Obtaining Transaction Authorization
CCC offers Plan Administrative Authorizations for plans CCC administers in various formats, depending on the transaction type.
CCC offers Authorization Vouchers for the following transaction types:
- 403(b) Distributions to the Participant (for qualifying events of Severance from employment and attainment of age 59.5)
- 403(b) Rollover Distributions (for qualifying events of Severance from employment and attainment of age 59.5)
- 403(b) Contract Exchanges within the Plan
- 403(b) Plan-to-Plan Transfers out of the Plan
For more information on requesting an Authorization Voucher, please click here.
Click here for information on submitting 403(b) Loans for authorization.
Click here for information on submitting 403(b) Hardship Distributions for authorization.
For all other transaction types
Participants may request plan authorization by completing the following steps:
- Complete a CCC Transaction Submission Cover Sheet and submit it, along with your completed vendor forms, to CCC. You may submit these documents to CCC using one of the following methods*:
- You may securely upload the documents to CCC by clicking here,
- You may fax the document to CCC at 503-968-7802, or
- You may mail the document to CCC at the following address:
Carruth Compliance Consulting
11515 SW Durham Rd. Suite E10
Tigard, OR 97224
- Once CCC receives your transaction submission we will review the documents, verify eligibility for the transaction.
- If appropriate, CCC will provide plan administrator's authorization for the transaction.
The CCC Transaction Submission Form is to be used to submit any transaction type except 403(b) Loans and 403(b) Hardships to CCC.
*Please note: some Vendors impose specific requirements before they will process certain (or any) transactions. Before you begin the process of submitting transaction, be sure to check for any special Vendor requirements (such as original document via mail only) by visiting their “General Information” page(s) available on the List of All Vendors page or contacting your vendor directly.
For more information on 403(b) transactions, including descriptions of the transaction types, click here.
View: CCC's Authorized Signatures Letter
CCC Transaction Processing Times
CCC transaction processing times vary by the type of transaction, the due diligence required to authorize the transaction and the receipt of all necessary documents. The following processing times are general guidelines only and are subject to change and circumstance:
- 403(b) Hardship Distributions: These requests take top priority and will be started on as soon as they are received. There is supporting documentation required to accompany the vendor's form, and the CCC Hardship Request Form. The CCC request form will outline what circumstances qualify for a Hardship Distribution and what additional documentation is required for each circumstance.
- 403(b) Loan Request: There is approximately a 2 week processing time for ALL LOAN REQUESTS. The participant must complete and sign the one-page CCC Loan Form and supply any additional documentation required. Please note that loans require communication with the broad vendor community to confirm whether the requesting participant has other outstanding loans. This process starts the first Monday following the week this loan request form is received by CCC. We give vendors one week to respond to our information request, if CCC has all the required information and no negative responses from vendors, CCC will proceed with authorization on the second Monday after the request is received.
- All Other 403(b) Transactions: Most other 403(b) transactions are authorized by CCC and sent to the specified party within 2 business days, barring any issues.
Information Concerning Rollover Options and the Taxation of Distributions
When taking a rollover or distribution from a 403(b) or 457(b) account, one must consider all options available to them and the tax consequences associated with those options. Most vendors provide a notice called a "402(f)" that describes the various rollover options and the applicable taxes associated with distributions and rollover options that comes as a part of or addendum to the vendor's distribution and rollover forms. Usually the participant's authorization section of one of these forms requires the participant to attest to the fact they have read the notice pertaining to taxation and understand the applicable tax consequences of the transaction they are submitting. (Please note: the IRS provided generic model language for 402(f) Notice in 2009 (Notice 2009-68), this model language is viewable here.) CCC strongly encourages participants to seek the advice of a qualified and trusted financial advisor and/or tax consultant concerning investment and distribution choices.
General Information Regarding Transactions
Carruth Compliance Consulting (CCC) serves as Third Party Plan Administrator (TPA) for Employer’s sponsoring 403(b) Plans. In this role CCC provides transaction processing for our “Full Service Clients” and limited transaction processing for certain vendors for our “Selected Vendor Plan Clients”. When a transaction requires a Plan Administrator or Employer signature, CCC conducts the appropriate due diligence required to determination eligibility for a given transaction prior to authorization.
Before you submit a transaction to CCC, please note the following information regarding transactions:
- Transaction may be restricted by a vendor’s investment agreement and the transaction processing requirements may vary from vendor to vendor. For example, Fidelity Investments requires “wet signatures” by the Participant and by CCC on all transaction processing forms. When available, CCC will post any available notes regarding transaction processing and forms if accessible online on the “Vendor’s CCC General Information” page for the each of the Vendors. The strong>“Vendor’s CCC General Information” pages are accessible via the “For Vendors” button at the top of any CCC web page under the heading “All Vendors Connected with CCC.” For further information regarding the availability of certain transaction options and other vendor-specific information, please consult your investment provider (Vendor), financial services professional or the information contained within your annuity contract(s) or custodial account agreement(s).
- All transactions are subject to their availability as an “optional feature” under the 403(b) Plan Document(s) for the Employer(s) associated with a transaction. CCC Full Service Client and Selected Vendor Client Plan Documents may be viewed by clicking the “ Employee Entrance” or the “ Employer Entrance” button at the top of the screen, selecting the appropriate Employer from the list of CCC clients, then selecting the “Plan Document” from the links in the light blue box on the employer’s page.
To submit a transaction for authorization, visit the “The Submitting a Transaction to CCC For Approval” section of this page or clicking here.
