The Super Roth IRA[1] - For Regular Guys (and Gals) - Part 2

by Gerald Nowotny


In Part I of this series, I introduced the Super Roth IRA an alternative to the Roth IRA and traditional IRA. The Super Roth IRA uses the tax-advantages of permanent life insurance and is a more flexible arrangement than either the traditional IRA or Roth IRA.

This article is designed to outline the path for investors that are not accredited investors or qualified purchasers, i.e. regular folks and gals. The article will outline how to make a traditional life insurance or variable life policy a “lean and mean fighting machine. The result of this planning will make the product very efficient from both an accumulation and cost standpoint.

The Super Roth IRA allows a taxpayer to make after-tax contributions into the plan irrespective of adjusted gross income (AGI) and without limitation to the contribution level. Furthermore, it is not subject to all of the restrictions and limitations of either the traditional or Roth IRAs in regard to minimum distributions and death.

Traditional IRA and Qualified Plan Basics

These days, you are lucky to work for a company that sponsors a retirement plan. The days of a company paid retirement plan are long gone unless you work for the federal, state or municipal government. You are lucky if your company even matches the employee’s contribution to a 401(k) plan.

The 401(k) allows a participant to defer up to $17,000 of earnings on a pre-tax basis in 2012. A participant that is older than age 50 may contribute an additional $5,500 per year

IRA contributions are the same for traditional and Roth IRAs. The amount of IRA contribution is reduced by the amount of contribution made to a Roth IRA. The IRA allows a taxpayer to contribute $5,000 in 2012 ($6,000 if the taxpayer is age 50 or older) if the taxpayer is a participant in a company sponsored pension plan.

If the taxpayer is a participant in a retirement plan, the taxpayer receives a full deduction on the contribution if adjusted gross income (AGI) on a joint basis is less than $90,000.

The deduction is phased out for AGI between $90,000-$110,000. For a single taxpayer the deduction is phased out between $56,000-$66,000. .

If the participant does not participate in a pension plan at work, the taxpayer is able take a full deduction on the contribution without consideration on the level of adjusted gross income.

The tax rules for traditional IRAs or qualified retirement plan benefits  require a taxpayer to begin required minimum distributions by April 1 in the year following the year in which the taxpayer reaches 70 ½. The IRS imposes a 50 percent excise tax on the difference between the required minimum distribution amount and the amount actually withdrawn.

The distributions are taxed as ordinary income rates. Distributions before age 59 ½ are subject to a 10 percent early withdrawal penalty. The account balance is included in the taxpayer’s taxable estate.

Roth IRA Basics

A taxpayer that files jointly is able to contribute to a Roth IRA if the taxpayer’s modified adjusted gross income (AGI) does not exceed $173,000. The contribution phases out between $173,000-183,000.

For a single taxpayer, contributions phase out between $110,000-$125,000. A taxpayer that is married and files separately is unable to make a contribution if modified AGI exceeds $10,000.

The calculation of modified AGI excludes the proceeds from an IRA rollover or qualified plan. This important distinction generally speaking makes it easier for a taxpayer to position himself to do a conversion from a traditional IRA to a Roth IRA.

The primary difference between the Roth IRA and IRA or qualified plan is that the Roth IRA does not have required minimum distributions. Distributions from the Roth IRA are not subject to income taxation. However, the distribution must be a “qualified” distribution. Qualified distributions require five years of “seasoning” within the plan unless the taxpayer is at least age 59 ½.

Distributions before age 59 ½ are subject to the 10 percent early withdrawal penalty as well as normal tax treatment on the distribution (as if it were a traditional IRA). Like the IRA, exceptions to these rules exist for a distribution for a first-time home buyer; distribution to a disabled taxpayer, or a distribution to a beneficiary on account of the taxpayer’s death.

