MetLife Resource (MLR) Certification Training · Certification training is recommended before...
Transcript of MetLife Resource (MLR) Certification Training · Certification training is recommended before...
For use only by former MPCG Advisors who have transitioned to Mass Mutual 1
MetLife Resources Sales Support
888-377-8999 / [email protected]
Updated November 2019
MetLife Resource (MLR) Certification Training
For use only by former MPCG Advisors who have transitioned to Mass Mutual 2
MetLife Resources Overview
– Importance of MLR
Certification Training
– MLR Business Overview
403(b) Plans – Tax
Sheltered Annuities (TSAs)
– ERISA
– 403(b) Regulations
457(b) Plans
Table of Contents
401(a) and 401(k) Plans
403(a) Plans
State Specific Retirement Plans
Maximum Allowable
Contributions (MAC) Calculations
Thank You and Next Steps
For use only by former MPCG Advisors who have transitioned to Mass Mutual 3
MetLife Resources Overview
MetLife Resources (MLR) is a division of Metropolitan Life Insurance
Company (MetLife) that specializes in providing retirement plan products
and services to healthcare, educational, governmental and other
not-for-profit employers and their employees
• Optional Retirement Program (ORP)
• Public Employee Retirement
Association (PERA)
State-specific retirement plans
Each of these employer groups is
allowed to sponsor a retirement plan for
its employees’ participation under one or
more Internal Revenue Code sections
403(b), 457(b) ,401(a), and 403(a)
For use only by former MPCG Advisors who have transitioned to Mass Mutual 4
MetLife Resources Certification Training
• Exclusively available to former MPCG advisors who have transitioned
to MassMutual
• Provides the advisor with knowledge to market to new participants and
service existing participants in existing MLR groups (excluding ERISA and
their affiliated non-ERISA groups) in the not-for-profit marketplace. MLR
Certification training is recommended before marketing within an MLR group
• Provides the advisor with knowledge to understand how 403(b)Tax Sheltered
Annuities (TSAs) and Deferred Compensation Plans (DCP) operate and the
tax advantages of each
• Provides the advisor with knowledge to understand the retirement benefits by
learning the key provisions, and understand the tax code provisions that
regulate payroll contributions to qualified plans
Why is MLR Certification Training important?
For use only by former MPCG Advisors who have transitioned to Mass Mutual 5
MLR Business Overview
*Note that as of 4/10/2017, former MPCG advisors who have transitioned to MassMutual may no longer sell/service ERISA 403(b) groups and their affiliated non-ERISA groups.
(This change does NOT impact existing brokers from other broker dealers.)
MetLife and
Brighthouse
Products Sold
in Existing
MLR Plans
• Fixed Annuities
• Variable Annuities
• Mutual Fund
Platform with fixed
account options
Participants
• Teachers
• School Employees
• College Professors
• Doctors & Nurses
• Employees of
Not-For-Profit
Organizations
and churches
Plan Sponsors
• Education
• Healthcare
• Charitable
Organizations
• Government
• Other Not-For-
Profits
• Churches
Markets
• 403(b)
• 457(b)
• 401(a)
• 403(a)
Distribution
• Former MetLife
Premier Client
Group (MPCG)
Advisors who have
transitioned to
MassMutual*
• Selected Third
Party Brokers (on
a grandfathered,
exception basis
only)
MetLife Resources
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MLR Knowledge Check – Question 1 of 1
Select all that apply.
Which of the following include MetLife Resources’
primary plan sponsors?
Healthcare
Sports Agencies
For-Profit Organizations
Education
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MLR Knowledge Check – Answer
Select all that apply.
Which of the following include MetLife Resources’
primary plan sponsors?
Healthcare
Sports Agencies
For-Profit Organizations
Education
For use only by former MPCG Advisors who have transitioned to Mass Mutual 8
403(b) Plans – Tax Sheltered Annuities (TSAs)
*Subject to certain requirements as state tax treatment varies
• A tax-advantaged, defined contribution, retirement savings plan, sometimes
called a tax-sheltered annuity, available for public education organizations,
institutions of higher education, some not-for-profit employers (only 501(c)(3)
organizations), cooperative hospital service organizations and self-employed
ministers in the United States
• May be subject to ERISA. 403(b) plans are either considered ERISA
or non-ERISA
• Employee contributions, which are payroll deducted into a 403(b) plan, are
generally made on a pre-tax basis and are allowed to grow tax deferred;
Withdrawals from the plan are taxed as ordinary income
• 403(b) plans are funded with annuity contracts and/or a mutual fund platform
• Roth contributions may be allowed and are taxable subject to certain
requirements; Earnings on Roth contributions that meet certain requirements are
not subject to Federal income tax*
• Some plans provide for employer match and/or non-match contributions
on behalf of plan participants
• FICA taxes are currently withheld from salary reduction contributions to the 403(b)
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Section 403(b)
• purchase an annuity contract and,
• subject to certain limitations, exclude the amount of the contributions from gross income for
income tax purposes or, otherwise, pay tax and allocate the amount to a Roth account
Section 403(b) of the tax code permits employees of public educational organizations and Section 501(c)(3) nonprofit organizations to:
• Employee authorizes the employer to reduce his/her salary by a specified amount to
contribute to a 403(b)
• Employer forwards this amount to an insurance company to fund a 403(b) on behalf
of the employee
A 403(b) annuity is normally funded by payroll deductions:
No federal income taxes are currently withheld on the portion of salary contributed to the 403(b)
and it is excluded from the employee’s gross income for federal and most state income tax purposes,
(except in the case of designated Roth contributions)
However, FICA taxes are currently withheld from the portion of salary contributed to the 403(b)
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Section 403(b)
Some 403(b) plans have automatic enrollment features that automatically begin
salary reduction contributions when employees become eligible to participate, unless the
participant affirmatively opts out. These automatic enrollment plans are also
known as “negative election” plans.
