[Official Guidance] June 12 IRS Phone Forum to Address 403(b) Written Plan Requirement and Frequent Issues
Begins at 2 PM; see the linked web page for registration information. The IRS is inviting requests for coverage of a specific issue; let them know via e-mail at ep.phoneforum@irs.gov on or before June 1, 2012. (Internal Revenue Service)
Text of Spring 2012 Issue of 403(b) Advisor Magazine
Articles include 'Philadelphia Story: Affirming Choice in 403(b) Plans' and 'The Evolution of the K-12 403(b) Marketplace.' (American Society of Pension Professionals & Actuaries; National Tax Sheltered Accounts Association)
[Guidance Overview] More Welcome 403(b) Relief from DOL
"The DOL, in its final 408(b)-2 regulation, issued relief for 403(b) plans, under which information related to certain contracts would not be subject to the the new fee disclosure rules. Though this was very helpful, it did not specifically address the 404a-5 participant disclosure regulations for the same type of contracts.... [The recently issued FAQs in Field Assistance Bulletin 2012-2 make] it clear in Question 2 ... that the 408b-2 relief for 403(b) plans also is extended to the 404a-5 requirements for said plans, on the same terms and conditions." (Business of Benefits)
[Opinion] A Policy Argument for Treating Individual 403(b)(7) Custodial Accounts As Distributable Assets Upon Plan Termination
"The IRS�s ongoing position is that an individual 403(b)(7) custodial account cannot be distributed from a 403(b) plan upon its termination, while a �fully paid� annuity contract is permitted to be distributed [because] it will not deem the custodial account to be an annuity for these purposes. This has the practical effect of preventing termination of any 403(b) plan which is funded with individual custodial accounts. As time wears on, and this position begins to get long in the tooth, its 'unworkableness' becomes more and more apparent as it causes difficulties beyond the actual plan itself." (Business of Benefits)
[Opinion] Text of Investment Company Institute's Recommendations for the 2012-2013 IRS Guidance Priority List (PDF)
The comments largely address certain regulatory issues that remain unsettled for 403(b) retirement plans. (Investment Company Institute)
[Guidance Overview] Another Question is Answered in the Who's the Employer Q&A Column
My wife (age 70, born September 1, 1931) and I both work for a small company (C corp) that had an SEP IRA but has recently switched to a calendar year 401(k) plan. My wife would like to roll over funds from the SEP IRA into the 401(k) plan. She would also like to roll other 'regular' IRA funds into the plan, as well as some 403(b) funds saved while working for a former employer. The goal is to avoid required minimum distributions. Can we? She is the President of the C corp and owns 4.96%. I am the CEO and own 4.5%. (BenefitsLink.com)
[Guidance Overview] Tax-Exempt Common Control Rules of the Final 403(b) Regulations of July 26, 2007
"These regulations address control group rules for tax-exempt entities. There are four tax-exempt common control rules. They generally do not apply to church or church-controlled organizations." (McKay Hochman)
Advisers Recommend Review of Non-Profit Employers' 403(b) Programs Before IRS Auditor Comes to Call
"The 2009 tax year is the first year that ... new regulations for documentation are truly in effect. And, of course, there's no guarantee that your plan will be audited. The plain fact of the matter is that the IRS gave plan sponsors more than sufficient time to bring their plans into compliance. And the simple truth is that it's the plan sponsor's responsibility to be in compliance, not the IRS's to enforce it." (The NonProfit Times)
Higher Education's Response to the New Defined Contribution Plan Environment
"Many [private colleges and universities] are taking a hard look at how their 403(b) pension plans are designed and administered, and are taking action to control costs, comply with new regulations, mitigate risk and help their employees prepare for retirement.... [This article] provide[s] a checklist for plan sponsors and administrators." (Towers Watson)
[Guidance Overview] Adapting and Complying in the New 403(b) Environment (PDF)
Recorded webcast. "Like many plan sponsors, Michigan State University ... used the resources offered by NAGDCA and others to help focus on the important and urgent issues that needed to be addressed: Creating a 403(b) Plan Document; Understanding and applying Universal Availability; Reviewing and deciding on the future of Loans and Hardship Withdrawals[.]" (National Association of Government Defined Contribution Administrators, Inc.)
