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excess deferrals. Retirement Manager monitors the following IRC limits:
403(b) basic limit under 402(g), age-based catch-up and 15-year lifetime cap expansion
457(b) basic limit, age-based catch-up (where applicable) and special catch-up
415 limits
Cross-plan limits for situations when the 402(g) limit applies across multiple plans of the
same employer
Retirement Manager does not perform 401(a) (17) limits monitoring.
7. Does your Firm prompt or remind 403(b) and 457(b) participants that they are eligible
for the catch-up elections or must they notify you? If not, why? What controls are in
place to assure the maximum catch-ups are not exceeded?
VALIC system provides, upon request, employer-level reports that detail available catch-up
amounts, based on expanded cap and age-based rules. These amounts are based on a
participant's age, years of service, and cumulative contributions. The 15 year catch-up
allowance under 402(g)(7) will be calculated first, prior to determining any 414(c) age 50
catch-up allowance.
VALIC proprietary contribution limit monitoring system projections are calculated and
provided to each financial advisor to help participants maximize their contributions while
preventing excess contributions before the calendar year end. Based on final year-end
contribution information, our system recalculates and identifies excesses in the first quarter
so that any necessary corrective action may be taken. Our financial advisors receive weekly
updates from the system on both potential and actual excesses allowing them to help their
clients maximize their retirement contributions.
Retirement Manager does not notify the participant if they are eligible for the catch-up or
expanded cap contributions. However Retirement Manager does automatically monitors
basic Internal Revenue Code ("IRC") contribution limits, age-based catch up, special catch-
up limits when applicable to identify excess deferrals. Retirement Manager monitors the
following IRC limits:
403(b) basic limit under 402(g), age-based catch-up and 15-year lifetime cap expansion
457(b) basic limit, age-based catch-up (where applicable) and special catch-up
401(a) limits
415 limits
Cross-plan limits for situations when the 402(g) limit applies across multiple plans of the
same employer
Retirement Manager uses plan and eligibility data provided by and approved by the plan
sponsor to determine the maximum allowable amounts. Retirement Manager monitors the
amount(s) contributed to each plan. Retirement manager produces online reporting across
all plan types and vendors.
In addition, Retirement Manager provides an enforcement module designed to prevent
excess deferrals through a proactive process that systematically reduces and/or stops