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My school district has drafted a 403(b) plan document. That document is being evaluated by Gallagher Benefit Service. I have reviewed GBS's S.E.C. filings. According to SEC Form ADV Schedule F "...GBS only acts as a solicitor for NFP...". That led me to an arrangement that GBS has with NFP Securities. That led me to NFP Securities. NFP's modus operandi is inconsistent with my standards for investment vehicles. Having been present at the SD's 403(b) committee meetings I am satisfied that this type of opaque, heavily expensed scheme will be the only option available to plan participants.

With that as background, I have stopped contributions and do not anticipate participation in the SD's 403(b) plan. I would like to get out of this plan without triggering a taxable event or incurring a penalty, however, mindful of the issues attending ISA and HH Agreements this may not be an option. With this in mind, a committee member suggested to me that I provide the committee with the language necessary to affect this outcome.

What can be suggested in this regard?

Does IRS Bulletin 2002-2 I.R.B. (Safe Harbor Explanation) have any bearing on this circumstance?

mhc

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Unless you have experienced a distributable event, your money will have to remain with an approved vendor.

 

Setting aside the bias of the decision makers, your 403b plan can have multiple vendors. NFP does not have to be the only investment option. The committee should consider including low cost investment options.

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Unless you have experienced a distributable event, your money will have to remain with an approved vendor.

 

Setting aside the bias of the decision makers, your 403b plan can have multiple vendors. NFP does not have to be the only investment option. The committee should consider including low cost investment options.

 

 

Mr. fishermh,

Thank you for your response.

Unfortunately TRP will not be one of the approved vendors in this plan. If my money must remain in the plan until I experience a distributable event and I choose not to select a vendor in the menu of options and I stop contributions (which I have done), what options remain?

My concern is that my account will somehow be swept up in this scheme. It occurs to me that there is the possibility that the vendor(s) selected by the SD may offer TRP and that I will somehow be forced to be an active participant whether I want to or not. If a TPA and the vendor(s) offered insinuate themselves between me and my money, will I still be required to pay the anticipated (and higher) fees associated with this SD plan even if I do not make any contributions? Is this a ligitimate concern?

Additionally:

A review of Gallagher's SEC filing states that "GBS will typically receives up to 95% of the advisory management fee paid by the client to NFP". That appears to be something of a conflict of interest.

A review of NFP's FINRA filing shows several regulatory actions resulting in fines and censures. That appears to be a violation of fiduciary duty and trust.

I am not especially well informed as to how to interpret these details. These items strike me as a cause for concern. Am I correct in this view?

Thank you.

mhc

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Has the SD signed a contract with Gallagher? Has the SD signed the plan document?

 

I have no specific experience with Gallagher/NFP, and therefore cannot confirm or disagree with your facts. I can tell you that any allegations of breach of fiduciary duty should be considered troublesome. Non-ERISA 403(b) plans don't create fiduciary duty issues, but the same types of concerns are going to be reflected in state securities, insurance and fraud laws. Particularly worrisome would be claims that the TPA was unjustly enriched in some way, to the detriment of participants. Is it possible to determine the details on the charges and whether the charges are legitimate? It is certainly appropriate to bring them to the attention of the SD and the union (if you have one) an request further inquiry.

 

As to your basic concerns, I'm not sure what you mean by "this type of opaque, heavily expensed scheme." Costs are going to go up somewhat because there is a whole new level of activity oriented towards legal compliance that has been ignored in the past, this compliance is in the context of a very complex set of investment options that do not now even collect all the information that is needed (let alone make it available to any central compliance function), and this costs money. In the context of mutual fund-based programs, it is normally possible to cut through the opacity if you know how to do it; because annuities are inherently not transparent, figuring out their relationships and economics is often harder.

 

As to your specific question about getting your current funds out of the system, this is still allowed, if the plan allows for it and the recipient investment provider jumps through a couple of hoops. Those hoops are (1) restrict distributions to those permitted under the transferring funding vehicle, and (2) enter into a cooperation/data sharing agreement. I have a plan document that I am about to release that automatically provides for such transfers, and can provide the appropriate language, but it would have to conform to the language of the overall plan document and be implemented as an amendment to that document (if it has been adopted).

