CCC Prospective Client Page

ALERT!! Effective 08/08/2008, no changes will be made to CCC’s legacy website, now with Internet address www.ncompliancelegacy.com. Henceforth, www.ncompliance.com goes directly to CCC's new, dynamic, database supported website.

For many months now, CCC has been developing and testing a new, dynamic, database-supported website, which now resides at www.ncompliance.com, while at the same time maintaining this website, which is now our legacy website (www.ncompliancelegacy.com). Development of the new website was essential to allow CCC to provide dedicated sections of its website to more than 50 new clients accumulated since publication of the Final 403(b) Regulations on July 23, 2007. We chose completion of the Plan Document System on the new website as the appropriate time to migrate from the legacy website, even though considerable work remains to be done. Specifically, we will be working with Vendors through the end of calendar year 2008 to incorporate updated Vendor information into the new website. Moreover, 457(b) Deferred Compensation Plan (DCP) information remains only on this legacy website, but those CCC clients for which we are managing their 457(b) Plans may continue to refer to this legacy website until the full migration has been accomplished.

We are very proud of our new website, especially the Plan Document System and the Content Management System (CMS), which allows Client Employers and Vendors to manage the content of their own sections of the website. We hope you share our enthusiasm and will create links form your own websites to your dedicated sections of the CCC website. Doing so will provide everything your employees need to know about their 403(b) Program.

ASBO Sample Questions for TPAs
In February of 2008 ASBO International published a list of 21 sample questions 403(b) Plan Sponsors should ask to prospective 403(b) Plan Third Party Administrators (TPAs). Click on the link below to review CCC's responses to those questions, which may be helpful as you evaluate options for administering your 403(b) Plan. An updated check-list was published to the ASBO website on April 15, 2008, but the responses to the February sample questions adequately address all questions raised in the April check-list.

CCC's Responses to ASBO Sample Questions

CCC Program Types
I. Full Service
II. Plan Document Only
III. Transitional Agreement (No Longer Available)

I. Full Service Program
CCC provides the following Third Party Administrator (TPA) services for 403(b) Plan:

• Monitors Contributions for Compliance
• Complete Plan Document Service
• Hold Harmless Agreements
• Information Sharing Agreements
• Salary Reduction Agreements
• Dedicated Section of CCC Website
• Web-Based Educational Information
• E-Mail and Telephone Support
• Roth Contribution Implementation
• Administers All Plan Transactions Effective 1/1/2009

Currently, CCC does not offer common remitter services. Our research has shown that public school districts prefer to continue *business as usual* to the extent possible in the new regulatory environment, so there have been no requests for CCC to implement common remitter functions. If and when such requests are made, CCC will consider development of common remitter services.

If you are intrested in adopting the services offered by CCC, then: 1) Download, edit, print, sign, and date the Draft Contract; 2) Download the Authorization Letter, add the date, signatory, and signatory position, then print the resulting letter on District letterhead, sign the letter, and send both the signed and dated Draft Contract and the signed Authorization Letter to CCC; and 3) Download the Letter to Employees, edit if you like (e.g., add the date), then print the resulting letter on District letterhead and distribute it to all District employees. Contact Us if you need help or have questions.

• Draft Contract (Word Document)
• Authorization_Letter (Word Document)
• Letter to Employees (Word Document)
• Revised New Client Fees for FY 2008-09 (Excel File)

II. Plan Document Service Only Program
CCC is aware that fees for the full complement of CCC services may be disproportionate for extremely small school districts. Consequently, CCC has also implemented a Plan Document Service Only Program as an option for School Districts with fewer than 2,000 students. In this program, your District may sign up for extremely limited CCC services (Plan Document Service Only) with no fees for the remainder of FY 2007-08. The Plan Document will be a dynamic web page to which the District will link from its own official website.

The Plan Documents provided within the Plan Document Service Only Program will *exclude* all optional 403(b) plan features except the Age 50+ Catch-up Provision. Hence, contract exchanges, plan-to-plan transfers, loans, hardship distributions, and employer-paid 403(b) contributions will be prohibited. Moreover, the Plan Document will specify that plan participants will not be allowed to use the 15 Years-of-Service Catch-up Provision ordinarily available under Internal Revenue Code Section 402(g)(7). On the other hand, plan participants will be allowed to use the Age 50+ Catch-up Provision specified in Internal Revenue Code Section 414(v). Therefore, by adopting a CCC Plan Document Service Only Agreement you will be restricting the features of your District's 403(b) Plan to those that may fairly easily be administered in-house. Please review the following documents, which provide details of this new program:

• Letter of Intent (Downloadable Word Document)
• Letter to Employees (Downloadable Word Document)
• Plan Document Service Only Agreement (Under Development)
• $300 for the Initial Plan Document, followed by $150 Annual Maintenance Fee

If your District has fewer than 2,000 students and, after reviewing the details of this new program you are interested in adopting the CCC Plan Document Service Only, then: 1) Download the Letter of Intent (first bullet point above), edit as instructed, print the esulting letter on District letterhead, and send the completed Letter of Intent to CCC; and 2) Download the Letter to Employees, edit as instructed, print the resulting letter on District letterhead, and distribute it to all District employees. Note: The Letter to Employees was modified on 12-06-2007 at 10:45 PM PST.

Once your District has become a CCC Plan Document Service Only Client, you will be prompted regularly to visit the Plan Document Service Only Client Home Page (under construction) to receive instructions for next tasks to be completed. To protect CCC intellectual property, the information on the Plan Document Service Only Client Home Page (under construction) is protected and requires User ID and Password for access. Contact Us for more information and/or to request User ID and Password to gain access to this section of the website.