The tax code limits the amount each employee can contribute to a 403(b) plan.
This amount depends on a number of factors and should be determined annually for
each employee using a formula that complies with applicable tax requirements.
• More details on this will be discussed later in the section on Maximum Allowable Contributions
Each employee who wishes to participate in a 403(b) generally must submit
a “salary reduction agreement (SRA)” (also referred to as an “amendment to
employment contract”) to the employer specifying the amount by which the
employee’s salary is to be reduced.
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What is ERISA?
ERISA, (The Employee Retirement Income Security Act of 1974) is a federal law that
sets standards for pension plans in private industry. It is intended to protect the
retirement plan assets of participants by imposing certain requirements.
• Effective 4/10/2017, MetLife’s ERISA plans (and ERISA-affiliated plans) may not be serviced by former
MPCG advisors who have transitioned to MassMutual.
• A 403(b) plan may not be subject to ERISA requirements if it does not provide for any employer
contributions (e.g. matching contributions) and the employer has a very limited role administering the plan.
This determination is based on the particular facts and circumstances and should be made by the plan
sponsor (not MetLife) in consultation with their own counsel.
• ERISA does not require any employer to establish a benefit plan, however for those that do, they must meet
certain minimum standards as stated below:
– Requires plans to provide participants regularly and automatically with important plan information such as its
features and funding
– Sets minimum standards for participation, vesting, claims processing, benefit accrual and funding. The law defines
how long a person is required to work before becoming eligible to participate in a plan, accumulate benefits and
have a non-forfeitable right to those benefits. In addition, plan sponsors are required to provide adequate
funding for the plan
– Requires accountability of plan fiduciaries. ERISA defines a fiduciary as anyone exercising discretionary authority or
control over a plan’s management or assets, as well as anyone providing investment advice to the plan. Fiduciaries
may be liable for restoring any losses for which they are responsible
– Gives participants the right to sue for benefits and breaches of fiduciary duty
– Guarantees payment of certain pension plan benefits through a federally chartered corporation, known as Pension
Benefit Guaranty corporation, (PBGC). PBGC coverage generally does not apply to MLR customers’ plans.
• Government plans are never subject to ERISA
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ERISA Considerations
• DOL Fee Disclosure Regulations
– Require plan service providers to disclose fees and revenue information to assist plan sponsors in
fulfilling obligations under ERISA rules (Plan-Level Fee Disclosures or "408(b)(2) regulations")
– Require plan sponsors to deliver disclosures and investment information to eligible employees,
participant and beneficiaries (Participant-Level Fee Disclosure Requirements)
• Substantial liability may result from failing to comply with ERISA when a 403(b) plan is
actually covered by ERISA
• Note that 403(b) plans not covered by ERISA may be subject to requirements similar to
ERISA by applicable state law
• Employers should consult with their own tax and legal advisers
• ERISA plans are subject to 5500 reporting and annual audits
Some of the challenges that exist for tax-exempt nongovernmental employers are covered by Department of Labor (DOL) FAB 2010-01 and other recent DOL guidance
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403 (b) Plans – Self-Study
Charges and Fees
Withdrawals
Hardships
Taxation of Withdrawals/Distributions
Loans
Click here to learn about
the following topics
related to 403(b) plans
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403 (b) Retirement Benefits
• A 403(b) annuity contract may be annuitized at any time after becoming
eligible for distribution
• There are 2 periods to an annuity; pay in (accumulation) and payout (annuitization)
• Until a 403(b) account is annuitized, required minimum distribution rules generally
require taxable amounts begin to be distributed by April 1 of the year following the
year the employee turns age 70½, or retires, whichever is later (participant should
consult with tax and legal advisers)
– For example, when a participant turns age 70½ (or, if later, retires) in 2019, he or she must
withdraw a required minimum distribution amount for the year 2019. However, you have until April
1, 2020 to actually receive the 2019 distribution. He or she then must take the distribution for year
2019 by December 31, 2020. Subsequent distributions must be taken by December 31 each year.
