FROM: Colin Bishop, Chief of Member Services
SUBJECT: Rescind Benefits Policies Nos. 017 through 020, and Replace with a Consolidated Version, Benefits Policy No. 031
RECOMMENDATION:
title
Recommend that the Board rescind Benefits Policies Nos. 017 through 020 (Required Minimum Distribution Rules, Compensation Limit, Rollovers, and Internal Revenue Code ?415 - Annual Limit), and replace with a consolidated version, proposed Benefits Policy No. 031 (Tax Compliance).
body
BACKGROUND:
SBCERA General Policy No. 005 involves the periodic review of Board policies, and indicates that the Administrative Committee review Administrative and Benefit policies every three years.
Accordingly, staff reviewed the group of four existing Benefits Policies, Nos. 017 through 020, which together cover various aspects of compliance with Internal Revenue Code ("Code") and United States Department of the Treasury Regulations. Because of the significant overlap between these policies, staff has created a single updated policy which consolidates all four existing policies into one. This simplifies previously separate tax compliance policies in a way that is easier for staff to use as a tool for operational guidance. Consolidating these policies in order to make them simpler and more straightforward is also consistent with the Strategic Pillar of "Operational Excellence and Efficiency," outlined in SBCERA's Triennial Strategic Plan for Fiscal Years 2020-2022, and approved by the Board on May 2, 2019.
Additionally, Nancy Hilu and Judith Boyette, from SBCERA's tax counsel Hanson Bridgett, have reviewed the updated policy and provided suggestions. The new policy generally "cleans-up" the previously separate policies, reorganizes the material, and moves a consolidated "Definitions" section to the end of the document. A description of the specific updates is as follows:
Changes to the 401(a)(9) Portion of the Policy (Formerly Policy No. 017)
* Update section references to...
Click here for full text