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limits will not be monitored for a Participating Employee across
multiple employers.
9.4
Data Requirements
9.4.1
All RMLM calculations are based solely on data provided by the
Employer. An initial data file from the Employer can include relevant
data provided to the Employer by one or more Vendors or service
providers under one or more of the Employer's Retirement Plans. VRSCO
will not seek the data directly from any Vendor or service provider,
including any VRSCO Affiliate (
e.g.
, VALIC). After providing the initial
data file, subsequent revisions or additions may be made online by the
Employer, or otherwise as agreed between Employer and VRSCO. In the
absence of all necessary data, contribution limits monitoring may default
to the basic limits as described in Section 9.2, above, as applicable to each
plan type. Employer must provide the following data in its initial RMLM
file for each Participating Employee (all fields are required):
1. Social Security Number
2. Employee ID
3. First Name
4. Last Name
5. Years of Service
6. 403(b) Plan: Amount Used Toward Lifetime $15,000 Cap
7. 403(b) Plan: Inception-to-Date Elective Deferrals
8. 457(b) Plan: Catch-Up Reserve Available
9. 457(b) Plan: Normal Retirement Age
If any of the above data is not provided for a Participating Employee,
RMLM will default to certain assumptions. For example:
•
If Employer has not provided Years of Service, RMLM will
determine Years of Service based on the date of hire provided and
calculate the expanded cap limit if applicable.
•
If no date of hire is provided, the individual will be assumed to
have zero Years of Service and, for example, will be assumed to be
ineligible for the expanded cap limit under Code Section 402(g)(7).
•
If Employer has not provided inception-to-date elective deferrals
for the Participating Employee, RMLM will assume this variable
to be zero (0) for calculation purposes.
•
If no 457(b) Catch-Up Reserve is provided for an employee, or if
no Normal Retirement Age is provided, the special catch-up limit
under Code Section 457(b) will be assumed to be unavailable,
although the age-based catch-up limit may be available.
9.4.2
Data required to be provided by Employer through Retirement Manager
for Code Section 402(g) expanded cap limit monitoring for Employer’s
403(b) Retirement Plans will include, but not be limited to, employee
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