Page 103 - FebDefComp
P. 103

From:     Gleason, Robert
                To:       Jay Castellano; Lisa Okada; Kim Pearson
                Cc:       Scussel, Sharon
                Subject:  2021 Performance Standard: Review of all four Defined Contribution Plan Documents
                Attachments:  image001.png
                          image002.png
                Hello Jay, Lisa, and Kim,

                Per our existing agreement, Empower has agreed to provide the County with an annual written notice that confirms that Empower has reviewed each of the
                County’s defined contribution plan documents to assure that the documents are maintained up to current compliance standards.

                Sharon Scussel performed this review in October 2020, and her comments are noted in the table below.

                I asked Sharon to review the documents again for 2021 and she confirmed that her comments in the table below are still accurate, and the County remains in
                compliance relative to all four plans.  Also, she looked at the timeline for the two 401(a) documents and they are slated for restatement next year.  On or
                around 9/1/2021, the County should receive restatement packages on the new Empower plan documents for the two 401(a) plans.

                Empower has not yet determined a timeline for restating the 457b documents to the Empower plan documents.  Sharon will notify me and/or the County once
                the timeline has been determined.

                   Plan  Plan Name        Type of Plan  Status of Plan  Plan Document  Plan Document is current for changes in law due  Plan Restatement,  Discretionary
                                                          Type     to key and other applicable guidance  and Interim Plan Amendments
                                                                                            (compliant documents)
                   61869-1  San Mateo Deferred  457(b)  Active  Specimen  There are no required 2020 Interim Amendments  Restatement – April 1, 2020
                         Compensation Plan                         to the 457(b) Plan.      Restatement – January 1, 2019
                                                                                            Restatement  - November 14, 2016;
                                                                                            Restatement - March 21, 2016;
                                                                   In the future, the following Interim Amendment  Amendment #1 - March 21, 2016
                                                                   will be forthcoming (adoption required by
                                                                   12/31/2024):
                                                                       SECURE Act (and Bipartisan Miners Act)
                                                                       CARES Act – RECEIVED SIGNED RCPO
                                                                       April 2020
                   61869-2  San Mateo County 457 Part  457(b) OBRA  Active  Specimen  There are no required 2020 Interim Amendments  Restatement - March 21, 2016;
                         Time, Seasonal and Temporary  (as of      to the 457(b) Plan.      Amendment #1 - March 21, 2016
                         Plan                     3/21/16)
                                                                   In the future, the following Interim Amendment
                                                                   will be forthcoming (adoption required by
                                                                   12/31/2024):
                                                                       SECURE Act (and Bipartisan Miners Act)
                                                                       CARES Act
                   61869-3  County of San Mateo 401(a)  401(a) PS  Active  Pre-Approved  Required Interim Amendment in 2020:  BBA Final Hardship Interim
                         Retirement Plan                               Final Hardship Regulations (issued  Amendment
                                                                       9/23/19)             Amendment #5 – April 1, 2020
                                                                           Includes changes in law under  Amendment #4 – June 1, 2019
                                                                                            Amendment #3 – June 1, 2019
                                                                           the Tax Cuts and Jobs Act of  Amendment #2 - November 14,
                                                                           2017 and the Bipartisan Budget  2016
                                                                           Act of 2018      Amendment #1 - March 21, 2016;
                                                                                            Restatement - January 1, 2016;
                                                                           Adoption deadline extended to
                                                                           December 31, 2021
                                                                       Interim Amendment adopted in 2020
                                                                       and provided to Sponsor
                                                                          ______________________________
                                                                   In the future, the following Interim Amendment
                                                                   will be forthcoming (adoption required by
                                                                   20204):
                                                                       SECURE Act
                                                                       CARES Act
                   61869-4  County of San Mateo Part Time,  401(a) PS  Frozen  Pre-Approved  Required Interim Amendment in 2020:  BBA Final Hardship Interim
                         Seasonal and Temporary  OBRA  (as of          Final Hardship Regulations (issued  Amendment
                                                                                            Amendment #1 – January 1, 2016
                         Retirement Plan          3/21/16)             9/23/19)             Restatement - January 1, 2016;
                                                                           Includes changes in law under
                                                                           the Tax Cuts and Jobs Act of
                                                                           2017 and the Bipartisan Budget
                                                                           Act of 2018
                                                                           Adoption deadline extended to
                                                                           December 31, 2021
                                                                       Interim Amendment adopted in 2020
                                                                       and provided to Sponsor
                                                                   In the future, the following Interim Amendment
                                                                   will be forthcoming (adoption required by
                                                                   12/31/2024):
                                                                       SECURE Act
                                                                       CARES Act

                Best Regards,

                Robert Gleason  | Client Relationship Manager | Government Markets
                Empower Retirement
                8515 E. Orchard Rd. 4T2  |  Greenwood Village, CO 80111
                860-835-8093 direct  |  916-765-5566 mobile  |  Robert.gleason@empower-retirement.com
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