Advice Fee Upfront Member Advice Fee Ongoing Member Advice Fee One-Off. Deducted from your Cash Account at the time of each partial withdrawal that attracts the fee. A range of advice fees are available (see page 18 for details). None will be charged unless you request us to do so. Other fees and costs Refer to the Additional explanation of fees and costs section on pages 17 to 19. Indirect cost ratio The indirect cost ratio (excluding any performance fee) varies across the managed investments available and can range from 0.18% to 3.00% pa 12 ($1.80 to $30.00 pa per $1,000 invested). No indirect cost ratio applies to listed investments and term deposits. Generally calculated daily as a percentage of the amount you have invested in each managed investment. It is not deducted directly from your account but is generally incorporated into the unit price of the managed investment and generally charged monthly or quarterly in arrears Account balance - comprises your Cash Account together with the value of your investment options. 11 Your Cash Account is currently invested in an operating bank account (for day-to-day transactions) and the IOOF Cash Management Trust (ARSN ) (CMT), for which IIML is the responsible entity. Interest generated by this investment is reduced by bank charges and the management costs charged by IIML, as the responsible entity of the CMT, before it is credited to the Cash Account. You are charged an indirect management cost on your Cash Account balance. As at 30 June 2014, this indirect management cost was 0.28 per cent pa. We may change the investment of the Cash Account at any time. 12 Indirect cost ratios (excluding any performance fee) applied by each fund manager This fee range is an estimate only and is based on the information provided by each fund manager as at the date of this PDS (for further information refer to SSB.11). Investment options and indirect cost ratios may change from time to time. The most recent indirect cost ratio (excluding any performance fee) applied by each fund manager for a particular managed investment appear on our website under the IOOF Employer Super Performance Report of Underlying Funds and the relevant PDS for each managed investment.

19 Bendigo and Adelaide Bank Staff Superannuation Plan Pension PDS Example of annual fees and costs for a balanced investment option This table gives an example of how the fees and costs in the balanced investment option for this product can affect your investment over a one year period. You should use this table to compare this product with other pension products. Example IOOF Balanced Investor Trust Balance of $50,000 Investment fee Nil. For every $50,000 you have in the investment option, you will be charged $0 each year. PLUS Administration fees Administration Fee 0.615% and Member Fee $40.04 ($0.77 per week) And, you will be charged $ in administration fees. PLUS Indirect costs for the investment option EQUALS Cost of product 0.50% And, indirect costs of $250 each year will be deducted from your investment. If your balance was $50,000, then for that year you will be charged fees of $597.54* for the investment option. * Note: Additional fees may apply. And, if you leave the super entity early, you may also be charged an Exit Fee of $ (if this was not your first lump sum withdrawal that financial year). Additional explanation of fees and costs This section explains the fees and costs set out in the Fee Table and also provides a brief explanation about any additional transactional fees and charges that may apply to your pension account. Administration Fee This fee is the percentage-based component and it includes all administration and other expenses we incur, excluding any member advice fees (outlined in the following pages) and the fees and costs charged by the fund managers for each managed investment (the indirect cost ratio, any buy-sell spread and any performance fee). Member Fee This dollar-based component is the fee for the general administration of your account. This includes annual reporting and any changes to your pension account details. Performance fees We do not charge any performance fees. However, a fund manager may charge a performance fee for a particular managed investment when the investment return generated by the managed investment exceeds a specific criteria or benchmark. The performance fee (if applicable) is generally calculated daily as a percentage of the amount you have invested in the managed investment. The fee is generally deducted on a monthly, quarterly or annual basis. A fund manager would normally incorporate the cost into the unit price of the managed investment. The underlying fund managers that can charge a performance fee are outlined in the Performance Report of Underlying Funds on our website ( and the relevant product disclosure statement for each managed investment. Indirect cost ratio This represents the fees and costs charged by the underlying fund managers and is generally calculated daily as a percentage of the amount you have invested in each managed investment option. It is not deducted directly from your account but is generally incorporated into the unit price of the investment option. The most recent indirect cost ratios applied by the underlying fund managers for the available managed investment options are set out in the Performance Report of Underlying Funds on our website and the relevant PDS for each managed investment. 17