Should a participant delay the first distribution until the year after turning 70 ½, he or she will be
taxed on two distributions in the same year.
• The annual required distribution amount is calculated based on life expectancy
tables provided by the IRS
• A federal tax penalty of 50% will apply to any required distribution amounts
that are not taken
• Distributions can be made in one lump sum or at periodic intervals, including as
annuity payments, depending on plan terms
• Income taxes are payable in the year a taxable distribution is received
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403(b) – Payout Options Other Than Lump Sum
Provides income payments during lifetime of annuitant. Upon death of annuitant there are no
payments to beneficiary.
Life Income
Provides income payments for period certain elected (5, 10, 15 or 20 years) or lifetime of annuitant, whichever is
longer. If annuitant death occurs prior to end of elected period, beneficiary will receive payments for remainder of
period certain. Beneficiary may not take remaining monies in lump sum.
Life Income with Period Certain
Provides income payments for lifetime of two annuitants. Upon death of either annuitant, income continues to
survivor for his/her lifetime. Payments to survivor may continue at the same amount or can be a reduced amount
of two thirds or one half.
Joint and Survivor Annuity
Provides income payments for a selected period of time. Periods available are usually 3 to 30 years; This is a
popular option because it allows the annuitant to individually customize distributions in the time period suited for
his/her retirement needs.
Income for a Specified Period (AKA “Income for a Designated Period” or “Period Certain”
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403(b) Knowledge Check – Question 1 of 5
Select the best answer.
Any of the following fees/charges may be assessed
against a Tax-Sheltered Annuity except:
Administrative fee
Separate account charge
Surrender charge
State sales charge
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403(b) Knowledge Check – Answer
Select the best answer.
Any of the following fees/charges may be assessed
against a Tax-Sheltered Annuity except:
Administrative fee
Separate account charge
Surrender charge
State sales charge
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403(b) Knowledge Check – Question 2 of 5
Select the best answer.
How long does a participant have to pay back a loan
that was not used to acquire his principal residence:
2 years
Before retiring or severing employment
10 years
5 years
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403(b) Knowledge Check – Answer
Select the best answer.
How long does a participant have to pay back a loan
that was not used to acquire his principal residence:
2 years
Before retiring or severing employment
10 years
5 years
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403(b) Knowledge Check – Question 3 of 5
Select the best answer.
Generally, required minimum distributions for a
Tax-Sheltered Annuity must begin by April 1st
of what year?
The year following the year in which the employee
turns 70 ½
The year following the year in which the
employee retires or turns 55, whichever is later
The year following the year in which the employee
turns 70 ½ or retires, whichever is later
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403(b) Knowledge Check – Answer
Select the best answer.
Generally, required minimum distributions for a
Tax-Sheltered Annuity must begin by April 1st
of what year?
The year following the year in which the employee
turns 70 ½
The year following the year in which the
employee retires or turns 55, whichever is later
The year following the year in which the employee
turns 70 ½ or retires, whichever is later
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403(b) Knowledge Check – Question 4 of 5
Select the best answer.
After taking a hardship withdrawal from her TSA, for what
length of time will the client generally be prohibited from
making salary reduction contributions to her TSA?
1 year
6 months
2 years
She can make contributions immediately
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403(b) Knowledge Check – Answer
Select the best answer.
After taking a hardship withdrawal from her TSA, for what
length of time will the client generally be prohibited from
making salary reduction contributions to her TSA?
1 year
6 months
2 years
She can make contributions immediately
For use only by former MPCG Advisors who have transitioned to Mass Mutual 24
403(b) Knowledge Check – Question 5 of 5
True or False:
Exchanges can be made between 403(b)
and 401(a) plans.
True
False
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403(b) Knowledge Check – Answer
True or False:
Exchanges can be made between 403(b)
and 401(a) plans.
True
False – Exchanges can NOT be made between
403(b) and 401(a) plans
For use only by former MPCG Advisors who have transitioned to Mass Mutual 26
403(b) Regulations – Effective as of January 1, 2009
Any employer that makes a 403(b) plan available to its employees must adhere
to certain requirements, including, in most cases, adopting and maintaining a
written plan. Subject to certain restrictions, the plan must have been adopted
by December 31, 2009.
