State of the Union Part 3 -- Mr. Smith goes to Washington (and not Detroit or Wall Street!)

by Gerald Nowotny
Contact

Overview

The 1939 movie Mr. Smith Goes to Washington tells the story of a proverbial "do gooder" (played by James Stewart) who goes to Washington as the junior senator from his state, hoping to make important changes but finds himself surrounded by dirty politics. It was made in 1939 but all of the backroom dealing and dirty politics are alive and well 70 years later.  Nothing ever seems to change in Washington . I am convinced that Republicans and Democrats would be unable to agree on the location for the Annual Congressional Christmas (correct - Holiday) Party.

One of the benefits for having served the "People" is a very generous retirement and employee benefits package. Even more interesting is viewing these benefits in relation to your own.  The question to be answered is "Can you have a retirement plan equal to or better than a Congressman or Senator without serving in Congress and ruining your reputation.

This article will focus on how a business owner without the benefit of  political clout and cronyism can create a pension plan that is  better than the Congressional Pension Plan and the defined benefit programs that for federal, state and municipal workers. 

The Days of Wine and Roses (and Defined Benefit Plans)

According to the Joint Committee of Taxation, 94 percent of businesses operate as S corporations or some form of pass-through entity - partnership or LLC.  In the current landscape, business owners are feeling the  impact of higher taxes. Taxpayers in the top marginal bracket will end up with a top federal bracket of 45.4 percent. High income states such as New York, New Jersey and California can add an additional 8-10 percent bringing taxpayers to a combined marginal tax bracket of 53-57 percent.

In 2010 (not that long ago!) the Treasury Inspector General for Tax Administration performed a study on the statistical trends in retirement plans. The results of the study showed that pension plan participation had increased dramatically over the last thirty years (1977-2007) but that the risk of funding retirement has shifted from employers to employees. 

In 1977, two-thirds of employees were covered by defined benefit pension plans. Over the thirty year period, defined benefit participation dropped to 23 percent. According to the U.S. Bureau of Statistics,  fewer than 20 percent of U.S. workers are covered by defined benefit retirement plans. These statistics include the 8.8 million federal employees and 19 million employees covered by state and municipal plans. The bottom line is this - if you work in private industry, the chances of being a participant in a defined benefit plan are "slim or none!"

In my view the dramatic drop in defined benefit participation by private employers is far worse when you consider that a healthy percentage of the defined benefit plans are made up of state and municipal plans.  As result, employees are expected to shoulder more of the funding of their retirement as taxes have gotten higher.

It is my strong contention that every  business owner would desire a defined benefit plan as the foundation of his retirement planning if he did not have suffer the cost of funding for his employees.  

The Congressional Pension Plan is a good example of the perks of being covered under a good defined benefit plan. The defined benefit plan provides a benefit for Congressmen who began participation before 1983 at a rate of 2.5 percent of the three year highest average salary for each year of service. Ten years of service provides a retirement benefit  equal to 25 percent of the Congressman's highest salary. Based on the current salary of $174,00 the retirement benefit is $43,500 per year.

For Congressman entering the plan after 1983, the credit is 1.5 percent for each year of service. Congressman now contribute to social security and receive benefits for social security retirement benefits which was not previously the case. A  Congressman with thirty years of service would receive a pension at age 62 of $130,500 per year.

The Congressional 401(k) Plan provides a 5.0 percent match of salary plus an additional 1.0 percent of salary regardless of whether or not the Congressman contributes to the Plan. The U.S. government pays 70-75 percent of the cost of post-retirement health insurance coverage. Nice work is you can get it!

Collectively Bargained Arrangements under IRC Sec 410(b)(3)(A)

The pension rules have strict rules regarding minimum participation and non-discrimination and minimum benefits. I  belabored the point in Part I and Part II of this series that there is an important exemption to this rule - employees covered under a collective bargaining agreement with a union may be excluded from participation.

IRC Sec 410(b)(3)(A) provides an important exception to the minimum participation rules of qualified retirement plans. This Code section exempts employees that are covered for retirement as well as health benefits under a collectively bargained agreement.

While the thought of union employees may be revolting to many business owners, the choices for the business owner can be narrowed to three choices - (1) Pay yourself; (2) Pay the Government 0r (3) Give your money to Charity. Presumably, a collective bargaining agreement with a business-friendly union (they do exist!) can strike a balance between a business owner and his employees. Better to have a job than not to have a job!

How deep is your love (for Uncle Sam)?

A Horse of a Different Color

Previously  I have focused on the fully insured defined benefit plan under IRC Sec 412(e)(3) as a solution for the business owner to create the largest tax deductible deduction with guaranteed retirement benefits. With a fully insured defined benefit plan, you won't end up like the participants of the City of Detroit pension plans with huge underfunding in the pension plan. The benefit payments are guaranteed by investment grade life insurers.

Nevertheless, some business owners and their advisors may believe that an insurance funded defined benefit plan is too conservative and unappealing for their sophisticated investment tastes. The traditional or split funded defined benefit plan is a fine solution.

In many respect following the Pension Protection Act of 2006 while introducing a number of provisions for under-funded pension plans, added more flexibility in terms of funding than previously existed for defined benefit plans.  It can now be a great contribution if your business has great and average years of financial performance.

In the present case, the planning objective is to maximize the level of contributions and benefits for the business owner.  The planning design provides for the inclusion of features and ancillary benefits to maximize contributions. Some of these provisions include (1) Form of Benefit - Joint and Survivor 100 percent, i.e. no reduction in benefit payments over the life of the survivor. (2) Incidental death benefit - The plan provides an incidental death benefit during retirement rather than ending at retirement.  (3) Disability Benefit - provides for benefits in the event of disability(4) Post Retirement Uninsured Medical and Long Term Care Benefits. The contribution component is limited to 25 percent of payroll. In small businesses, this may be a relatively small number. This component can be added after the defined benefit plan is fully funded.

