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Wrap Document

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Hi all,

I am in the process of creating a Wrap (Document and SPD) for a client. I believe I have everything covered except the requirement to explain how insurer refunds (dividends, dmutualization, etc) are allocated. I understand this differs from carrier to carrier, but I am just looking for sample language for a jumping off point.

Any help or pointing in the right direction would be greatly appreciated.


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  • 3 weeks later...

Nancy, where did you see that this is a requirement in the wrap document and SPD?

I found a blurb from someone that does 5500's but have not been able to confirm this anywhere.

Also, have you seen anything which says an employer loses its small plan exemption if this language is not in the SPD?

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Even if relevant law does not require plan provisions about insurer refunds, might we prefer plan document provisions so that deciding what to do with dividends, demutualization proceeds, medical-loss-ratio rebates, and similar payments need not be a discretionary decision?

If so, can a plan provide that all such payments belong only to the employer?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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