CCC 403(b) Transactions Defined

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.

Transactions Explained
Once an employee begins participation in the District's 403(b) Program, numerous types of transactions take place, beginning with the first contribution and ending with the last distribution. Along the way:

Contributions (employee contributions and/or employer discretionary or matching contributions) may be apportioned among two or more investment companies on the authorized vendor list, depending on plan policies. Specifically, as an administrative policy your Employer may limit the number of different companies to which you may contribute at any given time.

Contributions to a specific investment company may be allocated among several investment funds of the company in question. Periodically, such allocations may be changed by the participant for various reasons, e.g., to rebalance account balances or diversify investment portfolios.

If the employer sponsoring the 403(b) Program allows Roth contributions and a specific investment company accepts Roth contributions, then contributions to that investment company may be divided between Traditional (tax-deferred) contributions and Roth (after-tax) contributions in any proportion the participant desires. However, the aggregate of a participant's Traditional and Roth 403(b) contributions to all investment companies may not exceed the participant's elective deferral limit for the calendar year.

Accumulated account balances are sometimes exchanged or transferred to other 403(b) accounts, either within the same company (internal) or to a different company (external)

A distribution of an accumulated account balance is allowed once the participant attains age 59 1/2, has a severance from employment, dies, or becomes disabled.

Once account balances become eligible for distribution, they may be rolled over into different types of eligible retirement plans (IRA, 401(k), 401(a), etc.).

Hardship distributions and loans are additional types of transactions associated with 403(b) accounts.

Appearing in the column to the right are basic descriptions of the various types of transactions associated with 403(b) programs, with explanations of how such transactions are normaly processed. While some of the terminology is standard in the industry, some is not. "Apportioned" and "allocated" are good examples of non-standard terminology and often "transfer" and "rollover" are incorrectly used as equivalents. The new 403(b) Regulations published on July 26, 2007, introduced the concept of contract exchanges within the plan.

Contact us if you have questions about any of the transactions described on this page or if you need information about a transaction type that does not appear here.


Elective Deferral Contributions
To begin elective deferrals, you must submit a Salary Reduction Agreement to your employer specifying the monthly dollar amount or percentage of salary by which your salary is to be reduced while the Salary Reduction Agreement is in force. Also, the Salary Reduction Agreement specifies the investment company or companies into which your deferrals are to be deposited and how the total deferral is to be apportioned among these companies. To change your elective deferral amount, your elective deferral percentage, your selected investment company or companies, your apportionment of deferrals among these companies, or your division of your contribution to a particular company between Traditional and Roth contributions, you must submit a new Salary Reduction Agreement to your employer.

Employer Paid Contributions
In some instances employers will enhance total compensation packages by making employer discretionary contributions to the 403(b) program on behalf of certain employees, ordinarily for upper level administrators. Employees receiving such benefits must sign participation agreements that specify the investment company or companies into which such contributions are to be deposited and how the total contribution is to be apportioned among these companies. To change the selected investment company or companies or the apportionment of contributions among these companies, the employee must submit a new participation agreement to the employer.

Reapportioning Contributions
As described above under Elective Deferrals and Employer Paid Contributions, reapportioning contributions among selected investment companies is accomplished by submitting a new Salary Reduction Agreement or a new participation agreement to your employer. An online version of your employer's Salary Reduction Agreement is available within your school district's section of this CCC website. You may complete the form online, print it, sign it, and submit the completed form to the appropriate District office.

Redividing Contributions
As described above under Elective Deferrals, redividing contributions to a specific investment company between Traditional and Roth contributions is accomplished by submitting a new Salary Reduction Agreement to your employer. An online version of your employer's Salary Reduction Agreement is available within your school district's section of this CCC website. You may complete the form online, print it, sign it, and submit the completed form to the appropriate District office.

Reallocating Contributions
Initially monthly contributions apportioned to a specific investment company are allocated among the company's investment funds as specified in the application for annuity contract or custodial account. Such allocations may be changed by the participant in various ways, depending on the company involved (online via the company website, by telephone, or by reallocation form). Reallocating contributions is a transaction that is handled directly between the participant and the investment company. The employer is not involved. Check the Authorized Vendors page on your District's section of this CCC website for availability of an online form.

Internal Transfers
After contributions have been made to various accounts or funds of a particular investment company, accumulated balances may be transferred to other 403(b) accounts or funds of the same company. Such transfers may be accomplished by the participant in various ways, depending on the company involved (online via the company website, by telephone, or by transfer form). Internal transfers are transactions that are handled directly between the participant and the investment company. The employer is not involved. Check the Authorized Vendors page on your District's section of this CCC website for availability of an online form. Currently it is not possible to transfer money from a Traditional 403(b) account to a Roth 403(b) account.

External Exchanges and Transfers
After contributions have been made to various accounts or funds of a particular investment company, accumulated balances may be exchanged or transferred to 403(b) accounts of a different investment company. Such transfers are authorized by Revenue Ruling 90-24, strengthened by the new 403(b) Regulations, and generally require coordination of effort between the two companies involved. The new 403(b) Regulations distinguish between contract exchanges within the plan and plan-to-plan transfers. For our purposes, both types of transactions will be referred to simply as transfers.