• The employer must establish and maintain the plan
– Adopt a written plan document
– Identify the approved providers that are available as part of the plan
– Determine employee eligibility and enforce universal availability requirements
– Determine if the plan will allow employees to effect exchanges and transfers
– Decide what type of contributions will be permitted, including Roth contributions
– Decide if the plan will allow employees to take a loan or hardship distribution
– Ensure contributions are remitted to approved providers in a timely manner
– For ERISA plans, comply with DOL Plan and Participant-Level Fee Disclosure Regulations
• If the employer doesn’t operate the plan in accordance with IRS and ERISA guidelines,
it can have a severe adverse impact on plan participants and the tax-deferred status
of the plan
For use only by former MPCG Advisors who have transitioned to Mass Mutual 27
403(b) Plans – Key Provision: Written Plan
Employers can either
develop a single written
plan document; or compile
a series of documents that
together constitute the
written plan
The IRS has released
model plan language
for public school 403(b)
plans. MetLife also offers
a specimen plan document
If required to maintain
a written plan, the written
plan must satisfy the
403(b) requirements in
form and operation
• Eligibility
• Applicable limitations
• Approved providers under the plan
Written plan must contain all material terms and conditions including:
Information sharing agreements are needed to maintain the 403(b) status of contracts
and accounts that receive exchanges after 9/24/07 if the contract or account is not
already part of the employer’s plan
• Time and form of distributions
• Assignment of compliance and administrative
responsibility (Third party administrator
(TPA), if applicable)
For use only by former MPCG Advisors who have transitioned to Mass Mutual 28
Regulatory Review
For Use With Plan Sponsor Only — Not For Distribution. For Informational Use Only.
“MetLife” as used throughout this presentation refers to Metropolitan Life Insurance Company (MLIC) and its affiliated companies.
“MetLife Resources” refers specifically to the business unit, which is a division of MLIC.
Any discussion of taxes is for general informational purposes only and does not purport to be complete or cover every situation. MetLife, its agents and representatives may not
give customers legal, tax or accounting advice and this document should not be construed as such. Customers should confer with their qualified legal, tax and accounting
advisors as appropriate.
IRS 403(b) Pre-Approved Plan Document Program
What is it?The IRS has established for the first time, a pre-approved 403(b) Plan Document Program (Program)
similar to the pre-approved plan document program available for 401(a) and 401(k) plans.
What purpose does it serve?The Program is designed to lower the cost and ease administration of 403(b) plans by providing an employer
with assurance its written plan document complies with applicable tax code requirements.
Are there additional benefits?
The IRS has provided remedial amendment relief. By adopting a pre-approved plan by March 31, 2020,
an employer with an existing written 403(b) plan document may be eligible to have reliance on the plan
document’s pre-approved status back to January 1, 2010 or, if later, the effective date of the employer’s plan.
What steps did MetLife take?MetLife submitted an application to the IRS for approval of its 403(b) plan and received IRS
approval in May 2017.
What will MetLife make
available to plan sponsors?
The MetLife pre-approved plan document is available to MLR 403(b) clients (subject to plan provisions)
regardless of whether they currently use the MetLife specimen 403(b) plan document.
What impact does this have
on MetLife’s existing 403(b)
specimen document?
Our expectation is that clients will use this opportunity to restate onto the pre-approved document to be able
to rely on the IRS opinion letter and to take advantage of the remedial amendment relief.
For use only by former MPCG Advisors who have transitioned to Mass Mutual 29
403(b) Plans – Key Provision: Universal Availability & Effective Opportunity Requirement
Note that ERISA provisions may contain more stringent rules
• Significant IRS audit focus
• “Everyone or no one” Rule – If the Plan is offered to one employee, it must be
offered to all employees
• 1,000 hour rule – Employees working less than 1000 hours in the prior year may
be excluded; Employer will need to keep records of actual hours
• Subject to certain transitional rules, collectively-bargained groups may no longer
be excluded from eligibility to participate
• Effective opportunity requirement:
– Employees must be notified at least once per year of the availability to make salary reduction
contributions; Plan must keep records of notifications for audit purposes
– Opportunity at least once per plan year to start or change deferrals
– Anti-conditioning requirement: A plan can’t make participation conditional on another benefit
or employer program
For use only by former MPCG Advisors who have transitioned to Mass Mutual 30
403(b) Regulations Knowledge Check –Question 1 of 2
True or False:
Regarding 403(b) plan regulations, an employer
may choose to allow employees to make non-deductible
Roth contributions
True
False
For use only by former MPCG Advisors who have transitioned to Mass Mutual 31
403(b) Regulations Knowledge Check –Answer
True or False:
Regarding 403(b) plan regulations, an employer
may choose to allow employees to make non-deductible
Roth contributions
True
False
For use only by former MPCG Advisors who have transitioned to Mass Mutual 32
403(b) Regulations Knowledge Check –Question 2 of 2
Select the best answer.
In addition to the required 403(b) plan document,
the employer has the option of including which of the
following provisions?
