Document requirements for church 403(b) plan

[Guest LJC]

We have a (non-ERISA) 403(b) plan with employee contributions going into custodial accounts. I have been told that as a church plan we can also make employer contributions without being subject to any of the discrimination rules, but that we must have a plan document. Can anyone tell me what must go in that plan document. Since it's not subject to ERISA as a church plan, I wasn't sure if we just had to have in writing what we intend to do or if there are requirements other than ERISA that need to be included in the document.

Does anyone know of any model church plan documents? or anyone who drafts them at a reasonable price?

LJC

[mbozek]

Church plans are subject to the 200k, 402(g) and 415 limits as well as mrd rules, hardship, plan loan rules and requirements for salary reduction. But the plans are exempt fom the non discrimination requirements, and ERISA requirements such as spousal consent, non alienation and fiduciary provisions unless the church waives the ERISA exemption. There are no model or p- type plans because there is not a large enough market for such programs. Most large church groups sponsor their own plans.