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.
Providing plan sponsors with the “Good Faith” CARES / SECURE Acts Interim Amendment (CSIA) amendment to document plans compliance applicable under the following regulatory laws:
- Bipartisan American Miners Act 0f 2019 (“Miners Act”)
- Consolidated Appropriations Act, 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”)
Some plans elected to operate under the CSIA default elections, while other plans elected to override the defaults. This 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 additional concern is if plan sponsors can recollect past sunset provisions and if they are accurately administering the plan under chosen elections without a formal “Good Faith” amendment to the plan document.
EI’s Client intention is 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 requiring signatures.
The scope of sending out the amendments presented the Client with challenges due to the volume of plans, current resources, and staffing models.
OUR SOLUTION
Our Retirement Plan Compliance Services (RPCS) Team, was able to:
1. Provide a fixed cost predicted model:
- Using the fixed cost predicted model, cost stays the same, no surprises!
2. Assemble the right team. EI assembled a fully remote team of three with the following background:
- Project managers and team leaders
- Document generation and system experts
- Retirement plan compliance experts
- Experienced plan document consultants
3. Create processes and roadmaps, such as:
- Collected data from the Client with plan volume and plan sponsors CSIA elections
- Prepare the CSIA packages, including updating the RK system for certain elected provisions
- Our team drafted specific CSIA Interim Amendment procedures
- Forecasted delivery and predicted plan/sponsor/if applicable signer execution
- Management and communication with various stakeholders
4. Resolve significant challenges that arose. Processes and workarounds were created to quickly resolve significant project management and data challenges that arose. These included:
- Reviewed data provided by vendor to identify and prioritize CSIAs that required signatures
- Review of the CSIA amendment system generation for validation errors and work on correcting discrepancies
- Accommodated midstream scope changes such as updating contacts and/or authorized signers relieving the amendment volume on Client’s existing plan design team
5. Archive and perform quality review. Performed comprehensive archiving and clean-up including:
- Performed a thorough quality control review of documents loaded to Client platforms
- Published/archived all CSIA amendments and Summary Plan Descriptions (SPD)
- Updated and finalized relevant processes and procedures as leave behinds for Client
RESULTS & CLIENT BENEFITS
Our RPCS Team successfully prepared and sent all CSIA packages to plan sponsors.
For amendments that required signatures we achieved an overall signature rate of 98%.
Received positive feedback from the Client thereby enhancing Client’s reputation and goodwill among its own clients and within the industry.
The Client retained 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.”