Women: What You Need to Know About Financial Literacy
"As a woman, you need to assign a high priority to retirement planning, making your best effort to balance it with your other day-to-day and long-term priorities. With employer-paid pension and retiree health benefits being eliminated or scaled back, your retirement security is no longer something you can assume will be taken care of on your behalf. You need to take ownership, planning jointly with your spouse or partner if you have one." (TIAA-CREF)
Baby Boomers: What You Need to Know About Financial Literacy
"[F]or you, retirement is likely to be worlds apart from the old paradigm. Among other new challenges to your retirement security, you're faced with the decline of pension plans, a global economic downturn, an uncertain future for Social Security, rising health care costs and increasing life expectancies." (TIAA-CREF)
[Opinion] American Fidelity Assurance Company ? Low Fees for Us; High Fees for Educators
"[W]hen it comes to plan fees, this Oklahoma City-based firm behaves one way at home and another way on the road. Let's compare the retirement plan AFA offers its employees with the retirement products they pitch in California." (403bWise.com)
NAGDCA 2012 Survey of Defined Contribution Plans
"This report contains two sections. The National Summary provides a narrative overview of the key areas involved in administering governmental 457, 401(k), 401(a), and 403(b) plans. The survey also provides a pdf of the Overall Survey Results, which offers a look at the survey through charts and responses from all participating entities." (National Association of Government Defined Contribution Administrators, Inc.)
Using the IRS Interim 403(b) Document Audit Relief
"If an employer is found not to have adopted formal 403(b) plan document in a timely manner, the IRS may choose (presumably under non-abusive circumstances) to enter into a type of agreement where sanctions more resembling those available under the 'Voluntary Corrections Program' (VCP) will apply, rather than those under the more expensive 'Closing Agreement Program' (CAP). This should help encourage employers who still not have adopted a formal program to act as quickly as possible to adopt a formal written plan document, albiet late." (Business of Benefits)
Cut 403(b) Retirement Plans a Break, ERISA Advisory Council Tells DOL
"Government efforts to bring 403(b) retirement plans up to regulatory par with 401(k) plans has resulted in a rough transition for 403(b) plan sponsors, and in recognition of that fact, an ERISA advisory council gave the U.S. Department of Labor (DOL) five recommendations to help ease the compliance burden." (Thompson / SmartHR Manager)
Current Challenges and Best Practices for ERISA Compliance for 403(b) Plan Sponsors
"The objectives of this report are to (1) identify areas where guidance is confusing or lacking relating to complying with the new 403(b) regulations and (2) to determine what actions the Department of Labor (DOL) could take to enhance compliance with the regulations issued by DOL, as well as to ease certain regulatory burdens for 403(b) plan sponsors, especially smaller employers." (2011 Advisory Council on Employee Welfare and Pension Benefit Plans)
[Official Guidance] NC Public School Teachers' and Professional Educators' Investment Plan: NC 403(b) Plan
"The information on this web page provides information about the 403(b) plan as it will be administered by the NC Department of State Treasurer." (NC Department of State Treasurer)
[Official Guidance] Text of Massachusetts Bill Approved by Both House and Senate Allowing Nonprofit Employers to Adopt State-Run Defined Contribution Plan
"The treasurer and receiver general, on behalf of the commonwealth, may sponsor a qualified defined contribution plan within the meaning of section 414(i) of the Internal Revenue Code ... that may be adopted by not-for-profit employers for their employees in accordance with section 401(a) of the Code ... The treasurer may contract with practitioners, administrators, investment managers and other entities, including the Pension Reserves Investment Management Board, in order to design, administer and provide investment options under the plan." (187th General Court of The Commonwealth of Massachusetts)
