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Prepared for Springfield R-XII School District

26

12.Can your Firm provide the District with a report of participants utilizing the catch-up

provisions?

VALIC can provide limits monitoring and enforcement of applicable limits across supported

plans.

Retirement Manager 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

415 limits

Cross-plan limits for situations when the 402(g) limit applies across multiple plans of the

same employer

Retirement Manager uses data provided and approved by the plan sponsor to determine the

maximum allowable amounts. Retirement Manager monitors the amount(s) contributed to

each plan and determines whether an employee is eligible to utilize certain catch-up

provisions in each plan. Retirement Manager produces online reporting across all plan types

and vendors. With Retirement Manager Limits Monitoring in place, excesses should be

greatly reduced.

In addition, Retirement Manager provides an enforcement module designed to prevent

excess deferrals through a proactive process that systematically reduces and/or stops

excess deferrals from occurring. The process includes plan sponsor and participant

notifications through reports and emails. An additional reactive enforcement process is

designed to be a second IRC limits validation to prevent excess deferrals from occurring

.

13.Describe your in-house legal and compliance support for these services, including

your ability to provide periodic regulatory and compliance updates (not legal or tax

advice) to us.

Legal Support

VALIC’s legal department of attorneys and tax professionals has significant expertise in:

ERISA and tax laws

Regulations associated with retirement programs and plans established under Internal

Revenue Code sections 401(a)/403(a), including:

401(k)

403(b)

408(k)

408(p)

457

Non-qualified deferred compensation plans

IRAs

Tax-deferred annuities under section 72