Jennifer D. Posted November 15, 2022 Posted November 15, 2022 Hi all: I have a client who we are taking over from a prior TPA. They have a retirement plan as well as a SUB (supplemental unemployment benefit) plan. The client is a prevailing wage client (long story short the fringe is what funds the SUB plan). Because it is a SUB plan they file a 5500 for it, but they have not been able to get a copy of their plan document or SPD - instead their prior TPA keeps giving them a copy of their 125 plan. My understanding was that a SUB plan needs to have a separate document. Even if I was going to correct that for them with the IRS, I have no idea where to start in getting a SUB plan document - aka I have no idea which companies provide this specialized plan document that isn't a TPA. So, my questions are, does a SUB Plan Document need to be separate from a traditional cafeteria plan document, and does anyone know of a document provider I could use to draft a SUB plan document?
Bob the Swimmer Posted November 16, 2022 Posted November 16, 2022 I have seen separate documents for this done by consultants or law firms . I would start with one of the large volume document providers or a good ERISA law firm. Luke Bailey 1
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