Homework for Teachers: Their Investment Plans
"[Today's] streamlined 403(b)s look more like the private sector's 401(k) retirement plans, with employees putting part of their paychecks into individual accounts, sometimes with matching amounts from the employer, and choosing investments. Still, important differences remain. Workers in the nonprofit sector cannot simply follow the advice in the ubiquitous 'how to invest your 401(k)' books and articles because many of them also have pensions, annuities or other retirement investments." (The New York Times; free registration required)
[Opinion] California Bill Gives K-14 Educators a Second Chance at 403(b) Reform
"On February 23, 2012, [an assemblyman] introduced AB 1949 that would permit competitive bidding in K-14 California 403(b) plans." (403bwise)
Ensure your Plan Participants are Prepared for a Secure Retirement
Defined Contribution Conference, March 11-13, in Miami. Learn from your peers through presentations and discussions on plan design, communications, investment options and more. FREE registration for qualified plan sponsors. (Pensions & Investments)
Avoid the Common Mistakes Affecting Plan Loans Webcast
Earn CE credit while ERISA expert, Charles Lockwood, JD, LLM, explains the administrative issues that affect plan loans. Have questions? Charles will address them either during or after the webcast. March 22nd at 2pm EST. (ASC)
Assessing Reasonableness of 403(b) Fees (PDF)
"In an environment of change, adopting best practices for a disciplined and prudent process can help your organization evaluate fee reasonableness and provide a practical defense against fiduciary liability. Whether you have a 403(b) or a 401(a) plan, this process should include identifying the individual(s) at your organizationresponsible for evaluating plan fees and service quality." (TIAA-CREF)
[Opinion] 403(b) Specialist Discusses Retirement-Plan Tips and Traps for Educators and Other Workers in the Nonprofit Sector
"[Morningstar] recently interviewed Dan Otter, whose website, 403bwise.com, aims to help investors make sense of the often-confusing 403(b) marketplace. Otter discussed the 403(b) landscape and shared tips for 403(b) participants aiming to sift among a confusing array of choices." (Morningstar)
[Official Guidance] Annual Reporting and ERISA Coverage for 403(B) Plans
Field Assistance Bulletin ... responding to questions concerning the scope of and conditions for transition relief provided by FAB 2009-02. The FAB also responds to questions concerning the scope of the Department's safe harbor regulation[.]" (U.S. Department of Labor - Employee Benefits Security Administration)
[Opinion] Promoting Greater Transparency for 403(b) Plan Fees
"Over the past few years, new 403(b) regulations have changed the landscape significantly. While multivendor plans remain an option (unlike single vendor 401(k) plans), the 403(b) regulations require plan sponsors to adopt a written plan document and ensure that the plan operates in accordance with its terms. In addition, new mandatory procedures include limits on contributions and distributions and requiring a third-party administrator to monitor employee eligibility." (The Agbay Group)
IRS Providing Interim 403(b) Plan Document Relief
"Though not provided in formal, published guidance ... under the interim program, IRS examination staff will approach plan problems in an accommodating manner ... An employer should avoid attempting to retroactively amend the plan on audit ... Because of several procedural issues, retroactive amendment of the plan on audit will trigger the higher CAP sanctions[.]" (Smart HR Manager / Thompson)
Understanding the New 403(b) Model Disclosure Form
"One of the key reasons for the 403(b) Transparency Taskforce's new 403(b) model disclosure form is so vendors can show plan sponsors that they offer more than just products, according to industry experts." (PLANADVISER.com)
Do Non-Erisa 403(b) Plan Sponsors Have Fiduciary Responsibilities?
