Case Study: Participant Account Remediation

Enterprise Iron Financial Industry Solutions, Inc.
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BUSINESS PROBLEM

Our Client faced the complex challenge of making extensive adjustments to their retirement recordkeeping participant accounts. This highly-sensitive topic encompassed a wide range of scenarios involving active, terminated, and deconverted plans.

Participants in these plans had various statuses, including Active, Retired, Terminated Pending Payout, Terminated and Paid Out, Qualified Domestic Relations Orders (QDRO), and Deceased participants along with their beneficiaries.

Challenges:

1. Incomplete Initial Data: At the project’s inception, our Client did not possess all the necessary data to make the adjustments. This required a dynamic approach to data collection and processing.

2. Changes in Approach and Scope: After many deliberations with counsel, the initial approach changed from sending cash (i.e., issuing checks) to adjusting participant accounts within the recordkeeping system for each impacted plan. This pivot introduced additional complexities:

  • Engaging new record keepers for deconverted plans
  • Creating adjustments for plans that had ceased to exist
  • Managing forfeiture payments, QDRO payments, and payments to beneficiaries of deceased participants

3. Communication Requirements: The Client needed to effectively communicate the adjustments to a diverse audience composed of Plan Advisors, Plan Sponsors, Participants, Beneficiaries, Payees, Relationship Managers, internal employees, and business partners.

Communications had to be precise, targeted, and tailored to the recipient, requiring different media (verbal and written communications, training sessions, Client in-person meetings, conference calls, email and letter correspondence).

OUR SOLUTION

Data Organization and Process Definition: EI meticulously organized the available data and defined a robust process for handling each unique scenario:

  • Modeling every viable adjustment scenario based upon plan and participant status to determine the destination of the adjustments (back to original plan, to a newly issued IRA, to 3rd Parties for Deconverted Plans, etc.) including money sources
  • Creating a comprehensive database to manage the data, status and reconciliation
  • Organizing the business processes to manage various components of the correction lifecycle (e.g., Marketing Communications, Client Relationship Management, Contact Center Services, Operations, Mail and Imaging, etc.)
  • Designing specific transactions to execute the necessary adjustments

Transaction Creation and Mail Merge: EI developed the transactions required to make the adjustments and created extracts for a mail merge process. This facilitated seamless and efficient communication.

Collaborative Communication Strategy: EI collaborated with the Communications Team and the Legal Department to craft a detailed communication plan including:

  • Selecting paper color for physical mailings to facilitate easy identification upon return
  • Ensuring all communications were clear, concise, and compliant with legal requirements

Stakeholder Engagement: Throughout the project, Enterprise Iron worked closely with the Client’s leadership team and project sponsors. This ensured:

  • Full disclosure of progress and challenges
  • All original and additional requirements were addressed and met

Comprehensive Quality Control and Quality Assurance: EI collaborated with Business SMEs and Internal Audit to ensure methodologies and processes were aligned with Client standards and approved prior to engaging external stakeholder:

  • Creating the processes to calculate adjustment values per IRS guidelines
  • Reconciling all transactions to the recordkeeping system and the tracking database
  • Verifying transaction accuracy via internal Quality Control prior to execution and Quality Assurance after execution via Internal Audit

RESULTS & CLIENT BENEFITS

We structured and comprehensive approach enabled the Client to successfully adjust their retirement recordkeeping participant accounts.

The project was completed on-time, according to the original published schedule, with full transparency and compliance, ensuring that all stakeholders were informed and satisfied with the outcomes.

The collaborative efforts between Enterprise Iron and the Client resulted in a smooth transition and effective communication, ultimately enhancing the Client’s operational efficiency and participant satisfaction.

Client Testimonial upon project completion:

The success of this project is in large part due to our partners at Enterprise Iron and wouldn’t have been possible without each of the team members.” – Client Project Manager