 

For whatever it's worth, you're not alone. Lots of SDs are going to make bad decisions and lots of participants are going to feel at a loss. I actually believe that there will be a massive shift of providers before the final regulations go into effect, followed by a secondary, but still massive, shift when employers and participants have better capacity to understand and compare service offerings, providers and pricing.

 

Should have said this in the last response.

 

Do you have a 457 available? You could use a 457 to substitute for the 403(b) as to future contributions. Setting up and administering a 347 is simpler and cheaper than setting up a 403(b). Most TPA s avoid them because they are weird to those used to qualified plans and 403(b)s, but there are 457 solutions out there and that is another product we are about to announce.

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Has the SD signed a contract with Gallagher? Has the SD signed the plan document?

 

I have no specific experience with Gallagher/NFP, and therefore cannot confirm or disagree with your facts. I can tell you that any allegations of breach of fiduciary duty should be considered troublesome. Non-ERISA 403(b) plans don't create fiduciary duty issues, but the same types of concerns are going to be reflected in state securities, insurance and fraud laws. Particularly worrisome would be claims that the TPA was unjustly enriched in some way, to the detriment of participants. Is it possible to determine the details on the charges and whether the charges are legitimate? It is certainly appropriate to bring them to the attention of the SD and the union (if you have one) an request further inquiry.

 

As to your basic concerns, I'm not sure what you mean by "this type of opaque, heavily expensed scheme." Costs are going to go up somewhat because there is a whole new level of activity oriented towards legal compliance that has been ignored in the past, this compliance is in the context of a very complex set of investment options that do not now even collect all the information that is needed (let alone make it available to any central compliance function), and this costs money. In the context of mutual fund-based programs, it is normally possible to cut through the opacity if you know how to do it; because annuities are inherently not transparent, figuring out their relationships and economics is often harder.

 

As to your specific question about getting your current funds out of the system, this is still allowed, if the plan allows for it and the recipient investment provider jumps through a couple of hoops. Those hoops are (1) restrict distributions to those permitted under the transferring funding vehicle, and (2) enter into a cooperation/data sharing agreement. I have a plan document that I am about to release that automatically provides for such transfers, and can provide the appropriate language, but it would have to conform to the language of the overall plan document and be implemented as an amendment to that document (if it has been adopted).

 

For whatever it's worth, you're not alone. Lots of SDs are going to make bad decisions and lots of participants are going to feel at a loss. I actually believe that there will be a massive shift of providers before the final regulations go into effect, followed by a secondary, but still massive, shift when employers and participants have better capacity to understand and compare service offerings, providers and pricing.

 

Should have said this in the last response.

 

Do you have a 457 available? You could use a 457 to substitute for the 403(b) as to future contributions. Setting up and administering a 347 is simpler and cheaper than setting up a 403(b). Most TPA s avoid them because they are weird to those used to qualified plans and 403(b)s, but there are 457 solutions out there and that is another product we are about to announce.

 

 

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Has the SD signed a contract with Gallagher? Has the SD signed the plan document?

 

I have no specific experience with Gallagher/NFP, and therefore cannot confirm or disagree with your facts. I can tell you that any allegations of breach of fiduciary duty should be considered troublesome. Non-ERISA 403(b) plans don't create fiduciary duty issues, but the same types of concerns are going to be reflected in state securities, insurance and fraud laws. Particularly worrisome would be claims that the TPA was unjustly enriched in some way, to the detriment of participants. Is it possible to determine the details on the charges and whether the charges are legitimate? It is certainly appropriate to bring them to the attention of the SD and the union (if you have one) an request further inquiry.

 

As to your basic concerns, I'm not sure what you mean by "this type of opaque, heavily expensed scheme." Costs are going to go up somewhat because there is a whole new level of activity oriented towards legal compliance that has been ignored in the past, this compliance is in the context of a very complex set of investment options that do not now even collect all the information that is needed (let alone make it available to any central compliance function), and this costs money. In the context of mutual fund-based programs, it is normally possible to cut through the opacity if you know how to do it; because annuities are inherently not transparent, figuring out their relationships and economics is often harder.