Below we have listed the major categories of transactions, specific transaction types, and information regarding the general requirements necessary to approve transactions. Additional requirements may apply.
Exchanges and Transfers: Transaction Definitions and Requirements
Contract Exchange: A Participant’s 403(b) Account Assets under an Employer’s plan are moved to a new or existing 403(b) account under the same Employer’s 403(b) plan.
Requirements: The receiving Vendor must be a Vendor that is eligible to receive exchange and transfers in the Employer’s plan. Eligible Vendors will have an Information Sharing Agreement (ISA) in place, this agreement can be either a CCC Umbrella ISA or a Direct to Employer ISA. The list of Vendors eligible to receive exchanges and transfers is available on each of the Employer’s “List of 403(b) Vendors” page or by clicking the “Exchanges and Transfers” link in the left-hand navigation menu.
Plan to Plan Transfer OUT of the Plan: Funds in a 403(b) Account associated with a Employer (the “releasing” plan) are moved to another Employer’s 403(b) plan (the "receiving" plan). Note: The account may remain with the same Vendor (referred as an "internal transfer") it may be moved to another Vendor available in the new Employer’s plan.
Requirements: Participant must be eligible for a distribution out of the releasing Employer's plan. Please see "Regular Distributions out of the Plan" for more information on eligibility for a distribution.
Distributions: Transaction Definitions and Requirements
Regular Distributions OUT of the Plan: A Participant withdraws the funds in a 403(b) account and directs the payment to his/herself.
Requirements: A single Qualifying Event must occur to for a Participant (or in the event of death, the beneficiary or beneficiaries) to distribute the funds. These events include:
1. Attainment of Age 59 ½
2. Severance from Employment Severance is defined as a complete severance from any employment relationship with the Employer sponsoring the 403(b) plan.
CCC has created guidance for employers to determine if an employee meets the criteria to be considered "severed from employment". This document is available here.
3. Disability (Disability in this context is defined as the inability to participate in gainful employment of any type due to a disability or illness that is of an indeterminate length and/or will result in the Participant’s death (official documentation of the disability, duration and work status required) ).
4. Death (See "Death Beneficiary Claim" for additional information).
Required Minimum Distribution (RMD)
Required Minimum Distribution are minimum amounts that a retirement plan account owner must withdraw annually starting with the year that he or she reaches 70 ½ years of age or, if later, the year in which he or she retires.
Your first required distribution must be made by April 1 of the year following the year when you turned 70½. For example, if you turn 70½ in February 2011, you must take your first RMD by April 1, 2012. The IRS calls this your Required Beginning Date.
There's an exception to this rule: If you're still working, you can generally delay RMDs, but only from the retirement plans you participate in with your current employer. In these situations, your first distribution must be made by April 1 of the year following the year of your retirement.
|You reach age 70½
||February 1, 2011
|You wait until the deadline to take your first distribution
||April 1, 2012
|Your second distribution is due
||December 31, 2012
Rollover Distribution OUT of the Plan: A Participant withdraws the funds in a 403(b) account and directs the payment to another qualified retirement plan. Note: The account may remain with the same Vendor (referred to as an internal rollover) or it may be moved to another Vendor.
Requirements: Same as a Regular Distributions OUT of the Plan (see above).
Death Beneficiary Claim: A Beneficiary of a 403(b) account moves the account assets from a deceased Participant in an Employers plan into the beneficiary's name, by rolling the funds into another qualified retirement plan or directing the distribution to his/herself.
Requirements: A copy of the deceased Participant’s death certificate must be provided and the Beneficiary information must be verified with the Vendor.
Hardship Distribution: Please see our dedicated "Hardship Distribution" link in the left-hand navigation menu or click here for information on Hardship Distributions and the required CCC Hardship Form.
Distribution of assets via QDRO (Qualified Domestic Relations Order): Please see our dedicated "QRDO" link in the left-hand navigation menu or click here for information.
Loans: Transaction Definition and Requirements
Loans: Please see our dedicated "Loans" link in the left-hand navigation menu or click here for information and the required CCC Loan Form.
Types of Contributions
Rollover Contributions into the 403(b) Plan: A participant withdraws the funds from a qualified retirement plan (IRA, PERS, 457(b), 401(k), etc.) account and directs the payment into a 403(b) account sponsored by his/her Employer. Note: The account may remain with the same Vendor (referred to as an internal rollover) or it may be moved to another Vendor.
Requirements: The receiving vendor must be a vendor that is eligible to receive exchange and transfers in the employer’s plan.
Employee Elective Deferrals (via Salary Reduction): An employee establishes a 403(b) account then begins making contributions by requesting part of their salary be deferred to the account by reducing their pre-tax salary by an elected amount.
Requirements:A Salary Reductions Agreement (SRA) must be submitted to the Employer along with documentation that the account has been established with a Vendor with an Active Payroll Slot under that Employer's 403(b) plan. The SRAs and the 403(b) List of Vendor is available Employer's dedicated page (accessible from the "Employee Entrance" link at the top of the page.)
Reapportioning Contribution: Reassigning the division of contribution dollars between 403(b) Vendors.
Requirements:Complete an new SRA, see "Employee Elective Deferrals (via Salary Reduction)" above for details.
Redividing Contributions: Reassigning the division of contribution dollars to a specific vendor between 403(b) investments accounts.
Requirements: Complete an new SRA, see "Employee Elective Deferrals (via Salary Reduction)" above for details.