Retirement Savings Planner

"So easy anyone can use it."
In a few minutes you can punch in basic data and have Retirement Savings Planner generating meaningful and accurate retirement savings projections. Even more important, the easy-to-read charts display in "red" any projected shortfall.

Commentary on NASD Rule 2210:
Q: Does Retirement Savings Planner need to be submitted to the NASD for approval by my Broker/Dealer?
A: No, according to NASD Interpretative Material IM-2210-6.

Some financial advisors that work for NASD member firms often ask us "Does the software need to be submitted to the NASD for approval?".

We are obviously not members of the NASD, but have made available to you the following PDF file that is very clear as far as how NASD Rule 2210 applies to software.

Read the Investment Analysis Tools Guidance letter from the NASD made final February 14, 2005 (portions highlighted by Torrid Technologies)

Quoting from this letter, "IM-2210-6 defines an investment analysis tool as 'an interactive technological tool that produces simulations and statistical analyses that present the likelihood of various investment outcomes if certain investments are made or certain investment strategies or styles are undertaken, thereby serving as an additional resources to investors in the evaluation of the potential risks and returns of investment choices.'"

Note: our software does not produce simulations or statistical analyses related to the likelihood of investment outcomes. This is more typical with software that touts "monte carlo simulation" which our software currently does not do.

Quoting from this letter, "The filing requirement does not apply to hypothetical illustrations of mathematical principles that do not predict or project the performance of an investment or investment strategy, such as Web site calculators that compute future returns based upon assumed variables, since Rule 2210(d)(1)(D) does not prohibit (and IM-2210-6 thus does not cover) such illustrations."

Note: our software falls under this exception since it just computes future returns based upon the assumed variables that you enter.

Endnote 3 elaborates on this by saying, "The 'hypothetical illustration' exception to the prohibition in Rule 2210(d)(1)(D) applies to tools that serve the function of a calculator that computes the mathematical outcome of certain assumed variables without predicting the likelihood of either the assumed variables or the outcome. For example, this exception would apply to a calculator that computes a net amount of savings that an investor would earn over an assumed period of time with assumed variables of rates of returns, frequency of compounding, and tax rates. On the other hand, this exception would not apply to a calculator that predicted the likelihood of achieving these assumed variables and outcomes."

Our conclusion: If you are with an NASD member firm, the Retirement Savings Planner software falls under the "Hypothetical Illustration" Exception to Rule 2210 and does not need to be filed with the NASD.






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Professional Edition Testimonial:

"The Retirement Planner program is very intuitive, and it is graphically very rich. So my clients can see very quickly where they stand as far as their retirement assets are concerned... they can see if they have enough money to retire on, and if not, what they have to do to reach their goal!

For 80% of my clients, the 8-9 page Retirement Planner Report is all they need to get started, they don't need a 120 page report... and for the few that do need more detail I will arrange for that.

The Computer laptop presentation that we make for clients just 'wows' them, and then we do 'what ifs' for different scenarios and the graphs change before their eyes, so they can see what happens with different situations..."
Rusty Scheewe, Financial Advisor

1860 Sandy Plains Rd. • Suite 204-129 • Marietta, GA 30066
Ph: 770.565.6405

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