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.
View CCC's Responses to ASBO Sample Questions
CCC Program Types
- I. Full Service
- II. Plan Document Only
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 Employers 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 download, edit, print, sign, and date two copies of the Draft Contract and return them to CCC. Contact Us if you have questions concerning our services and fee structure.
II. Plan Document Service Only Program
CCC is aware that fees for the full complement of CCC services may be disproportionate for extremely small Employers. 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 Employer 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 System is a dynamic, database supported, web system, to which the Employer links from its own official website.
The Plan Documents provided within the Plan Document Service Only Program *excludes* all optional 403(b) plan features except the Age 50+ Catch-up Provision and In-Service Distributions after Age 59-1/2. Hence, contract exchanges, plan-to-plan transfers, loans, hardship distributions, and employer-paid 403(b) contributions will be prohibited. Moreover, the Plan Document specifies that plan participants are 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 are 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 are restricting the features of your Employer's 403(b) Plan to those that may fairly easily be administered in-house. If you are interested in adopting these services, please download, complete, sign, date, and submit the following Agreement to CCC. Also, print the 2009 Announcement and distribute it to all of your employees:
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 an Umbrella CCC Hold Harmless and Information Sharing Agreement (HH+ISA) before such exchanges or transfers will be allowed. However, in circumstances where a specific Vendor steadfastly refuses to enter into a Umbrella CCC Hold Harmless and 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 their plans, Vendor Information Sharing Agreements directly with individual Districts are allowed, such aggrements assigning District information sharing responsibilities to CCC.
Note: Some CCC clients may elect to restrict exchanges and transfers to Vendors that hold Active or Inactive Payroll Slots.
Authorization Letters and Power of Attorney
Early in the process of implementing new 403(b) Regulations, letters from CCC Client Employers authorizing CCC to act on behalf of the District with respect to contract exchanges within the plan and plan-to-plan transfers were made available for viewing on the CCC website. With those Authorization Letters posted, exchanges and transfers have been, and continue to be, allowed only to accounts of Vendors that have either CCC Umbrella Information Sharing Agreements or District-specific Vendor Information Sharing Agreements in force.
Effective 11/14/2008 CCC began to receive expanded authorities to act on behalf of its Client Employers in the form of Power of Attorney documents. As these new documents are received, they will be posted to the CCC website. Click to View Authorization Letters and Power of Attorney Documents.
Vendors Eligible To Receive Exchanges/Transfers
Effective September 25, 2007, through December 31, 2008, in-service under age 59 1/2 transfers from a 403(b) account with one Vendor to a 403(b) account of a second Vendor is allowed for participants in CCC Client District 403(b) Plans only if the the receiving Vendor agrees to enter into an Information Sharing Agreement with the District by December 31, 2008.
CCC has advised all of its Full Service Client Districts to require that 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 an Umbrella CCC Hold Harmless and Information Sharing Agreement (HH+ISA) with CCC before such exchanges or transfers will be allowed. However, in circumstances where a specific 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 agreements assigning District information sharing responsibilities to CCC.
When Vendors enter into Umbrella CCC Hold Harmless and Information Sharing Agreement , CCC requires that the Vendors provide specimen copies of their 403(b) annuity contracts and/or their 403(b)(7) custodial account agreements.
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 an Umbrella CCC Hold Harmless and Information Sharing Agreement (HH+ISA) with CCC 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 or the Vendor's Information Sharing Agreement directly with the District as the case may be. Both documents are available in the left hand column of this page. If the Vendor has entered into a Umbrella CCC Hold Harmless and Information Sharing Agreement , a copy of 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 new 403(b) Regulations have been published, CCC is prepared to relieve client Employers of the necessity to wade through the maze of new requirements. Learn More about how CCC is accepting responsibility for compliance with the new 403(b) Regulations on behalf of its client Employers. To safeguard CCC intellectual property, this information is protected and requires User ID and Password for access. Existing Employers may log in using their Employer login account to view this page. Or, if necessary, Contact Us to request access to this section of the website.