CCC Employer / Plan Sponsor Information

ALERT!! Effective 08/08/2008, no changes will be made to CCC’s legacy website, now with Internet address www.ncompliancelegacy.com. Henceforth, www.ncompliance.com goes directly to CCC's new, dynamic, database supported website.

For many months now, CCC has been developing and testing a new, dynamic, database-supported website, which now resides at www.ncompliance.com, while at the same time maintaining this website, which is now our legacy website (www.ncompliancelegacy.com). Development of the new website was essential to allow CCC to provide dedicated sections of its website to more than 50 new clients accumulated since publication of the Final 403(b) Regulations on July 23, 2007. We chose completion of the Plan Document System on the new website as the appropriate time to migrate from the legacy website, even though considerable work remains to be done. Specifically, we will be working with Vendors through the end of calendar year 2008 to incorporate updated Vendor information into the new website. Moreover, 457(b) Deferred Compensation Plan (DCP) information remains only on this legacy website, but those CCC clients for which we are managing their 457(b) Plans may continue to refer to this legacy website until the full migration has been accomplished.

We are very proud of our new website, especially the Plan Document System and the Content Management System (CMS), which allows Client Employers and Vendors to manage the content of their own sections of the website. We hope you share our enthusiasm and will create links form your own websites to your dedicated sections of the CCC website. Doing so will provide everything your employees need to know about their 403(b) Program.

About Us
Carruth Compliance Consulting, Inc. (CCC) provides indemnified compliance assurance and plan administration services to sponsors of 403(b) Tax Sheltered Annuity and 457(b) Deferred Compensation Plans. Click on the above link for more information about the company and its services.

Full-Service Oregon School Districts Each of the following Oregon School Districts is a full-service CCC Client District. These services include administration of contract exchanges within the plan and plan-to-plan transfers.

Bend-La Pine Schools
Canby School District 86
Corvallis School District 509J
Estacada School District 108
Eugene School District 4J
Gladstone School District 115
Gresham-Barlow School District 10J
Hermiston School District 8
Hillsboro School District 1J
Lincoln County School District
Molalla River School District 35
Oregon City Public Schools
Pendleton Public Schools
Portland Public Schools
Salem-Keizer Public Schools
West Linn-Wilsonville School District 3J
Woodburn SD 103 (New Client)

Full-Service Oregon ESDs
Each of the following Oregon Education Service Districts (ESDs) is a full-service CCC Client District. These services include administration of contract exchanges within the plan and plan-to-plan transfers.

Linn Benton Lincoln (LBL) ESD
Northwest Regional ESD
Umatilla-Morrow ESD (New Client)
Willamette ESD

Transitional Oregon School Districts Each of the following Oregon School Districts entered into a Transitional Agreement for limited CCC services through June 30, 2008. These limited services included administration of contract exchanges within the plan and plan-to-plan transfers. CCC has on file a letter from each CCC client District, including those full-service clients listed above, authorizing CCC to act on behalf of the District regarding exchanges and transfers and requiring target vendors to establish Information Sharing Agreements (ISAs) with CCC before accepting exchanges or transfers involving District employees after September 24, 2007. All of these Districts are now full-service CCC Clients.

Bethel School District 52
Centennial School District 28J
Central School District 13J
Culver School District 4
Dallas School District 2
David Douglas School District 40
Forest Grove School District 15
Gervais School District 1
Grants Pass School District 7
Greater Albany School District 8J
Harrisburg School District 7
Jefferson School District 14J
Knappa School District 4
Lebanon Community School District 9
Morrow School District 1
Newberg School District 29J
North Bend School District 13
North Marion School District 15
North Wasco County School District 21
Philomath School District 17J
Pleasant Hill School District 1
Rainier School District 13
Redmond School District 2J
Santiam Canyon School District 129J
Scio School District 95C
Seaside School District 10
Sisters School District 6
St Helens School District 502
Sweet Home School District 55
Tillamook School District 9
Umatilla School District 6R
Vernonia School District 47J

Transitional Oregon ESDs
Each of the following Oregon ESDs entered into a Transitional Agreement for limited CCC services through June 30, 2008. These limited services included administration of contract exchanges within the plan and plan-to-plan transfers. CCC has on file a letter from each CCC client District, including those full-service clients listed above, authorizing CCC to act on behalf of the District regarding exchanges and transfers and requiring target vendors to establish Information Sharing Agreements (ISAs) with CCC before accepting exchanges or transfers involving District employees after September 24, 2007. Both of these Districts are now full-service CCC Clients.

