Carruth Compliance Consulting

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CCC is closing at 3:30p.m. on 5/31/2023 for a staff event.

CCC Information and Services

Brief Company History

Dr. J. Harvey Carruth is nationally recognized as a 403(b) and 457(b) plans expert. He directed the Individualized Retirement Financial Planning Project at The University of Tennessee from 1980 through 1997, then founded Carruth Compliance Consulting, Inc. (CCC), an Oregon Corporation. During the period since 1997, CCC has developed solid consultant-client relationships with numerous Oregon and Washington State Public School Districts, ESDs, and Colleges. CCC services remove significant loads from the shoulders of school business officials, especially now that Final 403(b) Regulations have been published.

Compliance Issues

403(b) Tax Sheltered Annuity (TSA) Plans and 457 Deferred Compensation Plans (DCP) are rift with complexities, not the least of which is the need for historical salary, service, and contribution data all the way back to initial employment for some employees. Collection of historical data has proven to be one of the greatest single hurdles in audit-proofing efforts associated with both TSA and DCP Plans.

Other constantly changing rules and regulations include:
  • Elective deferral limits and catch-up provisions.
  • Contract exchanges, plan-to-plan transfers, and rollovers.
  • Loans, hardship withdrawals, severance pay, and back pay.
  • Early retirement incentives and post-retirement contributions.
  • Solicitation rules and requirements for vendors.

Compliance Monitoring Services

Carruth Compliance Consulting, Inc. (CCC) has developed, tested, and implemented a proprietary cost-effective critical pathway methodology that obviates the need for collecting historical payroll data for more than 95% of the participants in 403(b) and 457(b) Plans. Moreover, for the less than 5% of participants for whom historical data must be collected, a non-intrusive data collection approach is used, in that it does not require contacting either employees or investment companies.

Plan Administration Services

CCC serves as the clearing house for all aspects of plan administration except for the standard Payroll functions of receiving Salary Reduction Agreements, data entry into the Payroll system, and remittance of contributions to investment companies. Comprehensive practices and procedures are implemented for CCC clients, most of which are made available in client-specific sections of this website.

Plan administrative services provided by CCC include:

  • Information about participation in the plans.
  • Online salary reduction and service provider agreements.
  • List of and links to vendor websites.
  • Administration of contracts and plan-to-plan transfers.
  • Administration of rollover distributions.
  • Administration of other types of transactions.
  • Administrative policies and procedures.
  • Communications with administrators and employees.

No Conflicts of Interest

CCC personnel have never been involved in marketing 403(b) or 457(b) products, nor will they ever be so involved. Therefore, there cannot be even the appearance of a conflict of interest in the services provided by CCC.


Feel free to contact any of the officials listed in our references for evaluations of the quality and value of services provided by Carruth Compliance Consulting, Inc. Learn More

For additional information on CCC's services, please visit our Prospective Clients page.


CCC Team Members

Final 403(b) Regulations, published by the IRS in July of 2007, imposed significant new requirements on employers sponsoring 403(b) plans. As a result, many public employers have turned to CCC for compliance monitoring services. For this reason, and to ensure that all CCC clients will continue to receive the superb service they have received through the years, CCC has added highly-qualified staff members(see biographical information below).

Harvey Carruth


Harvey established Carruth Compliance Consulting, Inc. (CCC) in 1998 with the purpose of providing compliance monitoring services to public school districts for their supplemental retirement savings plans (TSAs under Section 403(b) and DCPs under Section 457(b) of the Internal Revenue Code). Beginning in 2002 Harvey began an expansion of the services offered by CCC to include certain plan administration services, primarily through a website with dedicated individual Employer sections. Publication of new 403(b) Regulations in July of 2007 led to substantial increases in number of clients, including new clients in Washington state. More recently CCC has expanded services to certain clients to include common remitting and online enrollment. Also, CCC has taken on a limited number of ERISA clients, including one in North Carolina.

Jim Kelleher

Chief Operating Officer

Jim comes to CCC with extensive experience in the financial services industry. Prior to CCC, Jim was a Director in Credit Risk Management at Deutsche Bank in New York and previously worked with JP Morgan Chase and Union Bank of Switzerland. Jim also spent five years working at Intel Corporation supporting the services business in controlling, business development, and sales roles. Jim graduated from UVA in 1989 and has an MBA from NYU. Jim is an Enrolled Retirement Plan Agent (ERPA), as such he is enrolled to practice before the IRS on certain retirement plan issues.

Heather Mondor

Director of Compliance and Data Analysis

Heather is responsible for analyzing data from CCC client employers, data related correspondence, performing tests to monitor compliance with IRS rules concerning 403(b) accounts and the supervision of CCC's Transaction Team. Heather received her M.A. in Sociology from California State University, Sacramento. Her studies focused heavily on research methodologies, both statistical and qualitative. Professionally, Heather has served in Management capacities in multiple organizations and brings strong business analytics knowledge to her work at CCC. Heather joined CCC's team in 2007.

Suelynne Chincio

Transaction Team

Jamie Buchholz

Transaction Team

Joan Lehninger

Transaction Team

Irene Wood

Transaction Team

Susan Erdt

Transaction Team


Page Last Modified: 11/12/2015 5:54:01 PM