Corbel / Collapsible Adoption Agreement

[austin3515]

Corbel just sent us an email that they are adding a "collapsible" Adoption Agreement where the unselected options will be suppressed.  Does anyone have more information on what that will look like?  I assume for example a non-safe harbor plan, the whole safe harbor section will be suppressed.  But their email was a little sparse on detail, perhaps because they haven't figured it out yet.

Just curious what others know about it.

I'm also concerned about losing familiarity with all of the options available for my own selfish purposes (i.e., being an expert on what my own document can do which I have due in part to seeing it entirely all the time).

[justanotheradmin]

ASC's document software has a similar option, but during the last DC restatement cycle ASC made crystal clear during webinars that the collapsed document could NOT rely on the IRS opinion letter. If I recall they had tried to get the IRS's blessing, but did not. 

So the suggestion was to have the regular fully expanded AA signed as always, and use the collapsed version only as a reference copy. 

For the reason you mention, familiarity, I prefer to use the full adoption agreement, and I prefer sending it to clients. I have seen other TPAs send just the collapsed AA out for signature, which I think is less than ideal, though for an unsophisticated plan sponsor it is definitely easier to read and use.

[austin3515]

You know what I misread our newsletter from them.  I thought it was what you are describing, but thats not it.  All they are saying is that there is one single Adoption Agreeemnt for 401k, PS and MP.  And if you'd like for a MP or PS only plan, you can have a separate adoption agreemetn that hides all of the 401k provisions.

So my misunderstanding.  I do like that option as you described it though.  It would be a nice reference tool especially for external clients (if not for internal purposes).

[Belgarath]

Austin - the FIS document does something like this, albeit in a different format. For the 401(k) plan their system will produce an "index" which lists the employer choices made in the AA, and gives references to the appropriate pages. VERY handy for clients, and a quick reference for the TPA as well - a total of 2 pages. Unfortunately, they don't do this on the 403(b) adoption agreement.

Obviously, no substitute for the full AA, but you can very quickly see most of what you need.

[austin3515]

Agreed, I do use that on occasion.  For some reason though Top-Paid Group election isn;t on there which makes me crazy :).

And interestingly I've been leery of using it for the same reason as stated above (losing familiarity with the AA).  

Anyway, thanks!!

[Belgarath]

Yup, but in my case I'm already crazy, so it doesn't matter. It just doesn't matter!

It just doesn't matter! It just doesn't matter! (Bill Murray in "Meatballs" - one of the better teen Summer Camp style movies ever made.)

Anyway, the index accurately captures most of the stuff that you would typically look at. But of course it doesn't show you what other options may be available, and no explanatory notes,, etc., etc. - however, if a client calls and wants to know what the allocation requirement are for a PS plan or something like that, very handy to have.

[ERISAGirl]

All - I work in ASC Document Support and am normally just a "lurker" on this site, but want to clear up any confusion that may have been caused by a comment made earlier in this post regarding ASC's collapsible AA. I can assure ASC's clients that if they generate a collapsed version of our PPA DC VS PS/401(k), the plan absolutely has reliance on the plan's IRS Advisory letter. The only stipulation, as required by the IRS, is that the ER/Plan Sponsor must also be provided a blank copy of the full, uncollapsed version of the AA so that the ER/Plan Sponsor can see all of the other choices that cannot otherwise be seen in the collapsed AA. 

It may be that there was some confusion between the PPA DC PS/401(k) and the pre-approved 403(b) plans in that the IRS would not permit a collapsed AA for pre-approved 403(b) plans. Therefore, we do not offer a collapsed option for the pre-approved 403(b) plans - not even for internal use only. 

Also, with regard to Cycle 3 DC, the IRS announced late last year that if a collapsed AA will be offered under Cycle 3, a separate IRS opinion letter will be required (whereas under PPA DC, one letter covers both the full and collapsed versions). Due to the large number of our clients that prefer using the collapsed AA, ASC is offering collapsed versions of both our Standardized and Nonstandardized Cycle 3 PS/401(k) plans. 

Thank  you!

[Bird]

Thanks ERISAGirl for clarifying.  I was wondering about that comment.

Our vendor, FTW, has offered an "Answers Only" adoption agreement which seems to be what is being described here.  I kind of get the hesitation about not seeing the full adoption agreement but we've been using the answers only version quite happily for the past...4 (?) years quite happily.  I don't miss the full answers and/but can easily pull up a full answer version easily and do from time to time.