How Does Your Plan Measure Up Against Other 403(b) Plans?

Recently, my firm, Carroll Consultants, Ltd., has been doing a great deal of document amendments for 403(b) plan sponsors wishing to add more options to their plan, such as Roth accounts.  The first question that clients have before they make the decision to amend their document is what are other 403(b) plan sponsors doing?  For those 403(b) plan sponsors seeking to compare their plans against their peers, the Plan Sponsor Council of America (PSCA) recently concluded its 2013 survey of 403(b) plans sponsored by 573 non-profit organizations.[1]  The survey findings are for the 2012 plan year.   The following are some of the highlights of the survey:

 

Employee Participation

• 85.3 percent of employees are eligible to participate
• 51.9 percent of the organizations allow all employee groups to participate, while 48.1 percent restrict participation to specific categories of employees

 

Employee Deferrals and Employer Contributions

• 66.2 percent of eligible employees made contributions in 2012
• 23.8 percent allow Roth after-tax contributions
• 82.3 percent of organizations make contributions to the plan, 40.9 percent making matching contributions only, 25 percent make non-elective contributions only, and 16.4 percent make both matching and non-elective contributions
• Average maximum matching formula was 4.7 percent of participant’s compensation and the average maximum non-elective contribution was 6.1 percent of compensation

 

Investment review and monitoring

• 52.8 percent have an investment policy statement (“IPS”)
• 24.1 percent were unsure if their plan had an IPS
• 48.2 percent monitored investments annually
• 46 percent have an independent investment advisor assisting them with fiduciary responsibility

 

Loans and Hardship Withdrawals

• 69 percent allow plan loans
• 75.7 percent allow hardship withdrawals

 

Participant Education and Communication

• 85.3 percent use enrollment kits
• 70.7 percent use e-mail
• 58.9 percent use intranet/internet sites
• 54.2 percent offer one-on-one meetings with the plan service provider

 

ERISA Status

• 76.3 percent were subject to ERISA
• 16.4 percent were non-ERISA
• 7.3 percent were unsure of their ERISA status

 

One of the most interesting results from the survey is the fact that 7.3 percent of the respondents did not know their plan’s ERISA status.  While 7.3 percent does not appear to be a big number, there are huge consequences for ERISA plans that are not operating in accordance with Title I of ERISA.  Specifically, Title I requires ERISA plans to comply with the U.S. Department of Labor’s reporting and disclosure rules, and fiduciary provisions.  Failure to comply with these rules, could lead to penalties and personal liability for plan fiduciaries.  Thus, it is important for all plans to know their ERISA status.

 

 

Founded in the 1950s, Carroll Consultants, Ltd. has experienced professionals with a wealth of knowledge about retirement plans. If you have any questions about this article or our services, please contact Marcie Carroll, at mcarroll@cclbenefits.com, or (610) 225-1210.

 

 

This material is not intended to provide specific legal or other professional advice.