SPD Question

[Guest lbz123]

I've just started a new job and my first project is creating or updating SPDs for all of the benefit plans.

One of the SPDs I'm working on is for a defined benefit pension plan. Over the years, this plan has had different plant sites or divisions that participated in it, and other pension plans were combined into it. Each group apparently had differing benefit formulas. Over time, most these sites/divisions either closed or were sold. Right now only one site actively participates (still accrues a benefit). The only remaining participants in the plan are from this one active division, or vested terms/in-pay status retirees from the former locations/divisions.

To keep it clean, I was going to do one SPD for the active group.

For the others, I wanted to somehow combine them into a single spd. However, I cannot locate documentation that indicates what all the differing benefit formulas were over time, and I cannot find the details on how certain sites came to no longer be part of the plan (did they close or were they sold, or whatever). I can't really even determine how many different sites were once in this plan. I only have the most recent plan doc restatement, which only shows 2 groups in it, but I know from the current third-party administrator, that there were once many other groups. I can't locate a copy of the prior plan doc.

the 3-rd party administrator has only had the plan for a few years, so isn't really a source for history. The former administrator before that is no longer in business.

Does anyone have suggestions on how to approach this? Has anyone ever done an SPD for just vested terms and retirees and if so, would the requirements be different? Would I need to describe the varying formulas involved for each of the one time participants in the plan?

[GBurns]

The SPD is only (as the name signifies) a Summary. The details and formulas etc are in the Plan Document. You should not be trying to modify a questionable SPD but should be composing new ones from the governing PD/PDs.

IMHO, your first step is to find the Plan Document. I dot not see how you can do anything without finding it/them. How to find them ??? I suggest asking any and everyone, including your predecessors and searching every possible archives etc.

Was a copy every filed with the DoL or in a lawsuit ?

Who drafted the various documents ? They might be helpful.

[Guest NJ-Center of the Universe]

I've just started a new job and my first project is creating or updating SPDs for all of the benefit plans.

One of the SPDs I'm working on is for a defined benefit pension plan. Over the years, this plan has had different plant sites or divisions that participated in it, and other pension plans were combined into it. Each group apparently had differing benefit formulas. Over time, most these sites/divisions either closed or were sold. Right now only one site actively participates (still accrues a benefit). The only remaining participants in the plan are from this one active division, or vested terms/in-pay status retirees from the former locations/divisions.

To keep it clean, I was going to do one SPD for the active group.

For the others, I wanted to somehow combine them into a single spd. However, I cannot locate documentation that indicates what all the differing benefit formulas were over time, and I cannot find the details on how certain sites came to no longer be part of the plan (did they close or were they sold, or whatever). I can't really even determine how many different sites were once in this plan. I only have the most recent plan doc restatement, which only shows 2 groups in it, but I know from the current third-party administrator, that there were once many other groups. I can't locate a copy of the prior plan doc.

the 3-rd party administrator has only had the plan for a few years, so isn't really a source for history. The former administrator before that is no longer in business.

Does anyone have suggestions on how to approach this? Has anyone ever done an SPD for just vested terms and retirees and if so, would the requirements be different? Would I need to describe the varying formulas involved for each of the one time participants in the plan?

[Guest NJ-Center of the Universe]

Another place you might look is the audit reports that are attached to prior year 5500s. If you don't have them maybe the auditing firm does and maybe the can provide you with a copy. Those audit reports likely have summaries of the plan provisions.

Can you draft a "primary" SPD with separate addendums for each location? Meaning, a very generic SPD with all the required ERISA language, and then you attach the addendum for the location where the person earned the benefit? That would be cumbersome to administer, however.

Good luck,

[JanetM]

The plan actuary and whoever does the benefit calculations would also be ones to check with.

[david rigby]

Does the SPD have to detail the benefit formula(e) that apply to those participants who are inactive?