"David W. Powell, Esq., The Groom Law Group, speaking to attendees at the National Tax Sheltered Accounts Association's (NTSAA) 403(b) Advisor Summit, pointed to the Uniform Management of Public Employee Retirement System Act (UMPERSA), which imposes a prudent standard for the main employee retirement system of states. It excludes 403(b)s, but, Powell noted, as states adopt 403(b)s, such language is used in state law." (PLANADVISER.com)
401(k) 403(b), and 457(b) Plans: Key Features and Contribution Limits for 2012 (PDF)
"Section 401(k) plans are the most prevalent type of defined contribution plan in the private sector. Section 403(b) plans are another form of defined contribution plan, available only to employees of certain tax-exempt and public educational organizations. Section 457(b) plans are defined contribution plans established by state and local governments and certain tax-exempt organizations. The table . . . compares important aspects of these plans." (Retirement Town Hall)
Text of White House'S Budget Proposal Cutting Back on Income Tax Benefit of Retirement Plan Contributions for High-Earners (PDF)
"The proposal would limit the tax value of specified deductions or exclusions from [Adjusted Gross Income] and all itemized deductions. This limitation would reduce the value to 28 percent of the specified exclusions and deductions that would otherwise reduce taxable income in the 36-percent or 39.6-percent tax brackets.... The income exclusions and deductions limited by this provision would include any ... employee contributions to defined contribution retirement plans and individual retirement arrangements[.]" (White House)
[Guidance Overview] IRS Begins Auditing 403(b) Plans and Provides Interim Procedure for Correcting Plan Document Failures
"We recommend, as we have previously, that a 403(b) plan sponsor that discovers a problem with their plan document or who has not yet adopted a plan document correct the failure immediately and not wait for IRS' update of the EPCRS program as IRS will consider 'good faith' efforts to comply in determining whether to assess penalties during an audit and in negotiating a correction under EPCRS once that program is open." (EisnerAmper)
[Guidance Overview] IRS Wants to Offer RMD Relief for Longevity Annuity Contracts in 403(b)/457, Other Retirement Plans
"Based upon [comments received], Treasury and the IRS concluded that 'substantial advantages' exist to modifying the RMD rules to make it easier for a participant to purchase a deferred annuity that is scheduled to commence at an advanced age -- such as age 80 or 85 -- using a portion of his or her account. Accordingly, the proposed regulations . . . would provide that before annuitization, a participant could exclude the value of a longevity annuity contract that meets certain requirements from the account balance used to determine RMDs." (Thompson)
[Guidance Overview] Final Fee Disclosure Regs Contain Important Relief for 403(b) Plans
"As with everything 403(b), there are going to be complications, as it is not a totally carte blanche of pre-2009 'frozen' contracts. There will be odd circumstances, like where vendors who insist on employer approval on loans and distributions from those contracts (but the price of that insistence will be 408(b)(2) disclosure)." (Business of Benefits, Robert J. Toth Jr.)
[Guidance Overview] DOL Finalizes, Delays 401(k) Fee Disclosure Rules
"The final regulations 'strongly encourage' service providers to offer plan fiduciaries a 'guide' or summary of their disclosures. The DOL included a sample guide as an appendix to the final rule. Debate about whether to require such a summary disclosure is rumored to have delayed the release of the final rules. For now, the summary is voluntary, but the DOL strongly hinted that it may make the summary mandatory in future regulations." (Benefits in Brief)
[Guidance Overview] Final ERISA Section 408(b)(2) Regulations Include Significant Differences from Interim Rules
"These regulations make several significant changes . . . including: [1] Excluding certain frozen IRC Section 403(b) plans issued before January 1, 2009 from coverage under the regulations; [2] Enhancing the information relating to 'indirect compensation' required to be disclosed; [3] Adding certain investment-related disclosures to facilitate compliance with DOL regulations under ERISA Section 404(a); [4] Extending the effective date to July 1, 2012. This has the effect of delaying the effective date of most participant-level disclosures under ERISA Section 404(a) to August 30, 2012." (Practical Law Company)
[Official Guidance] Proposed IRS Regs on Longevity Annuity Contracts
"This document contains proposed regulations relating to the purchase of longevity annuity contracts under tax-qualified defined contribution plans under section 401(a) of the Internal Revenue Code (Code), section 403(b) plans, individual retirement annuities and accounts (IRAs) under section 408, and eligible governmental section 457 plans. These regulations will provide the public with guidance necessary to comply with the required minimum distribution rules under section 401(a)(9). The regulations will affect individuals for whom a longevity annuity contract is purchased under these plans and IRAs (and their beneficiaries), sponsors and administrators of these plans, trustees and custodians of these IRAs, and insurance companies that issue longevity annuity contracts under these plans and IRAs." (U.S. Internal Revenue Service)
[Official Guidance] Text of Final 408(b)(2) Regs on Fee Disclosures to Plan Fiduciaries by Covered Service Providers (PDF)
109 pages. 'This document contains a final regulation under the Employee Retirement Income Security Act of 1974 (ERISA or the Act) requiring that certain service providers to pension plans disclose information about the service providers' compensation and potential conflicts of interest. These disclosure requirements are established as part of a statutory exemption from ERISA's prohibited transaction provisions. This regulation will affect pension plan sponsors and fiduciaries and certain service providers to such plans." (U.S. Employee Benefits Security Administration)
[Guidance Overview] Second DOL 'Fact Sheet'; Description of Major Changes to Final Fee Disclosure Rule
"The final rule's effective date has been extended to July 1, 2012, to allow additional time for compliance." (U.S. Employee Benefits Security Administration)
The Making of The 403(b) Model Disclosure Form
"These [403(b)] plan participants are not fiduciaries, and often do not have anyone to be able to collect and compare data on their behalf. They are sold investment products directly. So it really becomes a very simple issue for that school teacher or administrator: how much sales commissions is my investment generating; what services am I getting in return; is there a way for me to compare it all; and how can I reasonably access comparative data on the investments themselves?" (Business of Benefits, Robert J. Toth Jr.)
