Employer Information

It is generally the executive director, bookkeeper, accountant, or finance director who will be responsible for submitting the retirement plan contributions. It should be the person who handles payroll.

The primary responsibilities are to assist in enrolling new hires, determine the correct amount to contribute - both employer and elective salary deferral contributions, ensure the IRS Annual Limits are not exceeded (see limits below), and contribute within the legal timeframe - the fiscal year for employer contributions and by the 15th of the month following withholding from a paycheck for salary deferrals. 

It is important for the employer to return copies of the Retirement Plan Contribution Calculation form and the Workplace Savings Plan Contribution form to the ACC, on behalf of the cantor, every year.  

Refer to the plan documents and summary plan descriptions for all employer responsibilities. 

1. Is your new cantor/soloist a member of the ACC or GTM and eligible for the retirement plan?
   1. Eligibility: ACC and GTM members in good standing are eligible to enroll in the ACC Retirement Plan. 
   2. Rabbis ordained from HUC-JIR may be eligible through the CCAR (via the GTM) only if they no longer meet RPB's eligibility requirements.
2. Does your cantor/soloist have an existing ACC Retirement account? 
   1. If they need to create an account, see the ACC/GTM Member Enrollment Instructions. 
   2. If they have an existing account, email the ACC Retirement Administrator the name of your new hire and the employer's full name. 
3. Work with your cantor/soloist to complete the Contribution Calculation Form and the ACC Elective Deferral Form. Return both to the ACC Office.

If your congregation is not on the Simplified Contribution Platform (SCP) please see the following directions: 

Fidelity's Simplified Contribution Platform (SCP) makes contributing easy. 

1. If you're congregation in not already set up to make contributions on behalf of your cantor/soloist, complete an ACC Participating Employer Adoption Agreement and return it to the Retirement and Group Benefits Administrator. 
2. The Retirement Administrator will have the division code and division name created. 
3. When you receive instructions from the administrator, sign up for Fidelity's Simplified Contribution Platform (SCP - pronounced skip). This will be the person who handles the payroll for your congregation.
4. Once approved, add a funding source (a bank account) so contributions can be completed. The Fidelity system will take up to 10 business days to verify your bank account, so it is important to complete the process as soon as possible. Additionally, if you are changing a bank account, keep in mind that the same 10-day confirmation period applies. 
5. For questions regarding log in to the SCP system contact Fidelity SCP Customer Service at (800) 917-4369.

You can request to be a SCP user by clicking on this link. Fidelity Investments Simplified Contribution Platform (appiancloud.com) 

1. Click 'I Agree.'
2. Select 'New User' below the login fields.
3. Complete and submit the form - The plan number is 71280. Include the division code and the division name. If your congregation does not have the division code and division name yet, contact the Retirement Plan Administrator.
4. A request for access, will be sent to the ACC office. Once approved you will receive an email from the Retirement and Groups Benefits Administrator with further instructions.
5. Once you have successfully logged in to SCP and updated your password, add a funding method right away as it takes Fidelity 10 business days to verify each new bank account added before it is available for use. The funding method will be available on the 11th day. 
6. After the bank account is verified, enjoy the simple contribution process!

Fidelity Investments' SCP Help Desk is eager to assist you in the use of the Fidelity SCP system, every step of the way. Once your login has been established by following the above instructions, please contact Fidelity with any training, support, or technical issues. Unlimited training and support is available to employers at no charge; Fidelity's exceptional services are included as a benefit of our Plan.

Fidelity Simplified Contribution Platform (SCP) Contact Information

All contributions are made electronically through the Simplified Contribution Platform (SCP). Once you have a SCP account, have added a funding method and it has verified, you can make a contribution. There is a SCP user manual located on the landing page of the website at the top right under 'Resources'. 

