Retirement Plan FOCUS Bulletin - Second Quarter
Client servicing, social distancing
As a regional financial services institution, Fulton Bank is considered an essential business and has continued to remain open during the COVID-19 pandemic. However, that doesn’t mean that we haven’t adopted new practices designed to keep our team members and our clients safe.
Thanks to our technology and Fulton Bank’s Business Continuity Plan, the vast majority of our team is now working remotely from their homes. However, we do have a few team members coming in to the office to cover some functions that require an in-office presence. We are thrilled with the manner in which our team has handled this change and has continued to service our clients. At this time, the Fulton senior leadership team is developing plans to slowly reopen. It will be done in phases, with our financial centers being the first to reopen. Great care is being taken to provide a safe environment for clients and employees alike. As a result, the Retirement Services team will likely be maintaining our work-from-home practices for a few more months.
In order to help remain connected with our clients and participants, we have conducted a number of webinars for both participants and sponsors on a number of topics and we will continue to do so.
In terms of clients and participant meetings, we are currently minimizing our face-to-face client interaction and utilizing WebEx (an online meeting software) to conduct plan reviews and plan specific participant education. WebEx is a leading teleconferencing software that allows for sharing videos, reports and screens. Attending a WebEx meeting as a participant is fast and easy and can be done through a computer or mobile device. However, if your firm has a preferred online meeting tool, we are happy to utilize that tool on your behalf.
Providing participant email addresses (and text-enabled phone numbers)
There are many reasons why it is now more essential and beneficial than ever for Fulton to maintain participant email addresses and text-enabled cell phone numbers in our records. A few examples are:
- Many of our clients in today’s environment have sought to reduce face-to-face interaction and handling of paper. As a result, we continue to build processes to provide needed updates and documents directly to plan participants via email.
- The Department of Labor recently announced that they now support the delivery of disclosures via electronic delivery (please see our Industry & Legislative update in this newsletter for more information). This is a significant development that will allow us to greatly simplify the disclosure process for our clients that provide participant email addresses to us.
- Fulton’s ongoing implementation of additional online security tools to protect your plan participants.
- Improved automation of other essential participant communications.
As a result, we encourage all of our clients to provide Fulton with email addresses (and, eventually, text-enabled phone numbers) for all employees on a routine basis. The most efficient way of providing this information is to include these fields in the contribution file that you submit with each payroll. We will gladly work with you and your payroll provider to explore whether this is feasible. Although there will be initial upfront work involved in setting this up, we are confident that the increased communication, security and electronic delivery of disclosures will be more than worthwhile.
Please be assured, participant email addresses will not be used for the purposes of marketing or other sales-related functions, but purely for providing important updates, disclosures and education opportunities for your plan participants.
Electronic delivery of disclosures and notices
There is good news from the Department of Labor. They’ve just released a new set of relaxed rules concerning electronic delivery of disclosures and notices. These new rules bring the DOL rules closer to the IRS rules, which were always more lenient.
The new rules essentially say that any required document, statement, disclosure, or notice may be provided to “covered individuals” electronically, as the default method of delivery. A covered individual is any participant or employee who has provided an email address or telephone number for an internet-enabled mobile device. An employee who, as part of his or her job, is assigned a company email address may be treated as having provided an email address.
Not surprisingly, there are rules for email content and how long the information or materials must be available. And there’s a notice requirement. However, these notices may be combined with other notices or disclosures that are currently being provided annually.
At the time of preparing this newsletter, this was a fairly new development and we do expect additional guidance. We will certainly be sharing more information on this topic in the near future.
The CARES Act and retirement plans
Fulton acted quickly when the CARES Act was signed, and we found that the majority of our clients have already taken advantage of the benefits of the CARES Act. However, for anyone who would like to review the highlights of the CARES Act as they pertain to retirement plans, we feel that this article provided by Groom Law is an excellent overview.