THE PENTEGRA 3(16) ADMINISTRATOR

ADVANTAGE
Shift legal and operational burdens
of the Plan Administrator role
from your organization to ours.
 Pentegra’s 3(16)(A) Fiduciary Administration Services
Plan Operational Oversight Plan Document Administration New Hire and Termination
and Compliance Processing

• Accept responsibility under ERISA • Prepare plan document and ensure • Identify eligibles based on plan
404(a)(1)(D) for ensuring that the plan compliance with applicable laws provisions and employer-provided
is operated in accordance with the • Prepare plan adoption and trust data and automatically mail packet to
terms of the plan document subject agreements address of record
to the fulfillment of any responsibilities • Prepare plan qualification package • Administer auto-enroll provisions
retained by the employer • Ensure plan document is amended • Complete, up-to-date enrollment
• This is an extremely broad as required by new laws, regulations, materials
responsibility: “operational compliance” and mandatory restatements • Online enrollment process with live
is a catch-all term covering nearly • Obtain favorable letters of telephone backup
everything that can go wrong in a determination
retirement plan • Maintain records of historical
• Includes the many requirements that plan documents
must be met for a plan to be “qualified”
for tax purposes
• Ensure proper documentation and
ERISA 107/209 records retention

Participant Fee Disclosure Hardship Distributions Loans and Loan Repayments

• Compliance with DOL Reg. Sec. • Cross-reference plan document rules • Establish written loan policy as
2550.404a-5 since each plan may be different supplement to plan document
• Gather fee information from third • Test for both existence and amount • Review and approve loans; remove
parties and collate the data to create of need employer from loop except for
the plan’s disclosure documents • Take only from allowable sources and payroll deductions
• Ensure timely delivery of disclosures only after exhausting loans and ISDs • Ensure amortization periods match
annually and to newly eligible • Suspend deferrals for six months and actual payroll implementation
employees in accordance with the reinstate promptly when applicable • Ensure each loan agreement is
DOL’s rules on document delivery • Keep careful documentation of every executed and documented
distribution for the ERISA 107 period • Enforce quarterly deadlines and
deemed distribution requirements

Distributions and QDROs Forfeitures and Suspense Accounts Corrections and E&O

• Review and ensure the qualified status • Ensure that all unallocated monies are • SCP, VCP, Audit CAP, DFVCP, and VFCP
of domestic relations orders (DROs) used to offset employer contributions, calculations, preparation of government
• Ensure that alternate payees are given pay plan expenses, or are allocated to submission, follow-up, and
their ERISA participant rights participants by plan year end implementation of corrections
• Review and approve distributions, • Includes revenue sharing held within • Maintain an E&O account for trusteed
including determinations of disability, the plan, monies returned to the plan plans to ensure an audit trail for
death, retirement, or other such as expense reimbursements, corrections
distributable events forfeitures, demutualization proceeds, • Maintain insurance and reserves at
• Ensure that the appropriate notices are legal settlements, etc. appropriate levels at or in excess of
delivered and that the tax withholding regulatory requirements
rules are properly applied
 Service Provider Selection and Participant Notices, Statements Plan Audit
Oversight and Disclosures

• Prudent hiring of service providers not • Preparation of notices and • Select and monitor plan auditor in
appointed directly by employer such as disclosures such as SPD, SMM, SAR, accordance with joint DOL/AICPA
auditor and custodian 404(c), QDIA, ACA, Safe Harbor, guidelines
• Review vendor fee disclosures and and 402(f); contrast with how a • Negotiate volume discounts
ensure reasonableness of fees non-fiduciary TPA provides a • Serve as primary liaison with auditor;
• Responsibility for the reasonableness boilerplate document the employer is remove employer from loop to the
of Pentegra’s own fees (though only the supposed to review and approve maximum extent possible
employer can make the final • Ensure document delivery compliant • Prepare plan financial statements to
determination) with DOL rules on electronic meet the letter of AICPA independence
• Regular monitoring of Pentegra- disclosure guidelines
appointed service providers to ensure • Includes beneficiaries, alternate payees, • Obtain and make available an SSAE 16
they remain prudent and fees remain and other “interested parties” audit on internal controls to allow for a
reasonable limited scope audit

