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CCC Vendor/Agent Resources
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.
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.
Additional Vendor Requirements
Beginning January 1, 2009, in order for a Vendor to be associated with any CCC
Client District's plan either as a Vendor eligible to receive current contributions
(i.e., to be a Vendor with a payroll slot) or as a Vendor eligible to receive
contract exchanges within the plan and/or plan-to-plan transfers (i.e., to
be a Vendor that has entered into an Information Sharing Agreement with the
District), then such Vendor must:
- Enter into a Information Sharing Agreement with the District
- Meet the terms of the District's Plan Document
- Enter into a Hold Harmless Agreement with the District
- Provide information for the CCC website
Therefore, a Vendor must agree to meet the second, third, and fourth
requirements above before the District will enter into an ISA with the
Vendor, even though Plan Documents, Hold Harmless Agreements, and CCC
website information may not be available in final form until sometime
during calendar year 2008.
CCC Vendor Services
In the new regulatory environment for 403(b) Plans, CCC will be providing
the following services to Vendors associated with one or more CCC Client
Districts either as a Vendor eligible to receive current contributions
(i.e., to be a Vendor with a payroll slot) or as a Vendor eligible to
receive contract exchanges within the plan and/or plan-to-plan transfers
(i.e., to be a Vendor that has entered into an Information Sharing Agreement
with CCC on behalf of the District):
- A single ISA between CCC and a Vendor makes the Vendor eligible to
receive contract exchanges within the plan and plan-to-plan transfers
from accounts of *ALL*
participants in *ALL*
CCC Client Districts.
- Consequently, CCC provides cost savings to the Vendor by not requiring
that the Vendor enter into an ISA with each individual CCC Client District.
- Moreover, the Vendor secures the significant opportunity associated
with eligibility to receive exchanges and transfers from multiple employer
plans via a single CCC ISA.
- A single Hold Harmless Agreement (HHA) between CCC and a Vendor covers
*ALL*
CCC Client Districts.
- Consequently, CCC provides cost savings to the Vendor by not requiring
that the Vendor enter into a HHA with each individual CCC Client District.
- CCC takes responsibility for monitoring contributions for compliance
with all applicable sections of the Internal Revenue Code, thus relieving
the Vendor from any such responsibility (ordinarily required of the
Vendor in a HHA). Moreover, CCC guarantees accuracy of its determinations
by indemnifying participants, employers, governing boards, and Vendors.
- CCC takes responsibility for authorizing eligibility for, and amounts
associated with, all account transactions, including contract exchanges
within the plan, plan-to-plan transfers, loans, qualified domestic relations
orders, hardship distributions, and other types of distributions.
- Consequently, CCC serves as a single point-of-contact for the Vendor
regarding all information sharing requirements associated with *ALL*
CCC
Client Districts.
- CCC provides a dedicated section of the CCC website to each Vendor
associated with one or more CCC Client District. This website section
provides the single most important source of information about the Vendor
and its products to employees of CCC Client Districts. Each CCC Client
District provides 403(b) Plan details to its employees by linking to
the District's dedicated section of the CCC website from the District's
official website, thus guiding its employees to the CCC website where
Vendor information is available.
Vendors Fees
On October 4, 2007 at 1:30
PM PDT, the following sentence was included on this web page: "However,
before CCC enters into an Information Sharing Agreement with any Vendor,
consensus among a reasonable number of Vendors must be reached regarding
Vendor fees to be paid to CCC for the services provided to Vendors by
CCC (see "CCC Vendor Services" above)." However, this position
has now been abandoned by CCC for the following reasons:
- Ultimately any fees charged to Vendors will be imposed upon participants,
either directly or indirectly.
- Imposing Vendor fees could have the effect of eliminating providers
of low-cost investment options, which would not be in the best interests
of participants.
- Determining and administering Vendor fees would make an already challengingly
complex set of procedures even more complex.
- It may be prudent to enter into Information Sharing Agreements initially
with no associated fees and gain some experience with respect to resulting
administrative costs.
In any event, all CCC Client
Districts have been advised not to permit exchanges or transfers until
the receiving/target Vendor has entered into an Information Sharing Agreement
with CCC. Interested vendors should complete and submit the CCC Information
Sharing Agreement below.
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