Loans and hardships
Exchanges and rollovers
Automatic enrollment
All of these
For use only by former MPCG Advisors who have transitioned to Mass Mutual 33
403(b) Regulations Knowledge Check –Answer
Select the best answer.
In addition to the required 403(b) plan document,
the employer has the option of including which of the
following provisions?
Loans and hardships
Exchanges and rollovers
Automatic enrollment
All of these
For use only by former MPCG Advisors who have transitioned to Mass Mutual 34
457(b) Plans
A 457(b) Plan is an eligible non-qualified, tax deferred compensation
plan under section 457(b) of the Internal Revenue Code and a retirement
savings plan available to state and local government employers and certain
tax exempt non-government 501(c) employers that are not churches
Contributions are
pre-tax with no
Federal income tax
paid until distribution,
however state income
tax may apply.
Earnings grow tax
deferred until
distribution
Not generally
subject to ERISA
(non-government
457(b) plans are
subject to certain
parts of ERISA)
Although 457(b)
plans may allow
Roth Contributions,
MetLife and
Brighthouse Financial
do not provide this
feature for certain
products
For use only by former MPCG Advisors who have transitioned to Mass Mutual 35
457(b) – Plan Ownership
The trustee or custodian
holds a governmental plan’s
annuity contract, or custodial
accounts for the exclusive
benefit of plan participants and
their beneficiaries.
Assets maintained by a
non-governmental tax exempt
employer remain the property of
the employer. Non-governmental
plans may have a rabbi trust but
are not required to.
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• Withdrawals from the plan are generally limited to a triggering event
such as attaining age 70½, separation from service or for
unforeseeable hardship withdrawals
• Emergency withdrawals are subject to more stringent
requirements than hardship distributions from 403(b) or 401(k) plans;
Unlike 403(b) or 401(k) plans, emergency withdrawals from a
457(b) plan do not allow for the purchase of principal residence
or college tuition expenses
• Taxable distributions are subject to ordinary income taxation,
although there is no 10% penalty for withdrawals before age 59½*
457(b) – Withdrawals/Distributions
*Unless attributable to rollovers from a plan subject to the 10% tax penalty.
Before taking withdrawals/distributions, participant should
consult with tax and legal advisers
For use only by former MPCG Advisors who have transitioned to Mass Mutual 37
• Governmental employers must allow eligible rollover distributions to
IRAs, 401(a), 403(a), 403(b), and other governmental 457(b) plans
• If a plan accepts rollovers/transfers from a non 457(b) plan, it must
provide for separate accounting since distribution before the participant
reaches the age of 59½ may be subject to a 10% distribution penalty
• A governmental 457(b) plan may make direct transfers into a defined
benefit governmental plan to allow for the purchase of permissive service
credit, subject to certain restrictions
• An “eligible retired public safety officer”, subject to certain restrictions,
may exclude up to $3,000 per year from taxable gross income for amounts
that are transferred directly from a governmental 457(b) plan to the
provider of accident, health or long term care insurance for the payment
of premiums that provide coverage for the retiree, spouse and dependents
457(b) – Rollover or Direct Transfers
For use only by former MPCG Advisors who have transitioned to Mass Mutual 38
457(b) Plans – Governmental Catch-up Deferrals
• A governmental 457(b) plan may allow age 50 catch-ups of an additional
$6,500 in 2020
• The plan may allow a special “last 3-year catch-up,” which allows you to
defer in the three years before you reach the plan’s normal retirement
age:
- twice the annual 457(b) limit (in 2020, $19,500 x 2 = $39,000), or
- the annual 457(b) limit, plus amounts allowed in prior years that
you didn’t contribute.
If a governmental 457(b) allows both the age 50 catch-up & the 3-year
catch-up, you can use the one that allows a larger deferral, not both.