The account balance is included in the taxpayer’s taxable estate. At death, the remaining distribution of the account is subject to the same rules as the traditional IRA. A surviving spouse as the beneficiary of the Roth IRA can treat the Roth IRA as her own. Other beneficiaries must distribute the balance over their life expectancies.

The investment guidelines for a Roth IRA are similar to the restrictions for a traditional IRA. The policyholder can expand the investment guidelines through the use of a self-directed arrangement. The prohibited transaction guidelines applicable to the traditional IRA apply to the Roth IRA as well as the tax rules on unrelated business taxable income (UBTI)

Super Roth IRA Basics

  1. Overview

The Super Roth IRA uses after-tax contributions as premiums into a permanent life insurance policy – whole life, indexed universal life or variable universal life insurance. The policy is structured is a manner to minimize the impact of sales commissions within the policy which reduce the amount of cash value within the policy. It typically takes eight-ten years to overcome the impact of the sales commissions within a permanent life insurance contract.

  1. Tax Treatment

Life insurance is a highly tax-advantaged investment vehicle. The cash value within the policy accumulates tax-free within the policy. The policyholder may access the investment gains within the policy on a tax-free basis. Usually, the policyholder accomplishes the tax-free withdrawal by taking a partial surrender of the cash value up to the tax basis in the policy (cumulative premiums). Once the basis has been fully recovered, the policyholder is able to switch to tax free policy loans.

The loan is very low cost and non-recourse to the policyholder. Typically, the “spread” or cost of the loan is .25-.50 (25-50 basis points) per year. The policyholder does not need to make interest or principal payments during his lifetime. The accumulated loan reduces the death benefit at the insured’s death.

It is critical that the policyholder retain sufficient assets within the policy to cover policy costs. A policy lapse would be catastrophic for the taxpayer’s tax planning. In the event of a lapse, the loans would be treated as amounts received under the policy and subject to taxation at ordinary rates.

Unlike the traditional IRA and Roth IRA, the Super Roth IRA is not subject to contribution limits, earnings caps, or restrictions or conditions on distributions during lifetime or at death. Depending upon the type of policy(ies) chosen as well the insurer, the policyholder has equal or greater investment flexibility than the IRA or Roth IRA.

  1. Policy Design Considerations

In order to maximize the Super Roth IRA from an investment standpoint, the taxpayer needs strong and consistent investment performance and cost management. The biggest cost factor within the policy is the sales commission within the policy to the agent.

The typical retail life insurance policy has total first year commissions of 110-120 percent of the policy’s target premium (aka commissionable premium. This level of commission is the reason why it takes 8-10 years to recoup these costs within the policy.

The policy should be funded so that the policy is a non-Modified Endowment Contract (MEC). Non-MEC status is important. It preserves the tax-free treatment for policy withdrawals and loans from the policy. The policy design should use the guideline premium test tax law definition of life insurance.

The Super Roth IRA uses “reverse engineering” to fund the policy. First, figure out how much you want to contribute to the policy on an annual basis. You can have some fluctuate, but the taxpayer should select an annual that amount that has a reasonable chance of being consistent. With this information, the life insurer can figure out how much death benefit you need on the policy so that it meets the tax requirements.

Based on the desired premium level, the policy should have the minimum allowable death benefit based on the tax law requirements so that the policy is a non-MEC. Essentially, the policyholder is attempting to force as much premium into a policy with the least amount of death benefit so that the policy is a life insurance policy for tax purposes and a non-MEC.

Virtually every universal life (indexed, traditional or variable) has a policy rider known as a term rider. This rider is non-commissionable within the policy. The policy should be designed to that the policy death benefit is largely covered by this term rider. Generally a carrier will allow a mix of base coverage and this term rider in a ratio of 10-20 percent base coverage and 80-90 percent non-commissionable term rider. The term rider “dials down” the commission level within the policy.

As a result, the premium can be invested within the policy with a much smaller “haircut” providing a larger cash value on Day 1 for investment. The result is more money accumulating from Day 1 on a tax-advantaged basis. The net result is greater accumulation for retirement planning purposes.

