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403(b) FINAL REGULATIONS
COMPLIANCE REMINDER
As
you are likely aware, beginning January 1, 2009, your school
district's 403(b) plan must comply with Internal Revenue Service
final regulations. If your school district has not already
begun to do so, we strongly recommend that your school district take
the following steps:
·
Implement
written plan document(s) before year end that comply with the new
regulations. If your 403(b)
plan already has a written plan document, it should be reviewed for
compliance with the final regulations (and amended, if necessary).
·
In connection
with this review, it is prudent to review who is excluded from your
403(b) plan to ensure compliance with 403(b) "universal
availability" requirements.
·
Also in
connection with this review, consider which optional 403(b)
provisions you want to make available to participants (e.g. Roth
contributions, loans, hardship distributions, catch-up contributions,
etc.).
·
Make sure that
there are signed Information Sharing Agreements in place with each
approved vendor/provider under your 403(b) plan.
·
Consider
operational compliance and how plan functions will be handled (e.g.
monitoring contribution limits, loan, hardship withdrawals,
distributions, etc.).
If you would
like any additional information or would like assistance with
bringing your 403(b) plan into compliance with the final regulations,
please contact:
·
Edward C.
Hammond at (248) 988-1821 - ehammond@clarkhill.com
·
James M. Crowley at (248) 988-5851 - jcrowley@clarkhill.com
·
Kristi R. Gauthier at (248) 988-5854 - kgauthier@clarkhill.com
·
John P. Schneider at (616) 608-1108 - jschneider@clarkhill.com
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