 

As to your specific question about getting your current funds out of the system, this is still allowed, if the plan allows for it and the recipient investment provider jumps through a couple of hoops. Those hoops are (1) restrict distributions to those permitted under the transferring funding vehicle, and (2) enter into a cooperation/data sharing agreement. I have a plan document that I am about to release that automatically provides for such transfers, and can provide the appropriate language, but it would have to conform to the language of the overall plan document and be implemented as an amendment to that document (if it has been adopted).

 

For whatever it's worth, you're not alone. Lots of SDs are going to make bad decisions and lots of participants are going to feel at a loss. I actually believe that there will be a massive shift of providers before the final regulations go into effect, followed by a secondary, but still massive, shift when employers and participants have better capacity to understand and compare service offerings, providers and pricing.

 

Should have said this in the last response.

 

Do you have a 457 available? You could use a 457 to substitute for the 403(b) as to future contributions. Setting up and administering a 347 is simpler and cheaper than setting up a 403(b). Most TPA s avoid them because they are weird to those used to qualified plans and 403(b)s, but there are 457 solutions out there and that is another product we are about to announce.

 

 

 

 

Has the SD signed a contract with Gallagher? Has the SD signed the plan document?

 

I have no specific experience with Gallagher/NFP, and therefore cannot confirm or disagree with your facts. I can tell you that any allegations of breach of fiduciary duty should be considered troublesome. Non-ERISA 403(b) plans don't create fiduciary duty issues, but the same types of concerns are going to be reflected in state securities, insurance and fraud laws. Particularly worrisome would be claims that the TPA was unjustly enriched in some way, to the detriment of participants. Is it possible to determine the details on the charges and whether the charges are legitimate? It is certainly appropriate to bring them to the attention of the SD and the union (if you have one) an request further inquiry.

 

As to your basic concerns, I'm not sure what you mean by "this type of opaque, heavily expensed scheme." Costs are going to go up somewhat because there is a whole new level of activity oriented towards legal compliance that has been ignored in the past, this compliance is in the context of a very complex set of investment options that do not now even collect all the information that is needed (let alone make it available to any central compliance function), and this costs money. In the context of mutual fund-based programs, it is normally possible to cut through the opacity if you know how to do it; because annuities are inherently not transparent, figuring out their relationships and economics is often harder.

 

As to your specific question about getting your current funds out of the system, this is still allowed, if the plan allows for it and the recipient investment provider jumps through a couple of hoops. Those hoops are (1) restrict distributions to those permitted under the transferring funding vehicle, and (2) enter into a cooperation/data sharing agreement. I have a plan document that I am about to release that automatically provides for such transfers, and can provide the appropriate language, but it would have to conform to the language of the overall plan document and be implemented as an amendment to that document (if it has been adopted).

 

For whatever it's worth, you're not alone. Lots of SDs are going to make bad decisions and lots of participants are going to feel at a loss. I actually believe that there will be a massive shift of providers before the final regulations go into effect, followed by a secondary, but still massive, shift when employers and participants have better capacity to understand and compare service offerings, providers and pricing.

 

Should have said this in the last response.

 

Do you have a 457 available? You could use a 457 to substitute for the 403(b) as to future contributions. Setting up and administering a 347 is simpler and cheaper than setting up a 403(b). Most TPA s avoid them because they are weird to those used to qualified plans and 403(b)s, but there are 457 solutions out there and that is another product we are about to announce.

 

 

 

 

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Has the SD signed a contract with Gallagher? Has the SD signed the plan document?

 

I have no specific experience with Gallagher/NFP, and therefore cannot confirm or disagree with your facts. I can tell you that any allegations of breach of fiduciary duty should be considered troublesome. Non-ERISA 403(b) plans don't create fiduciary duty issues, but the same types of concerns are going to be reflected in state securities, insurance and fraud laws. Particularly worrisome would be claims that the TPA was unjustly enriched in some way, to the detriment of participants. Is it possible to determine the details on the charges and whether the charges are legitimate? It is certainly appropriate to bring them to the attention of the SD and the union (if you have one) an request further inquiry.

 

As to your basic concerns, I'm not sure what you mean by "this type of opaque, heavily expensed scheme." Costs are going to go up somewhat because there is a whole new level of activity oriented towards legal compliance that has been ignored in the past, this compliance is in the context of a very complex set of investment options that do not now even collect all the information that is needed (let alone make it available to any central compliance function), and this costs money. In the context of mutual fund-based programs, it is normally possible to cut through the opacity if you know how to do it; because annuities are inherently not transparent, figuring out their relationships and economics is often harder.