For use only by former MPCG Advisors who have transitioned to Mass Mutual 39
• Non-governmental 457(b) plans must be “top hat” plans
maintained primarily for a group of management or highly
compensated employees
• MetLife generally places the burden on employers
to determine if a plan qualifies as a “top hat” plan, as there
is no authority that establishes when a plan is too large to be
deemed a “top hat” plan
• To establish itself as a “top hat” plan, an employer must file
a one-time statement with the U.S. Department of Labor within
120 days of establishment
457(b) – Non-Governmental Plan Participation
For use only by former MPCG Advisors who have transitioned to Mass Mutual 40
457(b) – Non-Governmental Plan Funding
• Plan assets are not held in trust for employers, but remain the
property of the employer
• Assets cannot be set aside for the exclusive benefits of participants
A non-governmental 457(b) plan must be unfunded in order to avoid taxation of amounts credited under the plan
• A rabbi trust creates security for employees because the assets
within the trust are typically outside the control of the employers
and are irrevocable
• The trust is funded, but the trust assets remain available to creditors
Employee deferrals in non-governmental plans are frequently placed in “rabbi trusts”
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457(b) – Loans
Loans in 457(b) plans
of non-governmental
tax exempt employers
are not permitted
Although 457(b)
governmental plans allow
for loans, MetLife does
not provide administrative
services for this feature
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Differences between 457(b) plans of Governmental and Non-Governmental Employers
Governmental EmployerNon-Governmental Employer /
Tax-Exempt Employer
Funding Status of Plan Assets must be held in a 457(g) trust custodial account
or annuity contract for exclusive benefit of participant
and beneficiaries
Plan must be unfunded. All amounts must remain the
property of the employer until made available to
participants or beneficiaries. Rabbi trust may be used to
protect from employers refusal to pay deferred
compensation obligation
ERISA Title 1 Reporting and
Disclosure Requirements
N/A N/A if one time statement filed with DOL within 120 days
of plan establishment
Participant Eligibility Determined by employer. May be discriminatory Determined by employer; must be limited to select group
of management or highly compensated employees
Participant Investment Direction Yes, plan permitting Yes, plan permitting investment instruction
by participants
Catch-up Contributions for
Participants 50 and older
Permitted after contribution limit is exceeded; not permitted
in three years prior to reaching normal retirement age if
catch-up provision is used
Not permitted
Incoming rollovers and transfers Plan may agree to accept pre-tax rollovers from other
qualified plans such as 401(a), 403(b),
IRAs if separate accounting is provided
Plan may agree to accept from other non-governmental
plans, subject to IRS 457(b) regulations
Benefits Protected from Employer
Bankruptcy
Yes No
Benefits Protected from Participant
Bankruptcy (IRS claims excluded)
Maybe under state spendthrift trust laws or applicable
state statutes
Maybe, through state law exemption
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Differences between 457(b) plans of Governmental and Non-Governmental Employers
Governmental EmployerNon-Governmental Employer /
Tax-Exempt Employer
Loans May be permitted (MetLife does not provide) Not permitted
Federal Income Tax withholding
and reporting of distributions
10% of taxable amount withheld not eligible for rollover to a
qualified plan unless participant opts out of withholding or
increases withholding percentage
20% of eligible rollover distributions not rolled over to
another qualified plan
Tax Reporting done on IRS Form 1099
Distributions considered wages under 3401(a) subject to
income tax withholding. Tax reporting on IRS Form W-2.
10% of taxable amount of distribution withheld to
beneficiaries unless non-annuitized distribution, otherwise
wage withholding rates apply, unless beneficiary opts out
of withholding or increases withholding percentage.
Tax Reporting on IRS Form 1099
State Income Tax Withholding and
Reporting of Distributions
If Federal income tax withheld, some states
require withholding
Distributions to participants withheld using published
state supplemental wage withholding or graduated wage
withholding tables
If Federal income tax withheld, some states require
withholding
Outgoing rollovers and Transfers May be permitted to governmental Defined Benefit plans to
purchase service credit. Plan must permit eligible rollover
distributions to IRAs or other retirement plans.
May be permitted to other 457(b) plans, subject to IRS
457(b) requirements
IRS Premature Distribution Penalty
prior to Age 59½
N/A to distributions to regular 457(b) contributions.
May apply to taxable portion of distributions rolled into plan
from other qualified plans such as 401(a), 403(b), IRAs
N/A
Designated Roth Accounts Yes (MetLife does not provide) No
For use only by former MPCG Advisors who have transitioned to Mass Mutual 44
457(b) Knowledge Check – Question 1 of 3
Select the best answer.
Generally, in a governmental 457(b) plan, distributions
are allowed for all the following reasons except:
Severance of employment
Unforeseeable emergency as defined by the IRS
Retirement
Age 59 ½
For use only by former MPCG Advisors who have transitioned to Mass Mutual 45
457(b) Knowledge Check – Answer
Select the best answer.
Generally, in a governmental 457(b) plan, distributions
are allowed for all the following reasons except:
Severance of employment
Unforeseeable emergency as defined by the IRS
Retirement
Age 59 ½
For use only by former MPCG Advisors who have transitioned to Mass Mutual 46
457(b) Knowledge Check – Question 2 of 3
Select the best answer.
What are distributions from 457(b) plans taxed as?
Ordinary Income
Capital gains if participant was in the plan
for over a year
Contributions are tax-free, but earnings are
taxable as ordinary income
Tax-free if used for retirement
For use only by former MPCG Advisors who have transitioned to Mass Mutual 47
457(b) Knowledge Check – Answer
Select the best answer.
What are distributions from 457(b) plans taxed as?