Contributions Government Filings Compliance Testing

• Establish and enforce ERISA 402 • Prepare and submit filings such as Form • Determine plans to include for
funding policy for timing of remittances 5500 Annual Report with applicable compliance testing
• Maintain proper source accounts and Schedules, Form 5558 extensions, • 401(a)(4) Nondiscriminatory
tax basis Form 5330 prohibited transaction Allocations
• Ensure proper investment of tax reports, PBGC premium filings, • 401(a)(9) RMD
contributions of “defaulted” and more • 401(a)(26) Minimum Participation
participants • Tax reporting, state and federal, testing
• Ensure rollovers into the plan are from including 1099-R, 1096, 945, and • 402(g) Excess Deferrals
qualified sources 1099-MISC • 404 Maximum Deductible
Contributions
• 410(b) Minimum Coverage testing
• 414(s) testing for non-safe harbor
compensation
Claims and Benefit Determinations Annual Plan Review Process • ADP/ACP testing
• 415 Annual Addition testing
• Establish and administer ERISA- • Establish plan governance process and • 416 Top Heavy testing
compliant claims process checklist • Nondiscriminatory Benefits/Rights/
• Verify identity of beneficiaries • Provide completed checklist and annual Features
• Make benefit determinations in review report annually • Determine Highly Compensated
accordance with the plan document • Review service provider performance Employees and key employees
and ERISA and fees • Prepare comprehensive compliance
• Ensure QJSA/QPSA rules are met and reporting package
proper waivers obtained, including • Provide detailed analysis of testing
spousal consent on all loans and results
distributions with respect to protected • Develop corrective scenarios in the
sources event of test failures

The Pentegra 3(16) Advantage: We don’t merely help with these tasks, we are responsible for them.
2 Enterprise Drive, Suite 408 Shelton, CT 06484-4694 800•872•3473 tel 203•925•0674 fax www.pentegra.com
© 2015 Pentegra Retirement Services All Rights Reserved
 What makes an ERISA 3(16) fiduciary important?

Difference: Us PENTEGRA TPA ADVANTAGE

Pentegra offers a comprehensive array of Third Party Administrative
Retirement plans with the
highest level of integrity Services. Our in-house ERISA attorneys, consultants and compliance
specialists are knowledgeable, experienced and trained to handle the
varying complex issues surrounding retirement plans. Our flexible
arrangement can include an existing recordkeeper, trustee or
investment manager.

Advantage: Yours PLAN DESIGN & DOCUMENT SUPPORT

 Prototype or custom designed plan documents
The path to plan success
 Summary Plan Descriptions (SPDs)
 IRS Determination Letter Submissions (IRS Form 5300/5307)

 Plan amendment and restatement services

 Plan design consulting
 IRS Determination Letter Submissions (IRS Form 5300/5307)
 Plan amendment and restatement services
At Pentegra Retirement
 Plan design consulting
Services Our Difference is Your
Advantage.
PLAN COMPLIANCE SUPPORT
 Determination of plans to include for compliance
testing
 401(a)(4) Nondiscriminatory Allocations
 401(a)(9) Compensation Limitation
 401(a)(26) Minimum Participation (Defined Benefit
Plans)
 402(g) Excess Deferrals
 404 Maximum Deductible Contributions
 410(b) Minimum Coverage Testing
 414(s) Testing for Non-Safe Harbor Compensation
 ADP/ACP Testing
 415 Annual Addition Testing
 416 Top Heavy Testing
 Nondiscriminatory Benefits/Rights/Features
 Determination of highly compensated employees
LEGAL SUPPORT
 Review of Qualified Domestic Relations Orders
(QDRO)
 Annual ERISA Notices, including:
 QDIA, QACA and ACA)
 Safe Harbor notice
PLAN ADMINISTRATION
 Special Handling For “Hard-To-Value” Assets
 Confirm Contributions Deposited Correctly By
Source
 Annual Employer Valuation Report
 Related Companies/Common Ownership Review
 Fidelity Bond Requirements Check
ANNUAL PLAN CALCULATIONS
 Employer contribution allocations
 Profit sharing calculation with New
Comparability Analysis
 Profit Sharing calculation with Age-Weighted,
Integrated Analysis
 Forfeiture allocations
Learn more about Pentegra’s TPA Advantage. Contact the Pentegra Solutions Center at
solutions@pentegra.com, or 855-549-6689.
Pentegra Retirement Services 2 Enterprise Drive, Suite 408 Shelton, CT 06484 www.pentegra.com
 Comprehensive compliance reporting package
 Analysis of testing results
 Corrective scenarios in the event of failure
 Preparation of Government filings
 IRS Form 5500 and applicable schedules
 (A, C, D, E, G, H, I, R, MB, SB, SSA)
 Summary Annual Report (SAR)
 RS Form 5558 (Extension for Form 5500)
 IRS Form 5330
 PBGC Premium filings
 Tax reporting, including Form 1099-R, 1096,
 945 and 1099-MISC
 Required minimum distribution notification
 Voluntary Compliance Program Submissions (VCP)
 Legislative and regulatory updates
 Automatic enrollment notice
 Required minimum distribution notification
 Summary Annual Report
 Voluntary Compliance Program Submissions (VCP)
 Legislative and regulatory update
 Applicability of Joint & Survivor Annuity
Requirements
 Review and Update Census Data
 Review of plan eligibility, re-entry, rehires, forfeiture
restoration
 Review of plan matching and other contribution
 Vesting calculations