 

As to your specific question about getting your current funds out of the system, this is still allowed, if the plan allows for it and the recipient investment provider jumps through a couple of hoops. Those hoops are (1) restrict distributions to those permitted under the transferring funding vehicle, and (2) enter into a cooperation/data sharing agreement. I have a plan document that I am about to release that automatically provides for such transfers, and can provide the appropriate language, but it would have to conform to the language of the overall plan document and be implemented as an amendment to that document (if it has been adopted).

 

For whatever it's worth, you're not alone. Lots of SDs are going to make bad decisions and lots of participants are going to feel at a loss. I actually believe that there will be a massive shift of providers before the final regulations go into effect, followed by a secondary, but still massive, shift when employers and participants have better capacity to understand and compare service offerings, providers and pricing.

 

Should have said this in the last response.

 

Do you have a 457 available? You could use a 457 to substitute for the 403(b) as to future contributions. Setting up and administering a 347 is simpler and cheaper than setting up a 403(b). Most TPA s avoid them because they are weird to those used to qualified plans and 403(b)s, but there are 457 solutions out there and that is another product we are about to announce.

 

 

Thank you for your response. The "hoops" part of your note has my interest. Can you explain? Is there language that could be included in the plan document that would allow current participants to get out of the system without penalty?

The plan document here has not yet been approved by the board. It is a Draft Plan Document. There is a public Q&A scheduled for this week regarding that draft plan document.

I do not know if the SD has signed a contract with GBS.

 

 

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The rules contemplate two kinds of funding vehicles under a single plan, vehicles eligible to receive contributions and vehicles not eligible. An investment vehicle that is not eligible to receive contributions can be available to receive asset transfers. The regulations on the requirements for transfwers within a plan require:

 

"Requirements for contract exchange within the same plan--(i) General rule.

A section 403(b) contract of a participant or beneficiary may be exchanged under paragraph (b)(1) of this section for another section 403(b) contract of that participant or beneficiary under the same section 403(b) plan if each of the following conditions are met: (A) The plan under which the contract is issued provides for the exchange.

(B) The participant or beneficiary has an accumulated benefit immediately after the exchange that is at least equal to the accumulated benefit of that participant or beneficiary immediately before the exchange (taking into account the accumulated 115 benefit of that participant or beneficiary under both section 403(b) contracts immediately before the exchange).

© The other contract is subject to distribution restrictions with respect to the participant that are not less stringent than those imposed on the contract being exchanged, and the employer enters into an agreement with the issuer of the other contract under which the employer and the issuer will from time to time in the future provide each other with the following information: (1) Information necessary for the resulting contract, or any other contract to which contributions have been made by the employer, to satisfy section 403(b), including information concerning the participant’s employment and information that takes into account other section 403(b) contracts or qualified employer plans (such as whether a severance from employment has occurred for purposes of the distribution restrictions in §1.403(b)-6 and whether the hardship withdrawal rules of §1.403(b)- 6(d)(2) are satisfied).

(2) Information necessary for the resulting contract, or any other contract to which contributions have been made by the employer, to satisfy other tax requirements (such as whether a plan loan satisfies the conditions in section 72(p)(2) so that the loan is not a deemed distribution under section 72(p)(1)).

(ii) Accumulated benefit. The condition in paragraph (b)(2)(i)(B) of this section is satisfied if the exchange would satisfy section 414(l)(1) if the exchange were a transfer of assets.

(iii) Authority for future guidance. Subject to such conditions as the Commissioner determines to be appropriate, the Commissioner may issue rules of 116 general applicability, in revenue rulings, notices, or other guidance published in the Internal Revenue Bulletin (see § 601.601(d)(2)(ii)(b) of this chapter), permitting an exchange of one section 403(b) contract for another section 403(b) contract for an exchange that does not satisfy paragraph (b)(2)(i)© of this section. Any such rules must require the resulting contract to set forth procedures that the Commissioner determines are reasonably designed to ensure compliance with those requirements of section 403(b) or other tax provisions that depend on either information concerning the participant’s employment or information that takes into account other section 403(b) contracts or other employer plans (such as whether a severance from employment has occurred for purposes of the distribution restrictions in §1.403(b)-6, whether the hardship withdrawal rules of §1.403(b)-6(d)(2) are satisfied, and whether a plan loan constitutes a deemed distribution under section 72(p))."

