khn Posted November 10, 2017 Posted November 10, 2017 If a plan has Employer Nonelective Contributions for union employees only, does it need to be in the SPD or it okay for this contribution to only be addressed in the Collective Bargaining Agreement? The employer doesn't want the whole employee population to know that the union match is more than theirs.
Doghouse Posted November 10, 2017 Posted November 10, 2017 Many times I see different SPD's provided to different populations - such as when different nonelective contributions are provided to different allocation groups. The provision should probably be addressed in the CB version though. khn 1
Peter Gulia Posted November 13, 2017 Posted November 13, 2017 Here's a link to the Labor department's rule about different SPDs for different classes of participants: https://www.ecfr.gov/cgi-bin/text-idx?SID=61b245fa37ff49f3c1733d64e32ca6d5&mc=true&node=se29.9.2520_1102_64&rgn=div8 29 C.F.R. § 2520.102-4. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
My 2 cents Posted November 13, 2017 Posted November 13, 2017 That makes a lot of sense. How could it possibly be required to tell people that if they were in a different class of participants they would receive more generous benefits? How can you do that without adversely affecting morale? I cannot remember the exact situation, but I am pretty sure that I knew of a union plan/non-union plan situation where the non-union people got bigger benefits. Don't want to be waiving that in front of the union people! Always check with your actuary first!
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now