Columbia Gorge ESD
High Desert ESD

Plan Document Service Only Oregon School Districts
Each of the following Oregon School Districts has notified CCC that it will enter into a Plan Document Service Only Agreement beginning with adoption of the initial Plan Document by the Board of Education during calendar year 2008. In this program CCC provides exactly two services: 1) A comprehensive web-based Plan Document service; and 2) Annual announcements to satisfy the meaningful notice of universal eligibility and to list contribution limits for the coming calendar year. The Plan Document includes exactly one optional feature, namely the Age 50+ Catch-up Provision, which allows participants who reach their fiftieth birthday by December 31 of the year in question to defer additional amounts ($5,000 in 2008) under Internal Revenue Code Section 414(v). All other optional features will be unavailable, including contract exchanges within the plan, plan-to-plan transfers into the plan, plan-to-plan transfers out of the plan, loans, hardship distributions, 15 years-of-service catch-up provision, employer discretionary or matching contributions, Roth 403(b) contributions, and post-serverance employer contributions. Moreover, the District will administer the plan itself. CCC will not provide a dedicated section of the CCC website, nor will it monitor contributions for compliance. Fees for these services are $300 for the initial Plan Document and $150 per year maintenance fee.

Fossil School District 21J
St Paul School District 45

Transitional Washington School Districts
Each of the following Washington School Districts entered into a Transitional Agreement for limited CCC services through June 30, 2008. These limited services include administration of contract exchanges within the plan and plan-to-plan transfers. CCC has on file a letter from each CCC client District authorizing CCC to act on behalf of the District regarding exchanges and transfers and requiring target vendors to establish Information Sharing Agreements (ISAs) with CCC before accepting exchanges or transfers involving District employees after September 24, 2007. All of these Districts are now full-service CCC Clients.

Kennewick School District
Pasco School District No. 1
Richland School District No. 400
Seattle Public Schools
Walla Walla Public Schools

District and Vendor Matrix
For a list of all CCC clients and their authorized vendors, one list is Sorted by District and the other is Sorted by Vendor.

Visiting Employers/Plan Sponsors
If your school district is not a CCC client, please feel free to browse through one or more of the current CCC client websites listed to the left. The Portland Public Schools site includes more detailed information about authorized vendors, and is recommended for browsing. Contact us if you would like to discuss the possibility of securing CCC services for your District.

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 CCC Umbrella Information Sharing Agreements (updated 02-19-2008) before such exchanges or transfers will be allowed. However, in circumstances where a speicifc 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 aggrements assigning District information sharing responsibilities to CCC.

Authorization Letters
Click on the above link to view and/or print letters from CCC Client Districts authorizing CCC to act on behalf of the District with respect to contract exchanges within the plan and plan-to-plan transfers. Effective immediately, exchanges and transfers will be allowed only to accounts of Vendors that have either CCC Umbrella Information Sharing Agreements or District-specific Vendor Information Sharing Agreements in force.

Vendors Eligible To Receive Exchanges/Transfers
Click on the above link for the current list of Vendors for which either CCC Umbrella Information Sharing Agreements or District-specific Vendor Information Sharing Agreements in force. Vendors that have entered into CCC Umbrella Information Sharing Agreements are eligible to receive contract exchanges within the plan and plan-to-plan transfers from accounts of *all* participants in *all* CCC Client Districts. On the other hand, Vendors that have restricted their Information Sharing Agreements to specific Districts are only eligible to receive exchanges and transfers from accounts of participants in the plans of those specific Districts.

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 a CCC Umbrella Information Sharing Agreement 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 with CCC or the Vendor's Information Sharing Agreement directly with the District, as the case may be. If the Vendor has entered into a CCC Umbrella Information Sharing Agreement, a copy of the 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.

IRS Focus Area
Several District administrators have received letters from vendors about an IRS pilot initiative in three states (Washington, Missouri, and New Jersey) dealing with “universal eligibility”. Some of these communications suggest that Districts should be concerned about the issue the IRS is addressing and that the vendor’s representative(s) are available to discuss the issue with District personnel. CCC clients should rest assurred that they need not be concerned about this matter. Copies of the IRS letter, the accompanying Section 403(b) Questionnaire, and a follow-up form letter to Districts the IRS deemed to have provided responses indicating possible plan defects are available for your review at:
IRS Letter, Questionnaire, and Follow-up Letter (131 KB)
IRS Letter and Questionnaire (better quality 1 MB)
The IRS has now announced that it is expanding this initiative to all 50 states, beginning with Alaska, Florida, Hawaii, Illinois, Nevada, Pennsylvania, Tennessee and Virginia.
BenefitsLink Press Release, Thursday, June 21, 2007
IRS Announcement, June, 2007

Roth 403(b) Option
Effective January 1, 2006, some Districts decided to allow Roth 403(b) contributions and some District authorized vendors either currently accept or plan to accept Roth 403(b) contributions in the future. To find the latest information about which authorized vendors will accept Roth 403(b) contributions, visit the Master List of Vendors and Districts. To see whether a particular District has decided to allow Roth 403(b) contributions, click on that District's link on the above list. Please check these lists periodically, since additional vendors are likely to begin accepting Roth 403(b) contributions and perhaps additional Districts will begin allowing Roth 403(b) contributions.

Current CCC Clients/Plan Sponsors
If your school district is already a CCC client, click on your employer link to the left to view your District's CCC Home Page. From there, you may navigate to any of the following resources about the District's plan(s). Contact us if you have questions or concerns about any of the content of the District's CCC website.

Transaction Types - Definitions
Click here for information about the various types of transactions associated with 403(b) annuities and custodial accounts.