 

This is not a perfect solution. It does not save you from per-person fees or plan-level fees passed on by the SD. It does reduce the effect of any asset-based fees by removing them from the fee base.

 

There are three reasons a plan might avoid this kind of transfer. First, reduced asset fees may impact the economics of the plan, by reducing fees paid to the TPA or by reducing an offset by the plan that reduces employer-paid or employee-paid fees. Second, the employer or the TPA might want to avoid extra hassle involved in having a second list of transfer-eligible investments. Third, the recipient vehicle's issuer may not want to agree to the data sharing/coordination commitments quoted above.

 

There is a fourth reason the idea might not be accepted, which is that it is unusual. Employers and service providers are pretty confused about what they can and cannot do, and most are simply looking for a viable "groove" that will avoid problems, not for (too?) novel and exciting ways to empower participants.

 

If these can be resolved, the plan language would read something like:

 

The plan/employer/administrator may at any time and from time to time designate additional Funding Vehicles/Investments/Permitted Investments/Vendors/Issuers/Providers as inelgible to receive contributions but eligible to receive transfers within the Plan under Regs. Section 1.403(b)-10(b)(2). Transfers under this provision will be permitted only if the Funding Vehicle/Investment/PermittedInvestment/Vendor/Issuer/Provider agrees to comply iwith the requirements of Regs. Section 1.403(b)-10(b)(2))1)(B) and ©.

 

The drafter might want to expand on the references to the regulations, and the terminology might need modified somewhat.

 

I just finished a clinet project today to review the document form for a plan documents provider, and it was pretty awful. No understanding of ERISA v. non-ERISA, poor coordination between plan terms and funding vehicle terms, didn't take into account potential withdrawal fees and the like, and permitted contributions exceeding the 403(b) limits by having bad definitions. I stopped at the end of the definition, because the exercise had become pointless. I'd like to see the form your SD is looking at, and may be able to zing it or to better suggest how to modify it.

 

I am coming out with a plan document that will be finalized this week (not necessarily by Thursday, though). So I have an ulterior motive, to assess the quality of the competition, for looking at the document. I am happy about the progress of my document, other than cross-references, consistent use of terminology and readability, and have a way to prove what my documents say now, so I am not worried about plagiarism-type charges.

 

Tom Geer

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The rules contemplate two kinds of funding vehicles under a single plan, vehicles eligible to receive contributions and vehicles not eligible. An investment vehicle that is not eligible to receive contributions can be available to receive asset transfers. The regulations on the requirements for transfwers within a plan require:

 

"Requirements for contract exchange within the same plan--(i) General rule.

A section 403(b) contract of a participant or beneficiary may be exchanged under paragraph (b)(1) of this section for another section 403(b) contract of that participant or beneficiary under the same section 403(b) plan if each of the following conditions are met: (A) The plan under which the contract is issued provides for the exchange.

(B) The participant or beneficiary has an accumulated benefit immediately after the exchange that is at least equal to the accumulated benefit of that participant or beneficiary immediately before the exchange (taking into account the accumulated 115 benefit of that participant or beneficiary under both section 403(b) contracts immediately before the exchange).

© The other contract is subject to distribution restrictions with respect to the participant that are not less stringent than those imposed on the contract being exchanged, and the employer enters into an agreement with the issuer of the other contract under which the employer and the issuer will from time to time in the future provide each other with the following information: (1) Information necessary for the resulting contract, or any other contract to which contributions have been made by the employer, to satisfy section 403(b), including information concerning the participant’s employment and information that takes into account other section 403(b) contracts or qualified employer plans (such as whether a severance from employment has occurred for purposes of the distribution restrictions in §1.403(b)-6 and whether the hardship withdrawal rules of §1.403(b)- 6(d)(2) are satisfied).

(2) Information necessary for the resulting contract, or any other contract to which contributions have been made by the employer, to satisfy other tax requirements (such as whether a plan loan satisfies the conditions in section 72(p)(2) so that the loan is not a deemed distribution under section 72(p)(1)).

