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Ministry Leader,
Soon you will be reading many articles about the
significant changes coming in 403(b) plans. My objective
here is to outline those changes and provide a perspective for those
ministries currently served by Envoy, and those who are not yet served.
Here are the highlights of what you will be reading:
- There
will be increased scrutiny of 403(b) plans by the IRS
- Employers
will be responsible for the design, implementation and oversight of the
plans
- Employee's
investment options will be determined by the employer's investment
option selection
- Employers
will have a fiduciary responsibility for their plan
- Employers
will be responsible for the plan design and administration and will be
involved in loan and distribution oversight
- Church
plans may be exempt from ERISA regulations as they are now, or there
may be some increased oversight responsibility as will be true for
ERISA 403(b) plans that the rest of the 501(c)(3) ministries live with.
These plans are now referred to as "ERISA Light" as there are no audit
requirements and the 5500 filing is vastly simplified.
In simplified form, the ERISA 403(b) plans will look
much more like the current 401(k) plans used primarily in the
for-profit sector. Some ministries have adopted the 401(k) plan
now, but in doing so have chosen to increase their costs compared to
the 403(b) option as well as limiting many of the specialized tax
advantages unique to 403(b) plans and not existing in the 401(k)
alternative. The differences contained in the 403(b) plans primarily
impact missionaries and pastors.
So what has been Envoy's stance and approach knowing that these changes
were coming? 3-4 years ago we realized that the regulatory
direction was most likely to move in the direction of greater employer
responsibility for their ministry's retirement plan. The days of
"laissez-faire" were numbered.
Parenthetically, one of the primary markets for 403(b) plans is the
public school K-12 marketplace. Here school districts often allow
their staff to select from many vendors and simply act as a conduit for
contributions. In California, for example, many school districts
will have upwards of 40 approved vendors and will send monies to all of
them at the discretion of the employee. Most likely, those days
are over. As you read articles on the "changes in 403(b)" they
are often directed at the changes that may be required by public school
voluntary retirement plans. These issues are significantly
different from those faced by 501(c)(3) ministries. Do not try to
connect their issues to yours. However, there are still 501(c)(3)
ministries that are acting just like the school districts, allowing
employees to chose vendors and simply acting as a conduit for their
tax-deferred funds. Those days are coming to a close also.
So, back to Envoy's perspective on these changes. Believing that
employer plan oversight was coming, we have already moved our support
systems and plan set-up to reflect this new reality. We counsel
diversified investment options, hands-on advice for participants, while
providing a singular place for plan administration, support and
ministry counsel. We position ourselves as counsel to you and
your staff, while providing the oversight and review information that
will be required by the IRS as their scrutiny increases.
Simply said, we have prepared the ministries we serve and we have
developed the administrative support systems that fit hand-in-glove
with what is coming. This means that the coming changes will have
minimal impact on those we already serve, and that we are positioned to
ease the transition to the new reality for those we do not.
We have positioned our ministry to serve yours. Our recent move
to a Preferred Pension Administrator for those who use the Nationwide
investment platform and the transition to Retirement Solutions Premier
Group plan for most ministries are examples of how we plan to take our
support function to the next level. Our service to you is best
characterized as "your retirement plan support system." Another
way to say it, "We've got your back."
As the IRS divulges more we will keep you advised. Until then,
grow your ministry and let's change lives together.
Blessings,
Bruce Bruinsma
CEO & Co-Founder
Envoy Financial
Trusted Advice Along The Way

Envoy Financial 5350 Tomah Drive, Suite 2500, Colorado Springs, CO 80918
(888) 879-1376 • Fax: (719) 268-2716 • envoy@envoyfinancial.org • www.envoyfinancial.org
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