Retirement Plan Summary of Material Modification (SMM) Disclosure Notices Now Available

Two summary of material modifications disclosure notices are available to explain retirement plan changes to your employees.

In 2013, two features were added to the NRECA Retirement Plans. These changes affect all co-ops that participate in the Retirement Security Plan (RS Plan) and the 401(k) Pension Plan (401(k) Plan).

As required by the Department of Labor (DOL), NRECA has prepared two summary of material modifications (SMM) disclosure notices to explain the changes to your participants.

Deliver the RS Plan SMM and/or the 401(k) Plan SMM to current plan participants by July 28, 2014. Then complete the acknowledgement form and return it to Benefits Compliance via fax or email by August 1, 2014.

Combined distribution instructions and an acknowledgement form are on Cooperative.com under the Employee Benefits section of the website.

Since the SMM is an official addendum to your co-op’s summary plan description (SPD), instruct participants to keep it with the SPD. Also include a copy of each SMM with its respective SPD when you give the SPD to newly eligible participants. The changes described in the SMM will be incorporated into your plan’s SPD the next time it is revised.

Electronic Distribution
DOL regulations allow employers to give out SMMs electronically (usually via email) only to certain employees who can “effectively access” the documents through computers that are an “integral part” of their work duties. Other participants–for example, linemen and meter readers–must receive paper copies. Detailed information about electronic distribution of SMMs and other ERISA-required notices is on the BA Assistant section of Cooperative.com.

If you have questions about the SMMs or about the distribution process, contact the NRECA benefits compliance team at 1.866.673.2299, option 7, or group.compliance@nreca.coop.