Unraveling The Mystery of 401(k) Disclosures
"Sponsors will be required to present information about the investment options in the retirement plan in a chart that allows plan participants to compare fees and expenses . . . . Plan sponsors can use a model chart developed by the Labor Department or they can develop their own." (MarketWatch)
New Fee Disclosure Solution Released By NEA, NTSAA & ASPPA Joint 403(b) Taskforce
"Partners of the 403(b) Transparency Taskforce including the National Education Association (NEA), the National Tax Sheltered Accounts Association (NTSAA) and The American Society of Pension Professionals & Actuaries (ASPPA) today launched the 403(b) Model Disclosure Form -- the first ever transparency standards for disclosure of fees and services in the public school 403(b) marketplace." (American Society of Pension Professionals & Actuaries)
403(b) Model Disclosure Form (Jan. 2012)
"This form is designed to provide [you, a 403(b) plan participant,] with the ability to easily compare detailed information regarding the investment options available to you. It is designed to provide you with a snapshot of the critical information needed when selecting an investment, including the services to be provided to the participant, the fees to be charged to the participant, investment information, the commissions payable to the persons who provide services to the plan, and other payments to third parties." (ASBO, NEA & NTSAA Joint 403(b) Taskforce)
[Opinion] The Savings Crisis of Working Americans: The Retirement Industry Call to Action
"[I]f our society does not acknowledge and address the coming retirement savings shortfall, the American dream of retirement will most certainly become a nightmare. . . . Americans must save more for their retirement." (Legg Mason Retirement Advisory Council)
Pushback from Disclosure of Costs to Participants: Too Much 401(k) Sunshine?
"[R]ecord keepers for some plans are already experimenting with new ways to explain fees to retirement savers. And in at least one case, those disclosures are raising more questions than employers or investment advisers want to answer." (Wall Street Journal)
New Tool to Clearly Disclose 403(b) Fees
"[A]n industry task force, including the National Education Association, today will unveil a tool [called called the 403(b) Model Disclosure Form] that will clearly disclose 403(b) plan fees." (USATODAY.com)
[Opinion] NTSAA and ASPPA Letter on the Inclusion of 403(b) Plans in the Prototype Program
"On January 23, 2012, NTSAA and ASPPA submitted comments to [IRS] in support of the inclusion of 403(b) plans in the prototype program for pre-approved plan documents. IRS officials have recently indicated that budget concerns may result in a reexamination of whether to include 403(b) plan documents in the pre-approved plan program. NTSAA and ASPPA believe that a prototype program for 403(b) plans is essential for the proper administration of the tax laws and that it would be a mistake to abandon this integral component of 403(b) compliance." (American Society of Pension Professionals & Actuaries/National Tax Sheltered Accounts Association)
[Opinion] Is ASPPA Really Interested in Disclosure to 403(b) Participants? Here Is Their Chance to Prove It
"While I think Single Vendor [for 403(b) programs] is the best route, I am also a realist and understand that a single vendor environment is not going to happen overnight . . . . It got me thinking about what can be done to protect current participants who are stuck in a non-oversight multi-vendor program or even a program that does have oversight but has multiple vendors. . . . I am calling on ASPPA to . . . require that those who want to work with public school employees and give 'advice' be a fiduciary and those that sell product must disclose they are NOT advice givers and NOT acting as fiduciaries." (The Meridian Blog, authored by Scott Dauenhauer CFP, MSFP, AIF)
Best Practices for 403(b)s Subject to Fee Disclosure Rules
"[T]he NTSAA Fee Transparency Task Force is in the final stages of the development of a fee disclosure document patterned after the DoL model comparative fee chart. The document will be available for non‐ERISA employer plans in the belief that employers and participants will benefit from total transparency as they exercise their freedom to choose their own investment options, and financial advisers. It is expected that the Task Force will launch the new document in the first quarter of 2012." (PLANSPONSOR.COM)