Ordinary Income
Capital gains if participant was in the plan
for over a year
Contributions are tax-free, but earnings are
taxable as ordinary income
Tax-free if used for retirement
For use only by former MPCG Advisors who have transitioned to Mass Mutual 48
457(b) Knowledge Check – Question 3 of 3
True or False:
Loans can be taken against both 457(b) Governmental
and 457(b) Non-Governmental plans
True
False
For use only by former MPCG Advisors who have transitioned to Mass Mutual 49
457(b) Knowledge Check – Answer
True or False:
Loans can be taken against both 457(b) Governmental
and 457(b) Non-Governmental plans
True
False
For use only by former MPCG Advisors who have transitioned to Mass Mutual 50
401(a) Money Purchase and 401(k) Plans
• Retirement plan savings account primarily used by
government employers, that enables an employer to offer
employees an additional incentive program
• For a 401(a) plan, the sponsoring employer determines
contribution amounts, whether dollar-based or percentage-
based, eligibility and vesting schedules; Contributions are
allowed by the employee, employer or both
• Funds are withdrawn from a 401(a) plan through lump-sum
payment, rollovers to another qualified plan, or through
an annuity
• 401(k) plans offered by a non-governmental employer
may permit participant elective contributions on a Roth,
pre-tax or post-tax basis
For use only by former MPCG Advisors who have transitioned to Mass Mutual 51
401(a) Knowledge Check – Question 1 of 1
Select the best answer.
Who determines the amount of money that may be
contributed, vesting schedules and eligibility
requirements for a 401(a) plan?
Both employer and employee
Employer
Employee
For use only by former MPCG Advisors who have transitioned to Mass Mutual 52
401(a) Knowledge Check – Answer
Select the best answer.
Who determines the amount of money that may be
contributed, vesting schedules and eligibility
requirements for a 401(a) plan?
Both employer and employee
Employer
Employee
For use only by former MPCG Advisors who have transitioned to Mass Mutual 53
403(a) Plans
A 403(a) is a retirement annuity plan; It is a deferred compensation
plan that is established by an employer (commonly government
organizations) to provide benefits to participating employees
• Plan generally works in a similar manner to a non-governmental qualified
retirement plan except that the 403(a) plan does not have a trust or trustee.
Rather, plan assets are held under annuity contracts.
• Qualified plan funding only through annuities
• Funded solely by employer contributions
• Recommend that employer have independent investment advice
• May be eligible for a rollover if employee leaves the firm, depending on how the
403(a) annuity was created; Most individual retirement annuities and profit-sharing
plans may be rolled into a self-directed IRA post-employment (Employees should
consult with annuity administrator regarding pension plan qualifications for rolling
these type of annuity funds after employment has ended)
For use only by former MPCG Advisors who have transitioned to Mass Mutual 54
403(a) Knowledge Check – Question 1 of 1
Mutual Funds
Annuities
Through a trust
Mutual Funds and Annuities
Select the best answer.
How is a 403(a) funded?
For use only by former MPCG Advisors who have transitioned to Mass Mutual 55
403(a) Knowledge Check – Answer
Select the best answer.
How is a 403(a) funded?
Mutual Funds
Annuities
Through a trust
Mutual Funds and Annuities
For use only by former MPCG Advisors who have transitioned to Mass Mutual 56
State Specific Retirement Plans – ORP & PERA
• Another form of a defined contribution retirement plan which may be offered by a state to
public employees of colleges, universities, K-12 schools, and local government agencies
and public entities
• Generally offered as an alternative to participation in the traditional defined benefit plan
Not offered in all states. States that currently offer ORPs include Florida, Massachusetts, New Jersey,
New York, South Carolina, Texas
Optional Retirement Program (ORP)
• A form of defined benefit pension plan which may be offered by a state to public employees of
colleges, universities, K-12 schools, and local government agencies and public entities
• Generally offered as an alternative to participation in Social Security
Not offered in all states. States that currently offer PERAs include Colorado, Minnesota, New Mexico.
Public Employees Retirement Association (PERA) Defined Benefit Plan
For use only by former MPCG Advisors who have transitioned to Mass Mutual 57
Maximum Allowable Contributions (MAC) Calculation
• 401(k) and 403(b) plans defer taxes on income by allowing elective
before-tax contributions
• Roth after-tax elective contributions are also permitted and when
eventually distributed with earnings will be distributed tax-free subject
to certain restrictions
• Before-tax and Roth elective contributions are aggregated for
MAC purposes
• Two separate Internal Revenue Codes apply to contribution limits
for the individual employee:
– Limit I. Section 415(c) General Limit: applies to both employer and
employee contributions
– Limit II. Section 402(g) Elective Deferral Limit: applies to only the employee’s
voluntary salary reduction contributions (elective deferrals)
• A special increased elective deferral cap for certain employees is also
permitted, and contains specific rules regarding aggregating 403(b)
contributions and accrued benefits with those of other plans
For use only by former MPCG Advisors who have transitioned to Mass Mutual 58
Maximum Allowable Contributions (MAC) – Limits
*Refer to www.IRS.gov for more details on current limits
• Annual additions to a defined contribution plan on behalf of a participant (employer and employee
contributions) cannot exceed the lesser of 100% of the participant’s compensation or $57,000
(for 2020)
Limit I. Section 415 (c) General Limit
• Limit applies equally to all salary reduction contributions (elective deferrals) whether made by an
individual to a 403(b), 401(k), SEP or SIMPLE IRA
• All elective deferrals made by employee to other plans must be aggregated with the 403(b) contribution
to determine if limit has been exceeded. (Contributions to 457(b) plans are not aggregated into the
402(g) limit for the above plans).