Hear my word – your life insurance agent will not make this option available to you! You need to request this.

  1. Types of Policies
  1. Whole Life

From an investment perspective, the policyholder should look at whole life insurance as a long term investment grade bond. The crediting rate or dividend of whole life is tied to the investment performance of the life insurance company’s general account assets.

The investment of the general account assets is regulated by state insurance regulators. Generally 85-90 percent of the general account assets are invested in long-term investment grade bonds, mortgages and real estate. The general account has minimal exposure to the stock market but is interest rate sensitive.

  1. Variable Universal Life

Variable universal life insurance provides investment access to mutual fund-like sub-accounts managed by the best known mutual fund families (Fidelity, Oppenheimer et al). These assets are segregated from the insurer’s general account assets. The policyholder receives a direct pass-through of the fund’s investment performance. Most products offer a very large assortment of fund choices (50-60) across a wide segment of investment strategies. If you can’t find a fund that you like, you aren’t looking hard enough!

  1. Indexed Universal Life

Indexed universal life insurance is the new kid on the block. Indexed universal life insurance typically provides a minimal guarantee on the cash value crediting rate. but allows the policyholder to participate in the performance of a broad stock index such as the S&P 500 or Russell 2000. The upside is usually capped in exchange for downside protection when the S&P is less than zero. In essence, the policyholder has downside protection and upside participation in the stock market.

Case Study

The Facts:

John Smith, age 50, is information technology specialist for a Fortune 500 company. He participates in his firm’s 401(k) plan that matches up to fifty cents to the dollar up to three percent of his salary of $100,000. His wife also contributes to her company’s 401(k) plan. The company does not offer any matching to employee contributions.

John and Mary would like to save an additional $10,000 per year for retirement planning purposes.

The Strategy

John is the applicant, owner and beneficiary of a whole life insurance policy insuring his life. The policy issued by Southwestern Mutual. Southwestern Mutual has the highest ratings from the independent rating agencies. In effect, the policy is like a “AAA” corporate bond with tax-free treatment.

The policy has a premium of $10,000 per year and a death benefit of $500,000. This death benefit is the minimum allowable death benefit that will meet the tax law definition of life insurance without violating the MEC guidelines. The fixed annual premium for all base whole life coverage is $10,000 per year.

In the Super Roth IRA, the policy provides for base coverage of $1,000 and $499,000 of term insurance coverage. The combined cost for the death benefit coverage annually is $1,250 per year. The difference of the annual premium and the cost for the death benefit ($10,000 less $1,250=$8,750) is added to the policy as a paid up additions rider. The projected cash value at the end of Year 1 based on the company’s dividend scale is $9,000. The projected cash value based on this policy design will exceed cumulative premiums in the second policy year instead of the 9th or 10th policy year had the policy been sold with all base or commissionable coverage.

In Year 15 the policy has a projected cash value of $245,000 and a death benefit of $625,000. John is able to take tax-free withdrawals from the policy without penalty. In the event of death, Mary receives the proceeds income tax-free treatment. Policy distributions have no impact on the taxation of social security benefits. Additionally, in John’s state of residence, the policy is not subject to the claims of his personal creditors.


The Super Roth IRA is a more flexible alternative than a traditional IRA or the Roth IRA. One key factor in maximizing the benefit of the Super Roth IRA is to minimize the impact of sales load within the policy. I have outlined some “trade secrets” in order to make the policy more turbo-charged for accumulation purposes.

The combination of tax advantages and institutional pricing allow the Super Roth IRA to provide excellent retirement income and estate planning benefits families. The last installment on the Super Roth IRA will focus on a quantitative analysis between the traditional, Roth and Super Roth IRAs. Stay tuned!

[1] Super Roth IRA is a trademark of Reg Wilson of Epic Financial.


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

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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.