Ordinarily the company transferring the funds requires the participant to submit a transfer request form. In addition, the transferring company requires a letter of acceptance from the company receiving the transferred funds. Finally, the transferring company requires verification that the receiving company has entered into an Information Sharing Agreement (ISA) with the Employer or the Employer's representative (e.g., with a Third Party Administrator on behalf of the Employer). Of course, an account must be established at the receiving company before an exchange or transfer is possible. This is done by submitting an application to the receiving company. External transfers are transactions that are handled directly between the participant and the two investment companies involved. Neither the Employer nor CCC is involved, except that CCC makes available on its website the facts that the Employer allows exchanges/transfers and that the receiving vendor has entered into an ISA with CCC. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms. Currently it is not possible to transfer money from a Traditional 403(b) account to a Roth 403(b) account.

Internal Rollover Distributions
Once account balances become eligible for distribution, they may be rolled over into different types of eligible retirement plans (IRA, 401(a), 401(k), 457(b), etc.). If a particular company provides investment vehicles for a different eligible retirement plan type, it may be possible to rollover 403(b) account balances into another type of plan within the same company. Generally, such rollover distributions require completion and submission of appropriate company forms. Internal rollover distributions are transactions that are handled directly between the participant and the investment company. The employer is not involved. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms. Currently it is not possible to make a rollover distribution from a Traditional 403(b) account to a Roth 403(b) account. On the other hand, if money in a Traditional 403(b) account is eligible for distribution, then it may be rolled over into a Traditional IRA and then transferred to a Roth IRA. However, taxes must then be paid on the amount rolled over from the Traditional IRA to the Roth IRA.

Caution - To be an eligible distribution, one of the following criteria must be met:

  • Attainment of age 59 1/2
  • Severance from employment
  • Death
  • Disability

External Rollover Distributions
Once account balances become eligible for distribution, they may be rolled over into different types of eligible retirement plans (IRA, 401(a), 401(k), 457(b), etc.). It may be possible to rollover 403(b) account balances into a different plan type account of a different investment company. Generally, such rollover distributions require completion and submission of appropriate company forms for both companies. External rollover distributions are transactions that are handled directly between the participant and the two investment companies. Neither the Employer nor CCC is involved unless the distributable event is severance from employment before age 59 1/2. In this latter situation, the Employer must certify that employment has been severed. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms. Currently it is not possible to make a rollover distribution from a Traditional 403(b) account to a Roth 403(b) account. On the other hand, if money in a Traditional 403(b) account is eligible for distribution, then it may be rolled over into a Traditional IRA and then transferred to a Roth IRA. However, taxes must then be paid on the amount rolled over from the Traditional IRA to the Roth IRA.

Standard Distributions
Once account balances become eligible for distribution, they may be distributed to the participant or the designated beneficiary. Generally, such distributions require completion and submission of an appropriate vendor company form. Distributions are transactions that are handled directly between the participant and the investment company. The employer is not involved. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms.

403(b) Hardship Distributions
Click on the above link for the rules that apply to 403(b) hardship distributions. Hardship distributions are optional features that may or may not be allowed in an Employer's 403(b) TSA Plan. Your Employer's 403(b) Plan Document will specify whether or not hardship distributions are allowed in your 403(b) Plan. Some 403(b) annuity contracts and custodial accounts have hardship distribution provisions and others do not. However, the Plan Document takes precedence over provisions in the underlying annuity contract or custodial account agreement. An immediate and heavy financial need of the participant may justify a hardship distribution, even when the participant would not otherwise be eligible for a distribution. The hardship distribution rules may also be found on the Policies & Procedures page on your District's section of this CCC website. Generally, such hardship distributions require completion and submission of an appropriate company form. Prior to January 1, 2009, hardship distributions are transactions that are handled directly between the participant and the investment company. However, in certain circumstances the employer must be notified that a hardship distribution has been made, because elective deferrals must be suspended for six months following certain types of hardship distributions. After December 31, 2008, all hardship distribution applications in CCC Client Districts will be processed by CCC. Keep in mind that hardship distributions are not allowed in the plans of CCC Plan Document Service Only Client Districts. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms.

457(b) Hardship Distributions
Click on the above link for the rules that apply to 457(b) hardship distributions, which are more accurately described as "unforeseeable emergency" distributions. The rules are significantly different for hardship distributions in 403(b) and 457(b) plans.

Loans
Click on the above link for the rules that apply to loans. Loans are optional features that may or may not be allowed in an Employer's 403(b) TSA Plan. Your Employer's 403(b) Plan Document will specify whether or not loans are allowed in your 403(b) Plan. Some 403(b) annuity contracts and custodial accounts have loan provisions and others do not. However, the Plan Document takes precedence over provisions in the underlying annuity contract or custodial account agreement. The loan rules may also be found on the Policies & Procedures page on your District's section of this CCC website. Prior to January 1, 2009, loans are transactions that are handled directly between the participant and the investment company. After December 31, 2008, all loan applications in CCC Client Districts will be processed by CCC. Keep in mind that loans are not allowed in the plans of CCC Plan Document Service Only Client Districts. Check the Authorized Vendors page on your District's section of this CCC website for availability of online forms required for processing loans.