IRS Provides Guidance on 403(b) Plan Remedial Amendment Periods
Revenue Procedure 2019-39 sets forth a system of recurring remedial amendment periods for correcting form defects in 403(b) individually designed plans and 403(b) pre-approved plans occurring after the initial remedial amendment period ends on March 31, 2020.
In April 2013, the IRS issued Revenue Procedure 2013-22 establishing a pre-approved plan program for 403(b)s and offered a remedial amendment period for 403(b) plan documents. The last day of the remedial amendment period for 403(b) plans is March 31, 2020.
Now, the IRS has issued Revenue Procedure 2019-39 setting forth a system of recurring remedial amendment periods for correcting form defects in 403(b) individually designed plans and 403(b) pre-approved plans occurring after the initial remedial amendment period ends. It also provides a limited extension of the initial remedial amendment period for certain form defects. The IRS says issues that cannot be retroactively amended may be corrected under its Employee Plans Compliance Resolution System (EPCRS).
Rev. Proc. 2013-22 provides that the IRS expects future guidance to require the restatement of 403(b) pre-approved plans every six years. Accordingly, the new revenue procedure establishes a system of 403(b) pre-approved plan cycles under which an entity offering a pre-approved plan document may submit a proposed 403(b) pre-approved plan for review and approval by the IRS. Once approved, the plan may be made available for adoption by eligible employers.
Revenue Procedure 2019-39 also provides deadlines for the adoption of plan amendments for 403(b) individually designed plans and pre-approved plans.
In the revenue procedure the Department of the Treasury and the IRS announce they intend to issue additional guidance, prior to the date that 403(b) pre-approved plans may next be submitted for review, relating to the system of recurring remedial amendment periods and the system of recurring pre-approved plan cycles.
Woodbury Financial Partner Recruits Advisers to Greensboro Location
Woodbury Financial Services and affiliated office GCG Wealth Management have announced that GCG has recruited five advisers with a total of $330 million in client assets to its new Greensboro, North Carolina office.
Woodbury Financial Services is part of Advisor Group, one of the nation’s largest networks of independent wealth management firms, comprised of FSC Securities Corporation, Royal Alliance Associates, SagePoint Financial and Woodbury Financial.
The new recruits, all of whom joined GCG on the same day, include George Harris, Shell York, Billy Ricketts, Clay Craven and Garrett Mullins.
Founded in 1994, GCG is headed by President and Managing Partner Joel Burris. The firm’s affiliation model—which it refers to as the “Adviser-Preneurial” approach—gives advisers the option to join GCG as W2 employees, while still enjoying the benefits of full independent status in their affiliation with Woodbury.
“As today’s announcement demonstrates, GCG Wealth Management’s unique value proposition continues to resonate strongly with advisers from every channel of the industry,” says Burris. “Our approach gives advisers a level of support, tools and infrastructure that is truly exceptional in the independent space, while also providing them the freedom to pursue success on their own terms. Both Woodbury and Advisor Group have been amazing partners to us since we joined their platform earlier this year. Not only have they worked tirelessly to ensure our smooth transition, they’ve gotten in the trenches with us to support our recruiting and growth goals. We are thrilled to welcome these five advisers to our team and are eager to help them build their businesses here at GCG.”
In recent years, GCG has experienced asset growth as Burris and his team have actively recruited advisers from wirehouse firms and across the independent channel. At the end of 2017, GCG had nearly $500 million in client assets; it now has 34 affiliated advisers in eight offices across the southeastern United States, with more than $1 billion in total client assets. The firm opened its office in Winter Park, Florida, which now has over $100 million in client assets, less than a year before recruiting the five advisers above and opening its Greensboro office.
MassMutual Selects Workplace Solutions Leader
Gina Golson Nunery has been appointed head of consultant relationsfor Workplace Solutions by Massachusetts Mutual Life Insurance Company (MassMutual) in support of retirement plans.
Golson Nunery is responsible for developing and enhancing relationships nationwide with retirement consulting firms that serve corporate, Taft-Hartley, government, multiple-employer and not-for-profit plans. She reports to Una Morabito, head of client management for MassMutual’s Workplace Solutions.