(ii) Accumulated benefit. The condition in paragraph (b)(2)(i)(B) of this section is satisfied if the exchange would satisfy section 414(l)(1) if the exchange were a transfer of assets.

(iii) Authority for future guidance. Subject to such conditions as the Commissioner determines to be appropriate, the Commissioner may issue rules of 116 general applicability, in revenue rulings, notices, or other guidance published in the Internal Revenue Bulletin (see § 601.601(d)(2)(ii)(b) of this chapter), permitting an exchange of one section 403(b) contract for another section 403(b) contract for an exchange that does not satisfy paragraph (b)(2)(i)© of this section. Any such rules must require the resulting contract to set forth procedures that the Commissioner determines are reasonably designed to ensure compliance with those requirements of section 403(b) or other tax provisions that depend on either information concerning the participant’s employment or information that takes into account other section 403(b) contracts or other employer plans (such as whether a severance from employment has occurred for purposes of the distribution restrictions in §1.403(b)-6, whether the hardship withdrawal rules of §1.403(b)-6(d)(2) are satisfied, and whether a plan loan constitutes a deemed distribution under section 72(p))."

 

This is not a perfect solution. It does not save you from per-person fees or plan-level fees passed on by the SD. It does reduce the effect of any asset-based fees by removing them from the fee base.

 

There are three reasons a plan might avoid this kind of transfer. First, reduced asset fees may impact the economics of the plan, by reducing fees paid to the TPA or by reducing an offset by the plan that reduces employer-paid or employee-paid fees. Second, the employer or the TPA might want to avoid extra hassle involved in having a second list of transfer-eligible investments. Third, the recipient vehicle's issuer may not want to agree to the data sharing/coordination commitments quoted above.

 

There is a fourth reason the idea might not be accepted, which is that it is unusual. Employers and service providers are pretty confused about what they can and cannot do, and most are simply looking for a viable "groove" that will avoid problems, not for (too?) novel and exciting ways to empower participants.

 

If these can be resolved, the plan language would read something like:

 

The plan/employer/administrator may at any time and from time to time designate additional Funding Vehicles/Investments/Permitted Investments/Vendors/Issuers/Providers as inelgible to receive contributions but eligible to receive transfers within the Plan under Regs. Section 1.403(b)-10(b)(2). Transfers under this provision will be permitted only if the Funding Vehicle/Investment/PermittedInvestment/Vendor/Issuer/Provider agrees to comply iwith the requirements of Regs. Section 1.403(b)-10(b)(2))1)(B) and ©.

 

The drafter might want to expand on the references to the regulations, and the terminology might need modified somewhat.

 

I just finished a clinet project today to review the document form for a plan documents provider, and it was pretty awful. No understanding of ERISA v. non-ERISA, poor coordination between plan terms and funding vehicle terms, didn't take into account potential withdrawal fees and the like, and permitted contributions exceeding the 403(b) limits by having bad definitions. I stopped at the end of the definition, because the exercise had become pointless. I'd like to see the form your SD is looking at, and may be able to zing it or to better suggest how to modify it.

 

I am coming out with a plan document that will be finalized this week (not necessarily by Thursday, though). So I have an ulterior motive, to assess the quality of the competition, for looking at the document. I am happy about the progress of my document, other than cross-references, consistent use of terminology and readability, and have a way to prove what my documents say now, so I am not worried about plagiarism-type charges.

 

Tom Geer

 

 

Tom,

Thank you for your information.

As I understand it then, the bottom line is:

-I cannot leave the SD 403b plan unless I experience an event (separation from employment, 59 1/2, etc.). (Were this to occur I could "rollover" out of the plan to an IRA).

-That leaves 3 options: 1. transfer to a plan approved vendor and continue to contribute, 2. transfer to a plan approved vendor and stop contributions, or 3. leave the funds where they are with an unapproved vendor and make no contributions.

-If I choose to leave the funds where they are, I may be able to affect a transfer to an unapproved vendor if, for example, your "model" language were adopted by the SD and included in the plan document. Under this arrangement I would not be allowed to make contributions.

Would this mitigate the expenses I anticipate?

 

The plan document is in draft form, is part of a public record, and can be accessed at:

http://www.billingsschools.org/staff-resources.htm

 

mhc

 

 

 

 

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