CEBS: GBA/RPA 3 (new curriculum)
ERISA - -Employee Retirement Income Security Act 1974
-SOC Reports - -Service Organization Controls: for external vendors
-SOC 1 - -Internal Controls & Financial reports; used by auditors
-SOC 2 - -Security, availability, processing integrity, confidentiality and
privacy controls;used by management, regulators, and others under an NDA
-SOC3 - -Same as SOC2, but available for public use.
-Tribble V Edison - -Landmark court case re fiduciary responsibility
pertaining to reasonableness of fees. Also, allowed 6 yr statute of limitations
to be based on most recent time fees were applied rather than when fund
was added. Greater exposure for plan sponsor.
-SPD-renewals - -Renew every 10 yrs, every 5 years if changes; provide to
ppts no later than 210 days after plan year in which changes were made
ends.
-QLAC - -Qualified Longevity Annuity Contract; individual purchases
contract. Allows individual to delay withdrawing money from retirement
account. Must start by distributions by age 85; Amt of QLAC is not included in
amount determined for an RMD
-Plan document should include: - -(a) The name(s) of the plan fiduciary(ies)
(b) Policies and procedures relating to plan administration
(c) Funding requirements
(d) A description of how benefit payments will be made
(e) Claims and appeals procedures
(f) Plan amendment and termination authority and procedures
(g) Method for distribution of plan assets upon plan termination
(h) A statement that plan assets can be used to pay reasonable costs of plan
administration.
-Plan Document - -No set requirements; include plan name, fiduciary, claims
review procedures; funding; eligibility
-Summary of Material Modification (SMM) - -Must be delivered within 210
days after the end of the plan year, or within 60 days after a "material
reduction" in benefits of a group health plan. penalty up to $110/day for not
delivering within 30 of ppt/beneficiary's request
, -Social Insurance-Fully Insured - -40 credits/quarters of coverage
1 credit for each $x earned (2017-$1300)
Adjusted for inflation
Must be fully insured to be eligible for retirement benefits
-Currently Insured - -At least 6 credits in last 13 calendar quarters ending
with quarter of death, disability, or entitlement to retirement benefits.
-Disability Insured - -Two work tests: 1) recent work test; depends on age at
disability. and 2)duration of work test (doesn't require work within a certain
period of time)
-FASB ASC 960 - -Defined Benefit Plans; establishes the accounting and
financial reporting standards.
Under DOL
ERs can file one set
-FASB ASC 960-which plans - -All ongoing plans-Funded and Unfunded that
provide pension benefits
a) plans subject to ERISA
b) plans not subject to ERISA
c) plans without intermediary funding agencies or plans financed through
trusts, contracts of insurance or a combination thereof
DOES NOT APPLY to gov sponsored SS plans
-FASB ASC 960-Acctg and Reporting - -a) accrual basis, include statement of
net assets available at the end of the year and a statement of a change in
assets
b) plan investments- FAIR value except for insur contracts
c) info on actuarial PV and sig changes
d) accumulated plan benefits one of three options:
-face of statement
-net assets available for benefits
-separate statements or in notes of fin statements
e) actuarial PV of accumulated plan benefits baed on EE earnings
-2014 DOL Audit quality study - -Almost 40% of benefit plan audits had
unacceptable major deficiencies
-3 types of deficiencies/weaknesses - -1)Internal Plan Processes
2)Regulatory requirements
3) Outside Service Providers
-Deficiency-408(b)(2) - -Lack of proper monitoring of service provider fees
and disclosures. Impt b/c a service provider is a party in interest. If not
written down, they are considered unreasonable
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