“Gina will lead our efforts to share our Workplace Solutions story to our consultant network as part of MassMutual’s support for retirement plans,” says Morabito. “Gina’s experience in the retirement plans industry will be a real plus for consultants and retirement plan sponsors.”
Golson Nunery is part of a nationwide network of relationship managers and account managers who support large retirement plan sponsors and their participants. Client managers and account managers are responsible for helping employers, consultants and financial advisers make the most of 401(k), 457 and 403(b) defined contribution retirement plans as well as defined benefit plans for employees.
An industry veteran with more than two decades in relationship management, proposal development and negotiation, Golson Nunery joins MassMutual from TIAA-CREF where she was senior director of consultant relations. Previously, she also served in a number of roles at TIAA during her 18 years with the company, including relationship management and market and business development positions. Prior to TIAA, she held financial services roles with The Vanguard Group and Cigna.
Golson Nunery attended West Chester University, holds Series 24, 7 and 63 licenses, and is an accredited investment fiduciary.
“Gina has been consistently recognized during the past two decades for her motivation and leadership skills, forward-thinking ideas, efficient issue management and advanced problem resolution skills,” says Morabito. “We look forward to her partnership and ideas as we all work to help more Americans achieve financial wellness in the Workplace.”
NAGDCA Elects 2020 Governing Officers
The National Association of Government Defined Contribution Administrators, Inc. (NAGDCA) elected its 2019-2020 governing officers and members-at-large at the organization’s annual conference.
Sandy Blair will preside over the new board as board president. Blair is the director of retirement readiness for the California State Teachers’ Retirement System (CalSTRS). She rose through the ranks in CalSTRS after arriving in 2009 to a management position in CalSTRS’ office of Client Outreach and Guidance and was instrumental in establishing the model of CalSTRS first Member Service Center in West Sacramento. Blair administers the CalSTRS Pension2 personal wealth plan, which consists of 403(b), 457 and Roth 403(b) plans. Pension2 serves as a supplemental savings plan for all California school and community college employees. Blair also has extensive private sector experience in consumer banking, finance and tax preparation.
Other NAGDCA members elected to the Executive Board include Josh Luskin, Indiana Public Retirement Systems; Rob Boehmer, State of Nevada; Darlene Malaney, Palm Beach County Clerk & Comptroller; Kelly Hiers, Virginia Retirement System; Cindy Rehmeier, Missouri State Employees’ Retirement System; Ketul Thaker, Voya Financial; and Jake O’Shaughnessy, SageView Advisory Group.
Wagner Law Group Adds ERISA Attorney
The Wagner Law Group has addedKim Shaw Elliott to the firm as of counsel in its St. Louis office.
“Kim is a recognized expert in in her fields of practice with an extraordinarily unique wealth and depth of experience; we are excited that she will be joining us, ” says Marcia Wagner, managing director of the firm.
Elliott is an ERISA [Employee Retirement Income Security Act of 1974] investment lawyer, engaging in a multi-disciplinary practice helping clients successfully navigate the complex intersection of ERISA, securities law, broker/dealer regulation and tax regulation. Elliott represents broker/dealers, investment advisers, insurance companies and other entities nationwide, with a focus on fiduciary responsibility and best practices. She brings a business leader’s perspective to the practice of law, having served as an executive responsible for advisory services to retirement plans, as well as a chief compliance officer. As general counsel of industry leading broker/dealer and investment adviser firms, Elliott navigated through extensive claims litigation, multi-state regulatory actions and errors and omissions disputes, and presented actionable plans and guidance for compliant sales, operations, product development and customer service.
Elliott is a three-time graduate of Washington University in St. Louis, where she earned her J.D., LL.M, and executive MBA. She is a member of the compliance and legal division of the Securities Industry and Financial Markets Association (SIFMA), was named president emeritus of the Association of Corporate Counsel (St. Louis), chaired the Employee Benefits Committee of the Missouri Bar, and is a frequent speaker on employee benefits and securities-related topics. Elliott is licensed to practice law in Illinois and Missouri. She formerly held Series 7, 66 and 24 securities licenses.