20 Transaction costs Managed investments Some managed investments have a difference between their entry (purchase) and exit (sale) unit prices and this is referred to as the buy-sell spread. This difference is an allowance for the transaction costs (such as brokerage, clearing and settlement costs and stamp duty, if applicable) of buying and selling the underlying securities/assets incurred by the fund manager of the particular managed investment. The buy-sell spread (if applicable) is incurred when you purchase or redeem units in a managed investment (at the time of a switch or when you move money in or out of your account) and is in addition to indirect cost ratios and performance fees. However, the buy-sell spreads are not charged separately to your account - they are generally included in the unit prices of each managed investment. The buy-sell spread that applies to each managed investment can change from time to time. Details of the buy-sell spread (or how to obtain the current buy-sell spread) applicable to each managed investment are outlined in the product disclosure statement issued by the fund manager for the particular managed investment which are available on our website. Listed investments Brokerage of per cent of the gross value of each trade (or $2.05 per $1,000 trade - minimum $38.44) applies to each order to buy or sell a listed investment. Brokerage is deducted from your Cash Account at the time of the transaction. Member advice fees You can request that we acquire and pay for the services of a financial adviser selected by you to provide financial advice in relation to your pension. We do not supervise the provision of services by your selected financial adviser. The following optional fees are available for you to select the most appropriate remuneration with your financial adviser: Member Advice Fee Upfront Member Advice Fee Ongoing Member Advice Fee One-Off You may agree to one or more of these options. For each option, we set a maximum amount that we will pay to the financial adviser. You and the financial adviser must agree on the amount of each member advice fee within these relevant limits. The amount of any member advice fee(s) that we pay to the financial adviser, as authorised by you, will be an additional cost to you and charged against your pension account. We shall not charge a member advice fee unless you tell us to do so. Any agreed member advice fee(s) will be charged by us to your account and paid in full to the financial adviser, until you instruct us to cease payment. Member Advice Fee Upfront This fee is charged by us and we deduct the net cost from your account. We then pay the full amount to the financial adviser for financial advice and services provided to you in relation to the establishment of your account. You can agree with the financial adviser on the amount of this fee up to a maximum of 5.5 per cent (inclusive of GST) of your initial contribution. For example, on an initial contribution of $50,000, we would pay the financial adviser up to a maximum of $2,750. You can agree to a different amount for the initial contribution and transfers/rollovers made to your account. The amount of this fee is deducted from your Cash Account at the time of each contribution. This fee is not applied to: transfers from existing accounts within the Plan any income distributions credited to your Cash Account switches between investment options. Member Advice Fee Ongoing You can agree to have any advice fee that is to be deducted based on the value of your account, on an ongoing basis. This amount is charged by us and we deduct the net cost from your account. We then pay the full amount to the financial adviser for ongoing financial advice and services provided to you in relation to your account. You can agree with the financial adviser on the amount of this fee which can be: up to a maximum of 2.2 per cent per annum (inclusive of GST) of your account balance (calculated daily), and/or up to a maximum of $18,000 per annum (inclusive of GST). The amount of this fee is accrued daily and is deducted from your Cash Account on the last day of each calendar month. For example, on an average monthly account balance (over 12 months) of $50,000, we would pay the financial adviser up to a maximum of $1,100 per annum (based on a Member Advice Fee Ongoing of 2.2 per cent per annum) (inclusive of GST). Member Advice Fee One-Off This fee is charged by us and we deduct the net cost from your account. We then pay the full amount to the financial adviser for one-off financial advice and services provided in relation to your pension account. The amount of this fee can be up to a maximum of $11,000 (inclusive of GST) per request. A new request must be supplied each time you wish this fee to be applied. Additional financial adviser benefits In certain circumstances we may also pay distribution costs to a financial adviser (or their dealer group). Any such amounts are paid from our resources and are not separate or additional charges to you. 18 The financial adviser should provide you with the details of any such benefit that they may receive. This information will be included in the adviser s Financial Services Guide and/or a Statement/Record of Advice, detailing any recommendations with respect to the Plan.