• The 2020 annual limit is the lesser of 100% of compensation or $19,500
– Employees over age 50 are eligible to use a catch-up contribution of $6,500 (Govt. plans only –
Not available for 457(b) tax-exempt)
– Eligible employees can contribute $19,500 and a catch-up of $6,500 to both a 403(b) and a 457(b)
Limit II. Section 402(g) Elective Deferral Limit
For use only by former MPCG Advisors who have transitioned to Mass Mutual 59
Alternative to 402(g) Limit
Catch-Up Contributions
Salary Reduction Agreements
Final Pay Plan
Excess Deferrals and Contributions
Contributions to 457(b) Plans
Special Catch-Up Contributions
to 457(b) Plans
Click here to learn
about the following
topics related to MAC
Calculations:
Maximum Allowable Contributions (MAC) – Self-Study
For use only by former MPCG Advisors who have transitioned to Mass Mutual 60
MAC Knowledge Check – Question 1 of 2
Select the best answer.
In a 403(b) plan, what is the maximum additional annual
deferral amount an individual can contribute if she has
15 years of service with her employer?
$1,000
$3,000
$6,500
$5,000
For use only by former MPCG Advisors who have transitioned to Mass Mutual 61
MAC Knowledge Check – Answer
Select the best answer.
In a 403(b) plan, what is the maximum additional annual
deferral amount an individual can contribute if she has
15 years of service with her employer?
$1,000
$3,000
$6,500
$5,000
For use only by former MPCG Advisors who have transitioned to Mass Mutual 62
MAC Knowledge Check – Question 2 of 2
Select the best answer.
Which of the following employer groups is not eligible to
provide the special increase in deferral limits for employees
with 15 or more years of service?
Churches
Hospitals
Educational Institutions
Charitable Organizations
For use only by former MPCG Advisors who have transitioned to Mass Mutual 63
MAC Knowledge Check – Answer
Select the best answer.
Which of the following employer groups is not eligible to
provide the special increase in deferral limits for employees
with 15 or more years of service?
Churches
Hospitals
Educational Institutions
Charitable Organizations
For use only by former MPCG Advisors who have transitioned to Mass Mutual 64
Thank You & Next Steps
Thank you for completing the
MetLife Resources Certification Training!
• You must receive approval from your Manager and acknowledgement from the MetLife
Resources Workplace Sales Director (WSD) to market to and/or service participants in an
MLR employer group. Contact your Manager or MLR Sales Support for next steps
• Contact MLR Sales Support for help with your questions about the not-for-profit marketplace
– 888-377-8999 or [email protected]
• Please note, if you have not already completed the MetLife/Brighthouse Annuity product-specific
training, visit https://naic.pinpointglobal.com/BrighthouseFinancial/apps/default.aspx
Please email a print screen shot of this page to MLR Sales Support
at [email protected] and cc your Manager
so that completion of this training can be tracked.
For use only by former MPCG Advisors who have transitioned to Mass Mutual 65
Disclosure
Any discussion of taxes is for general informational purposes only, does not purport to be complete or cover every
situation, and should not be construed as legal, tax or accounting advice. Clients should confer with their qualified legal,
tax and accounting advisors as appropriate.
MetLife Resources is a division of Metropolitan Life Insurance Company (MLIC), New York, NY 10166. Annuities are
issued by Brighthouse Life Insurance Company, Charlotte, NC 28277 and in New York only by Brighthouse Life Insurance
Company of NY, New York, NY 10017. Variable annuity products are distributed through Brighthouse Securities, LLC
(member FINRA). Product guarantees are solely the responsibility of Brighthouse Life Insurance Company or in New York
only Brighthouse Life Insurance Company and not MetLife. MetLife, a registered service mark of Metropolitan Life
Insurance Company, is used under license to Brighthouse Services, LLC and its affiliates. Brighthouse Financial is a
service mark of Brighthouse Financial, Inc. or its affiliates. Securities, including Metropolitan Life Insurance Company
variable products, are distributed by MetLife Investors Distribution Company (MLIDC)(member FINRA).
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