CCC Breaking News - Changes Ahead

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.

Model Language Published
The above link leads to the Revenue Procedure 2007-71, which was published by the Treasury Department on November 27, 2007. This Revenue Procedure provides model language that may be used to generate written plans (Plan Documents), required to be in place for 403(b) plans by December 31, 2008. Moreover, guidance is provided for other requirements imposed by the Final 403(b) Regulations. CCC will provide draft Plan Documents for all Full and Transitional Service client Districts for adoption by March 31, 2008.

403(b) Final Regulations Released
The above link leads to the 403(b) Final Regulations, which were released by the Treasury Department on July 23, 2007. Under these new regulations, public school districts and education service districts will be held responsible for numerous 403(b) Program administrative functions formerly limited to 401(k) Plans in the for-profit sector. These new responsibilities must be taken very seriously, for otherwise the 403(b) Program could lose its tax-advantaged status. Click here to review District options in preparing for the new 403(b) Regulations. To protect CCC intellectual property, this information is protected and requires User ID and Password for access. Contact Us and request access to this section of the website.

Impact of Final Regulations
The above link leads to a two-page summary of the most critical impacts the 403(b) Final Regulations will have on Public School Districts. Alternatives for meeting the new requirements are provided and compared.

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

The Integrative Advisor (Vol 1, No 1)
The primary purpose of the Association for Integrative Financial and Life Planning is to help bridge the gap between financial and life planning specialists, by supporting the development of methods and tools to further integrate them, and by supporting the establishment of viable ways for individual practitioners to work together. The Integrative Adviser advances this goal by providing education and publicity concerning holistic planning and advice concepts to our primary constituencies: the financial industry (financial companies and advisers), the life planning movement (individual practitioners and organizations that support them), other supporting organizations (such as employers and voluntary associations), and the broader community (including journalists, academics, and the general public).

The Integrative Adviser is distributed electronically six times a year by the Association. To be added to the distribution list, contact the General Editor. The General Editor is Charles S. Yanikoski ( ). There is currently no charge for inclusion on the distribution list.

EGTRRA 2001 - Roth 403(b) Accounts
Roth 403(b) accounts became available on January 1, 2006. Check out Section 617 in the Economic Growth and Tax Relief Reconciliation Act of 2001 for the details.

Roth 401(k) Temporary Regulations
The Treasury Department issued temporary regulations for Roth 401(k) arrangements on March 2, 2005. It is widely believed that Roth 403(b) arrangements should follow Roth 401(k) guidance until Roth 403(b) guidance is provided.

Groom Law Group Comments on Roth 401(k) and 403(b)
Pertinent observations about Roth 401(k) accounts from Groom Law Group in Washington, DC. Most of these observations will be applicable to public school district Roth 403(b) accounts, the primary exception being that no ADP nondiscrimination testing is required.

457 Final Regulations
Full text of the Final Regulations on Section 457 is available at the above link.

National Council on Teacher Retirement Report
This report from the NCTR Washington Counsel (Cindie Moore) to NCTR Members summarizes options presented by staff members of the Joint Committee on Taxation (JCT) for changing the tax treatment of PERS pick-up contributions, cafeteria plan contributions, post-severance 403(b) contributions by employers, and the 15 years of service catch-up provision for 403(b) programs. For the full report, see the Joint Committee on Taxation paragraph immediately below.

Joint Committee on Taxation - Proposed Options
This is the full report from the Joint Committee on Taxation (435 pages), which includes the detailed options presented by staff members of the Joint Committee on Taxation (JCT) for changing the tax treatment of PERS pick-up contributions, cafeteria plan contributions, post-severance 403(b) contributions by employers, and the 15 years of service catch-up provision for 403(b) programs.

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