Primer Article: Back To Basics - All About Your Plan Documents
Qualified retirement plans are governed by written plan documents. These documents provide the structure for what will end up being your company's unique retirement plan.
Plan Document Types
IRS pre-approved plans fall under one of 2 categories: Master and Prototype (M&P) or Volume Submitter (VS).
Under these categories, there are 3 plan types: standardized, non-standardized, and volume submitter. Contrary to their names, all plans are designed with your goals and objectives in mind. For purposes of this article, we will acknowledge that another plan type is possible, the individually designed plan document; however, we'll stick to the pre-approved plans as they are far more common.
When discussing plan documents here, we will refer to their flexibility. A plan that can be modified to fit your goals and objectives most fully is flexible.
M&P: Standardized Plan Document
The most inflexible IRS pre-approved plan document type we have is, the Standardized Plan Document must be safe harbor. Which means, generally, that you, the employer, will have fewer choices over the design of the plan. Modifications to the plan are not permitted or at the most severely restricted.
M&P: Non-Standardized Plan Document
Here we see a little more flexibility, but not much, in terms of how you can design the plan with your design consultant. The IRS pre-approved non-standardized plan does not have to be safe harbor. Minor modifications to the plan are permitted, and will be outlined for discussion during your consultation.
VS: Volume Submitter Plan Document
The most flexible plan document you can use without hiring, and paying for, an attorney to draft a plan document suite for you. The VS contains a specimen plan document that offers choices over plan terms, a trust or custodial account, and may also have an adoption agreement containing elective provisions. In other words, we can draft for your plan a single plan document (which is traditionally how a VS is prepared) or a "prototype format" document, in which we will provide an Adoption Agreement as well as the Basic Plan Document (our clients (the fiduciaries) prefer this option for the ease with which it can be reviewed for accuracy and completeness).
Uniglobal Plan Document Suite Components
Plan document suites are comprised of a number of plan-related documents. While Uniglobal has M&P and VS plans, the majority of clients we serve are on our VS plan document (it's the most flexible allowing us to really get the right provisions in the plan for you).
In our Suite of plan documents, the first and most significant we will provide you with is the Basic Plan Document (BPD).
The Basic Plan Document outlines all possible plan provisions and options imaginable. Most retirement plans utilize the Base Plan Document in conjunction with an Adoption Agreement (AA).
The Adoption Agreement, as its name suggests, adopts only those provisions of the Base Plan Document that you want in your company's retirement plan. Customarily, both documents are not shared with plan participants. Plan Participants have their own version of these documents - the Summary Plan Description (SPD).
The Summary Plan Description is formatted most often in a Q&A format. It is written at a reading level that relays complex plan provisions in an easy to understand way. Uniglobal can provide English and Spanish versions of this document.
In addition to the primary plan documents above, your Suite also includes: Participant Plan Highlights, Loan Policy & Procedures, Annual Notices, and QDRO Procedures.
The Participant Plan Highlights is generally a 3-page document that is used to quickly provide participants with a general overview of your plan. It is not a plan document and does not replace your requirement to furnish new and existing plan participants with the SPD. Uniglobal can provide English and Spanish versions of this document.
Our Loan Policy & Procedures document contains important information about the procedures for obtaining a loan from your plan. It outlines the rules for plan loans. It is for you, loan applicants, and those you delegate to manage/facilitate the processing of loan applications for the plan in your organization. This could be an HR Manager, a Payroll Administrator, or any other authorized person you deem capable.
The required Annual Notice is generally for Safe Harbor plans. The annual notice requirements of IRC §414(w)(4) are satisfied in this document we prepare for you and your plan annually for you to distribute to your plan participants. Uniglobal can provide English and Spanish versions of this document.
The QDRO Procedures document outlines what your administrator must do when he or she recieves a DRO. A QDRO is a qualified domestic relations order, the DRO is the domestic relations order. To qualify the DRO procedures outlined in this document must be followed. The distribution team at Uniglobal will work with you to assist in qualifying the DRO, including working with attorney and court requests.
Final Notes As Your Document Provider
As your document provider, Uniglobal is committed to providing you with sound guidance and consult regarding your retirement plan. Together, we assist you in ensuring that your plan and its documents are kept compliant with all applicable laws. We support you in a number of ways, including proactively drafting and presenting you with all mandatory and required interim plan amendments when new laws impacting our industry occur.