Can a Professional Retirement Plan Advisor Really Make That Much of a Difference? (PDF)
"This survey of 409 employer offering a 401(k) or a 403(b) plan completed in September 2011 found that sponsors who partner with a Professional Retirement Plan Advisor enjoy superior retirement outcomes for their participants, superior understanding of fiduciary issues, improved plan designs, improved plan arrays, improved overall asset allocation among plan participants, more reasonable fees, and greater confidence in plan compliance and investment options." (Retirement Advisor Council / EACH Enterprise, LLC)
Teachers' 403(b) Plans Becoming More Like Corporate 401(k) Plans
"Much of the current change is being driven by Internal Revenue Service rules that began taking effect in 2009 and that give plan sponsors administrative and compliance responsibilities for employees' 403(b) investments. Change also is coming as growing numbers of teachers face cuts to their traditional pensions, giving them more incentive to sock away money in 403(b)s, consultants and school officials say." (The Wall Street Journal)
2011 NTSAA 403(b) Compliance Resolution Summit
"The third annual NTSAA 403(b) Compliance Resolution Summit attracted a large gathering of product providers, third party administrators, and resource people from the Department of Labor, Internal Revenue Service, American Institute of Certified Public Accountants, the Association of School Business Officials, the 501(c)(3) community, and legal firms for open dialogue on best practices to contribute to the operation of compliant 403(b) plans. All three of the Summits have contributed greatly to the resolution of what were systemic problems through the adoption of best practices that most in the industry can follow. The result has been the standardization of processes and procedures that most can utilize for a smoothly operating 403(b) plan." (National Tax Sheltered Accounts Association via American Society of Pension Professionals & Actuaries)
[Opinion] Those 403(b) RMD Amendments and Corporate Resolutions
"Some vendors are presenting [RMD amendments for 403(b) plans] to plan sponsors for their signature by year end, as the vendor may have taken it upon itself to generally waive these requirements for those 403(b) customers with individual contracts." (Robert J. Toth, Jr., Business of Benefits)
CalSTRS' Julia Durand Discusses Challenges of Public DC Plans
"Julia Durand, the president of NAGDCA and a director at CalSTRS, discusses the unique challenges facing public defined contribution plans with P&I online editor Matthew Wurtzel." (Pensions & Investments; free registration required)
Father of 401(k): 'Blow Up the System and Restart'
"Ted Benna, the 'father' of the 401(k) believes the plans have become to complex and are not working the way they should. Imagine what he would think of the 403(b) world." (The Meridian Blog)
403(b) Advisor, Winter 2011 Edition
Articles include: University of South Alabama Hospital Gets a New 403(b) Plan; Organization Attributes High Participation Rate to Education and Personal Contact; and, Fixed Index Annuities Offer Safe-Money Alternative for Retired or Retiring Clients. (National Tax Sheltered Accounts Association / American Society of Pension Professional and Actuaries)
403(b) Advisor, Spring 2011 Edition
Articles include: Questions and Answers about the New Roth Rollovers in 403(b) Plans and Building Retirement from Floor to Ceiling in the Trend Spotting column. (National Tax Sheltered Accounts Association / American Society of Pension Professional and Actuaries)
403(b) Advisor, Summer 2011 Edition
Articles include Navigating the Regulatory Waters; Rush to Retirement: Layoffs, Pay Cuts, Benefit Reduction, Mass Exodus; Get The Most Out Of Social Security... While You Still Can; Is the 403(b) Plan Dying?; and Paying 'Reasonable Plan' Expenses. (American Society of Pension Professional and Actuaries )
[Opinion] DC Plans and the Recession Inequities
"I would make the case that the smartest thing Congress could do right now is to increase the DC limit, as least for an interim period, to allow balances to be rebuilt." (Robert J. Toth, Jr., Business of Benefits)
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