403(b) Regulation Requirements

1. Administration & Compliance Service (ACS) to the Rescue!Your Total Remittance and Compliance Solution for 403(b)/457(b) Plans

2. 403(b) Regulation Requirements • Written Plan Document • New Restrictions on tax-free transfers • 90-24 Transfer Modifications • Now called “exchanges” may move to other 403(b) plans within the employers vendor list • New Requirements on the timing of remitting salary reduction contributions • Must be submitted by the 15th day of the month following deduction • Universal availability requiring annual notification

3. Employer Responsibilities • IRS states....public School Districts do not have “fiduciary responsibility” however they do have responsibility for “tracking the information” • IRS Regulations do not require public School District employers to track performance of investments

4. Responsibility (cont.) • ERISA Plans require plan sponsors to perform fiduciary duties • Governmental Plans are exempt from ERISA • Public Schools are exempt from ERISA • The IRS has no authority to create fiduciary responsibility • School Districts do not have fiduciary duties related to 403(b) Programs

5. Vendor Selection Responsibility • None • ACS will accept any/all vendors that adhere to established requirements • Limiting vendors may increase employer liability and create unnecessary employee discontent/confrontation

6. Participating Vendors • All vendors that sign required Information Sharing, Hold Harmless, and Compliance Agreements • All vendors that agree to share information electronically in accordance with data privacy practices • All vendors that agree to share in costs associated with processing

7. ACS Features • Educators Benefit Consultants is a Third Party Administrator specializing in the compliance needs of Public Sector employers administering 403(b)/457(b) plans. We call this service the Administration and Compliance Service (ACS).

8. Simplified Plan Administration • Data goes from District payroll system into ACS database • Contribution reports are produced automatically • Reports are reviewed and reconciled on secure website • Reports are submitted electronically to each vendor • Single payment remitted electronically from District to ACS

9. ACS-Services • Coordinate Vendor Information Sharing Agreements • Remit all contributions to respective vendors • One Payment to ACS • Hold Harmless Agreements with Vendors • Compliance Notices • Minimum distribution requirements communicated to participants • Provide Written Plan Document • Documents reviewed for Federal and State compliance

10. ACS-Services (cont.) • Keep Districts apprised of new compliance and legal requirements and upgrade system accordingly • Provide template for annual “Universal Eligibility” notice

11. Website Features • Secure Website Access • Webpage with participating vendors and links to those vendors • Universal Salary Reduction Agreement • Downloadable • Employer access to contribution and transaction history

12. Website Features (continued) • Payroll login • Upload contribution file • Report printing and reconciliation • Able to track loans, transfer and hardship withdrawals • Access to historical data for limits • ACH transfer to one source

13. ACS Pricing Proposed pricing standard may be subject to change

14. Why ACS? • Simplified Plan Administration • Licensed Third Party Administration • Multiple Vendors Available • Maintain employee satisfaction • Low cost solution for District • Ongoing Compliance

15. 403(b) Admin & Compliance Service • 263 Employer Groups • 261 Public Schools • 33,186 Participants

16. Questions • Derrick Nelson • 763-689-0111 • 855-369-5518 • derrick@ebcsolutions.com • Paige McNeal • 763-552-6053 • 888-507-6053 • paigep@ebcsolutions.com

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