BUSINESS PROBLEM
Our Client, a prominent recordkeeper serving various retirement industry providers with diverse retirement plan options, faced obstacles with delivery of plan amendments due to staffing challenges.
The Client provided plan sponsors with the “Good Faith” CARES / SECURE Acts Interim Amendment (CSIA) to document plans compliance applicable under the following regulatory laws:
- Bipartisan American Miners Act of 2019 (“Miners Act”)
- Consolidated Appropriations Act of 2021 (“CAA”)
- Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”)
- COVID-Related Tax Relief Act of 2020 (“CRTRA”)
- Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”)
- Taxpayer Certainty and Disaster Tax Relief Act of 2019 (“Disaster Tax Relief Act of 2019”)
- Taxpayer Certainty and Disaster Tax Relief Act of 2020 (“Disaster Tax Relief Act of 2020”)
A significant number of plans elected to operate under the CSIA default elections, while other plans elected to override the defaults. These options provided a set of challenges with tracking elections and effective dates without a written CSIA amendment to the plan document reflecting the applicable provisions.
An added risk was that plan sponsors could recollect past sunset provisions and if they were accurately administering the plan under chosen elections without a formal “Good Faith” amendment to the plan document.
EI’s Client intention was to provide plan sponsors with the CARES / SECURE Acts Interim Amendment to approximately 2400 plans on the Cycle 3 Pre-Approved Plan document.
Approximately 250 custom CARES / SECURE Acts Interim Amendments required signatures.
The added scope of sending out the amendments presented the Client with challenges due to the volume of plans, current resources, and staffing models.
OUR SOLUTION
EI’s Retirement Plan Compliance Services (RPCS) resolved the Client’s issues by:
1. Providing a fixed cost predicted model
- Applying a fixed cost predicted model, cost stays the same, no surprises!
2. Rapidly assembling and deploying an experienced, and fully remote RPCS team
- Project managers and team leaders
- Document generation and system experts
- Retirement plan compliance experts
- Experienced plan document consultants
3. Creating strategic and tactical processes and roadmaps
- Collecting data from the Client with plan volume and plan sponsors CSIA elections
- Preparing the CSIA packages, including updating the recordkeeping system for certain elected provisions
- Drafting specific CSIA Interim Amendment procedures
- Forecasting delivery and predicted plan/sponsor/”if applicable” signer execution
- Delivering critical communications to stakeholders
4. Resolving challenges in real-time. Processes and workarounds were created to quickly resolve significant project management and data challenges that periodically arose throughout the engagement
- Analyzing data provided by vendor to identify and prioritize CSIAs that required signatures
- Reviewing the CSIA amendment system generation for validation errors and remediating discrepancies
- Accommodating midstream scope changes such as updating contacts and/or authorized signers, thereby relieving the amendment volume on Client’s existing plan design team
5. Performing quality review and archiving results, as well as a comprehensive archiving and clean-up
- Executing a thorough quality control review of documents loaded to Client platforms
- Publishing/archiving all CSIA amendments and Summary Plan Descriptions (SPD)
- Updating and completing relevant processes and procedure documents as leave behinds for our Client
RESULTS & CLIENT BENEFITS
Our RPCS Team successfully prepared and sent all CSIA packages to plan sponsors in a prompt fashion.
For amendments that required signatures we achieved an overall signature rate of 98%.
Our Client received positive feedback from their customers, thereby enhancing their reputation and goodwill within the industry.
Our Client retained a repository of written and tested procedures to leverage for future projects.
Client Testimonial upon project completion:
“We didn’t wait to do CSIA interim amendment because many small business clients do not document what they did during that period. The Enterprise Iron Team stepped in and was able to take our data, complete actual amendments for those plans that did not elect some of our defaults and get the interim amendments out for signature (and back) before the deadline was extended. Couldn’t get it done with existing resources who were stretched with the “normal” day to day activities. They are a wonderful team of experts and love working with them.”