403b Documents New IRS preapproved documents now available Restatement deadline to get retroactive reliance is March 31 2020 Retroactive effective dates as early as 112010 can be used Custom effective date and custom language attachments with retroactive effective dates ID: 727248
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403(b) DOCUMENT UPDATE
Presented By: Christine LeBlancSlide2
403(b) Documents
New IRS pre-approved documents now available
Restatement deadline to get retroactive reliance is March
31,
2020
Retroactive effective dates as early as 1/1/2010 can be used
Custom effective date and custom language attachments with retroactive effective datesSlide3
403(b) Documents
New service provider attachment
Approved vendors
Un-approved vendors
Service providers
Plan
sponsor dutiesSlide4
403(b) Documents
Restatement Deadline
March
31, 2020
If document was amended timely for final regulations then plan may have retroactive reliance back to 2010.
All provisions must be documented in some form
Interim amendments
Special effective date addendumSlide5
403(b) Documents
5 types
ERISA for 501(c)(3) Organizations
Non-ERISA Deferral Only for 501(c)(3) Organizations
Non-ERISA for Governmental Organizations
Non-ERISA for Churches without RIA
Non-ERISA for Churches with RIASlide6
403(b) Documents
ERISA for 501(c)(3) Organizations
Robust document intended to provide maximum flexibility
Contribution Types Included
deferrals – pre-tax and Roth
voluntary after-tax
mandatory - after-tax and pre-tax
matching contributions
n
on-elective contributions
r
ollover contributionsSlide7
403(b) Documents
ERISA for 501(c)(3) Organizations
Other Provisions
ACP Safe Harbor
Auto-Enrollment – ACA, EACA, QACA
Integrated, Age Weighted, and Cross-Tested Non-Elective ContributionsSlide8
403(b) Documents
ERISA for 501(c)(3) Organizations
Testing Provisions
Designed to be Universal Availability compliant
All ERISA language included
ACP testing elections included
410(b) failure language includedSlide9
403(b) Documents
Non-ERISA 403(b) Deferral Only for 501(c)(3) Organizations
Designed to be used by a 501(c)(3) organization that intends to meet the DOL safe harbor of limited employer involvement under
29
C.F.R
. section 2510.3-2(f)
Contributions Types include
Deferrals – pre-tax and Roth
Voluntary after-tax
r
ollover contributionsSlide10
403(b) Documents
Non-ERISA 403(b) Deferral Only for 501(c)(3) Organizations
Does not include
Matching or non-elective contributions
Safe harbor provisions
Automatic enrollment
Vesting provisionsSlide11
403(b) Documents
Non-ERISA for Governmental and Church Employers
Robust document intended to provide maximum flexibility
Contribution Types Included
deferrals – pre-tax and Roth
voluntary after-tax
mandatory - after-tax and pre-tax
matching contributions
n
on-elective contributions
r
ollover contributionsSlide12
403(b) Documents
Non-ERISA for Governmental and Church Employers
Other Provisions
Auto-Enrollment – ACA
Integrated Non-Elective Contributions
Not Included
Safe Harbor
Auto-Enrollment – EACA, QACA
Age-Weighted and Cross-Tested Non-Elective ContributionsSlide13
403(b) Documents
Non-ERISA for Church Employers
Steeple Church
Qualified Church Controlled Employers
Retirement Income Account
Not subject to Universal Availability