FROM: Christina Cintron, Chief of Member Services
SUBJECT: Benefits Policy No. 021 (Distribution Restrictions)
RECOMMENDATION:
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Approve and adopt updates to Benefits Policy No. 021 (Distribution Restrictions).
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BACKGROUND:
General Policy No. 005 (Policy on SBCERA Governing Documents) provides for the periodic review of Board policies every three years. Benefits Policy No. 021 (Distribution Restrictions) was last reviewed in August 2022.
Accordingly, SBCERA staff, in consultation with outside tax counsel, have completed a review of Benefits Policy No. 021. This policy addresses distribution restrictions related to the return to work of retired SBCERA members and supplements SBCERA Benefits Policy No. 032 (Retirees Returning to Work). Specifically, it establishes that retired members may not receive pension benefit distributions if they return to work in any capacity with an SBCERA-covered employer unless they have satisfied applicable distribution requirements under state and federal law, which helps ensure compliance with IRS rules and preventing improper in-service distributions.
The review found the policy to be consistent with current practice and appropriate for SBCERA’s program. Based on recommendations from outside tax counsel, staff have proposed clarifying revisions to further strengthen the policy.
Staff recommends renewal of Benefits Policy No. 021 (Distribution Restrictions), with the proposed redline changes reflected in Exhibit A.
COMMITTEE REVIEW:
This item was reviewed by the Administrative Committee at its September 18, 2025 meeting, and recommends Board approval with a 4-0 vote. Trustee Stafford participated in the absence of Trustee Hatch.
BUDGET IMPACT:
None.
STRATEGIC PLANNING GOAL/OBJECTIVE:
Operational Excellence & Efficiency
STAFF CONTACT:
Christina Cintron
ATTACHMENTS:
Exhibit A: Benefits Policy No. 021 (Distribution Restrictions) - Redline
Exhibit B: Benefits Policy No. 021 (Distribution Restrictions)