III. Transitional Agreement Program (Expired)
When the new 403(b) Regulations were published on July 26, 2007, CCC was aware that budgets for FY 2007-08 were already fixed and that it would have been difficult for Employers to adopt new services mid-year. Consequently, CCC implemented a Transitional Agreement Program, in which Districts were allowed to sign up for limited CCC services (contract exchange and plan-to-plan transfer administration services only) with no fees for the remainder of FY 2007-08. Many Districts took advantage of this program and, by doing so, became immediately protected from adverse tax consequences that might have arisen as a result of improper exchanges and transfers. By adopting CCC Transitional Agreements, these Districts committed to the CCC Full Service Program for FY 2008-09. The documents below provided details of this Transitional Agreement program, and are maintained on our webiste now for historical documentation purposes only. Please be aware that the "New Client Fees" for Transitional Agreement clients in the schedule below were honored for FY 2008-2009, but all such clients were notified that those fees would increase by 10% plus a reasonable COLA for FY 2009-2010.

• Transitional Agreement (Fillable PDF Form)
• Authorization_Letter (Word Document)
• Letter to Employees (Word Document)
• New Client Fees for FY 2008-09 (Excel File)

Note: The Transitional Agreement Program was an interim program that applied only to FY 2007-2008.

References
Contact the officials listed at the above link for evaluations of the quality and value of services provided by Carruth Compliance Consulting, Inc.

Contact Us
How to reach us on- and offline.

New Rules for Transfers
Effective September 25, 2007, Final 403(b) Regulations imposed new requirements on transfers from a 403(b) account with one Vendor to a 403(b) account with a different Vendor. The Final 403(b) Regulations isolate two different types of transfers: 1) Contract Exchanges within the Plan; and 2) Plan-to-Plan Transfers. Beginning September 25, 2007, under the new Regulations the receiving Vendor in any exchange or transfer is required to agree to enter into an Information Sharing Agreement with the District by December 31, 2008. CCC has advised all of its Full Service and Transitional Agreement Client Districts to require such Information Sharing Agreements be established between the District and a Vendor before exchanges within and transfers into their plans are allowed. Generally, CCC requires that Vendors enter into CCC Umbrella Information Sharing Agreements (updated 02-19-2008) before such exchanges or transfers will be allowed. However, in circumstances where a speicifc Vendor steadfastly refuses to enter into a CCC Umbrella Information Sharing Agreement, and yet a sufficient number of CCC Client Districts request that the Vendor in question be eligible to receive exchanges and transfers within there plans, Vendor Information Sharing Agreements directly with individual Districts are allowed, such aggrements assigning District information sharing responsibilities to CCC.

Authorization Letters
Click on the above link to view and/or print letters from CCC Client Districts authorizing CCC to act on behalf of the District with respect to contract exchanges within the plan and plan-to-plan transfers. Effective immediately, exchanges and transfers will be allowed only to accounts of Vendors that have either CCC Umbrella Information Sharing Agreements or District-specific Vendor Information Sharing Agreements in force.

Vendors Eligible To Receive Exchanges/Transfers
Click on the above link for the current list of Vendors for which either CCC Umbrella Information Sharing Agreements or District-specific Vendor Information Sharing Agreements in force. Vendors that have entered into CCC Umbrella Information Sharing Agreements are eligible to receive contract exchanges within the plan and plan-to-plan transfers from accounts of *all* participants in *all* CCC Client Districts. On the other hand, Vendors that have restricted their Information Sharing Agreements to specific Districts are only eligible to receive exchanges and transfers from accounts of participants in the plans of those specific Districts.

Procedures for Processing Exchanges/Transfers
First the individual (participant or agent) planning the exchange/transfer should check the list of Vendors eligible to receive exchanges/transfers to be sure the "receiving" Vendor is eligible to receive the exchange/transfer from an account of a Participant in the District in question. If the "receiving" Vendor is on the list, then the application process may continue. Otherwise, the desired "receiving" Vendor should be contacted and encouraged to enter into a CCC Umbrella Information Sharing Agreement or a Vendor Information Sharing Agreement directly with the District that assigns CCC as the information sharing party on behalf of the District.

Once it has been verified that the "receiving" Vendor is eligible to receive the exchange/transfer, typically both the "releasing" Vendor and the "receiving" Vendor will have forms that must be completed by the applicant or the applicant's representative. However, sometimes the "releasing" Vendor does not require a form of its own. Typically the "receiving" Vendor's form is referred to as a *letter of acceptance." All appropriate forms should be submitted to the "releasing" Vendor, by the "receiving" Vendor, including copies of the "receiving" Vendor's Information Sharing Agreement with CCC or the Vendor's Information Sharing Agreement directly with the District, as the case may be. If the Vendor has entered into a CCC Umbrella Information Sharing Agreement, a copy of the District's Authorization Letter should also be attached. Neither the Employer nor CCC should be involved in the transaction, nor should authorizing signatures from either the Employer or CCC be required for processing.

Breaking News - Changes Ahead
Learn about significant changes either already set in concrete or under consideration.

Charting A New Course
Now that the new regulations have been released, CCC is prepared to relieve client Districts of the necessity to wade through the maze of new requirements. Click on the above link to review details of how CCC is accepting responsibility for compliance with the new 403(b) Regulations on behalf of its client Districts. To protect CCC intellectual property, this information is protected and requires User ID and Password for access. Contact Us and request access to this section of the website.