Unlike a typical defined benefit plan which provides the option of a lump sum payout at retirement based upon a single life only annuity payout, this plan version is "benefit oriented" instead of being lump sum driven. The upside side of the tradeoff is a much larger tax deductible contribution.

Strategy Example

John Smith, age 52,  operates a small manufacturing company that provides specialty goods to the Department of Defense and other government agencies. His personal income is $1 million per year. He has twenty employees and an annual payroll of $1.5 million. 

The employee average age is 45. John's current pension administrator  has presented a new defined benefit option for consideration. John feels that the costs and benefits for both the company and himself are not attractive.

John's attorney (you or me) suggests that he consider establishing a defined benefit plan but suggests excluding the employees as result of the unionization of his employees. John  elects to take advantage of the provisions under IRC Sec 410(b)(3)(A) to exclude his employees from participation in the Plan. The employees are covered under the collective bargaining agreement between the  company with  a business friendly union that would provide benefits for the employees.

John adds his wife Betty, age 50, as an employee and participant in the plan and pays her the maximum allowable salary for contribution purposes in 2013 - $255,000. The defined benefit plan is a split funded plan, i.e. funded with investments and life insurance. The plan provides for retirement at age 65 with an annual retirement benefit of $205,000 for John and $205,000 for Betty -a total of $410,000 per year. 

The  Plan also provides a pre and post retirement death benefit equal to 100 times the monthly plan benefit. The Plan includes a cost of living increase on retirement benefits of three percent. Each participant's benefit provides for a 100 joint and survivor annuity payout. The plan also provide for benefit payments in the event of each participant's disability. Contributions for post-retirement medical benefits will be added once the Plan is fully funded for retirement purposes.  The plan does not have a lump sum option.

The defined benefit contribution for John in 2013 is $484,000. The defined benefit contribution for Betty is $430,000.  John and Betty will each be able to make a full 401(k) of $17,500. Each participant is able to make a catch up contribution of $5,500. The company is able to make a contribution into a profit sharing plan of $51, 000 in 2013 for each participant.

The total deductible contribution for the company is $1,051,000. The only participants are the business owner and his spouse. The tax savings for John is a combined tax bracket of 50 percent are $525,500. The company's match to the union 401(k) plan is the same as it was before. Additionally, he is paying slightly more for his employee's healthcare than he was before. The difference is that the quality of coverage is dramatically better. Additionally, the union's history for rate increases has been very stable and low relative to the commercial marketplace. Everybody is happy!

What if My Name is Not Daddy Warbucks?

So far I have demonstrated the benefits of the proposed solution for the highly compensated and "rich and famous". But what about the  business owner that is prosperous but not wealthy? What happens if he has  a great year this year and a horrible year in 2014. God forbid!

Example

Bob Jones, age 55, is a solo practioner with three employees. Bob has a general practice including some personal injury work. In a good year, Bob settles a nice "slip and fall" case and receives additional compensation through the contingency fees. In other years, John's income is stable, averaging $150,000 in personal compensation for himself. In a good year, his income can double to $300,000 or more. In a bad year, his income can be $120,000-130,000.

John has had a late start in his retirement planning and would like to make up for lost time. He decides to have his employees covered under union plan. He forms a split funded defined benefit plan along with a 401(k) and profit sharing plan which allow for flexible contributions.  The defined benefit plan provides for retirement at age 65 and will provide him with a projected retirement benefit of $150,000 per year.  The plan is loaded with ancillary benefits - (1) 100 percent joint and survivor retirement benefit  (2) Pre and post retirement death benefits (3) Disability benefits  (4) Post retirement medical and long term care benefits.

In 2013, John settles a personal injury receives contingency fee income of $350,000 so that his total income is $500,000. John is able to make a tax deductible contribution of $365,000. He makes a 401(k) contribution of $23,000 as well. His profit sharing contribution is $15,300. The total contribution is $398,300.

In 2014, John has a mediocre year and does not settle any personal injury cases.  His total compensation is $150,000. His contribution to the defined benefit plan is $25,000. He does not make a contribution to his 401(k) or profit sharing plans.

Summary

You don't need to be a member of Congress in order to receive political favor under the law at least when it comes to retirement planning. The ability to exclude employees from benefit plans allows the business owner to maximize contributions and benefits for himself and his spouse. The statutory tax benefits of qualified retirement plans remain as the most powerful and "black and white" with respect to legal authority and challenge.

A business owner only has three choices - (1) Write a check to himself for savings and investment (2) Write a check to Uncle Sam or (3) Write a check to his favorite charity. There are no other  choices!

The ability of a business owner to operate his company pension plan on a discriminatory basis is a dream come true for a business owner. Fortunately, the legal authority is very straight-forward and clear.

This article demonstrates that it does not matter what type of defined benefit plan that you establish- fully insured, or split funded. When you exclude employees from participation, the path is and only be clear. The level of contributions are flexible to accommodate fluctuations in earnings.

In high income years, the business owner can make larger contributions. In average years, the business owner can stable contributions and in bad years, the business owner can make a minimum contribution that can be as low as 20 percent of the regular contribution.

The layering of the defined contribution plan - 401(k) and profit sharing allows the business owner to take larger investment risks with those assets and have more upside to complement the defined benefit  fixed monthly income at retirement. The combination of the two concepts makes for a very powerful combination of large tax savings, tax referral and more importantly, a comfortable retirement.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Gerald Nowotny, Law Office of Gerald R. Nowotny | Attorney Advertising

Written by:

Gerald Nowotny
Contact
more
less

Law Office of Gerald R. Nowotny on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.