SCP is the required method for making all contributions to the ACC Retirement Plan. Here are some tips and best practices:

• Be sure to double check your funding source once a year. Remember, if you add a source (bank account), the Fidelity system takes up to 10 business days to confirm the accuracy to make the account available. 
• While SCP has a "repeat contribution" function, it is highly recommended that whoever is entering contributions, use the current payroll report to confirm any additions or changes to staff salary deferrals. The ACC plan allows deferrals to begin or change at any payroll interval and it is the responsibility of the employer to ensure the contributions--particularly salary deferrals--are correct. 
• Salary deferrals should be contributed to a participant's retirement plan within three days of each payroll. They can't be pre-paid and should not be held longer than necessary to facilitate contributions being made. 
• If you notice a mistake, please contact the ACC office immediately. 

Employer Contributions: 02- Temple Contributions

1. Employer contributions are the contributions the temple makes as a benefit to the cantors.
   1. They are calculated and paid throughout a fiscal year period. 
   2. Can be any percentage of the cantor’s full compensation as determined in the contract or can be a set rate regardless of salary. 
   3. This amount can be changed at any time. The ACC recommends the employer contributions be 15% of the cantor’s salary.
   4. The employer contribution can be paid as one lump sum payment or stretched out monthly, however, all employer contributions must be deposited by the end of the fiscal year. 
2. Calculate employer contributions by using the Annual Calculation Contribution Form.
   1. Start with the Full compensation. 
   2. Determine the percentage of full compensation that the employer’s contribution will be calculated from. 
   3. Are you contributing quarterly, monthly, a single contribution or by paycheck? That would determine your contribution per period. 
3. Employer contributions can be prepaid, and you can preschedule this payment ahead of time with Fidelity. 
4. When coding for temple contributions in the SCP system, use 02-Temple Contributions.

Salary Deferrals: 01 Salary Deferrals 

1. A salary deferral is the amount of salary that a cantor requests to be withdrawn from their paycheck each pay period. See IRS Elective Deferral Rules.
2. Salary Deferrals are calculated in the calendar year, not fiscal year.
   1. There are IRS limits that must not be exceeded in the calendar year.
   2. Salary deferrals can’t be prepaid. They can only be taken after the salary is earned.
   3. Salary deferrals must be deposited into Fidelity within three days of payroll.
   4. Preschedule salary deferrals through Fidelity’s Simplified Contribution Platform or SCP. 
      1. The ACC recommends you preschedule six months’ worth of deferrals at a time, once in the beginning of the year and once in the middle of the year when a salary changes with the new fiscal year.
      2. When coding a salary deferral in the SCP system, use 01-Salary Deferral.
3. To calculate Salary Deferrals, complete the Workplace Savings Plan Contribution Form 403(b) and return to the ACC office. 

Section 415 of the Internal Revenue Code provides for dollar limitations on benefits and contributions under qualified retirement plans. Section 415(d) requires that the Secretary of the Treasury annually adjust these limits for cost‑of‑living increases. Other limitations applicable to deferred compensation plans are also affected by these adjustments under Section 415. Under Section 415(d), the adjustments are to be made pursuant to adjustment procedures which are similar to those used to adjust benefit amounts under Section 215(i)(2)(A) of the Social Security Act.

Should the participant choose to exceed the limits, the excess should be deposited into the participant's non-qualified Supplemental Plan account. 

• Employer Adoption Agreement - New Employer? Fill out the Employer Adoption Agreement to be a participating employer in the ACC Retirement Plan. Completing and returning this form is commits you to abiding by the ACC Plan documents and IRS regulations.
• Procedures for Temple Staff - Download a copy for use in the Temple office. It consists of helpful information to ensure retirement contributions run smoothly. 
• SCP User Manual - Instructions on how to use the Simplified Contribution Platform.
• Contribution Tracking Worksheet - Use the attached form to track your calendar year and fiscal year contributions. Spreadsheet can be adjusted to account for your congregation's number of payroll periods.
• IRS Elective Deferral Rules

Proper handling of participant deferrals is arguably one of the most important duties of a plan sponsor and requirement of an employer.

While it's easy to understand the need to treat plan assets with the deference required by the Employee Retirement Income Security Act of 1974 ("ERISA"), what may not always be so clear is exactly when amounts deferred by employees through payroll become "plan assets." Since it is so important that participant deferrals and loan payments be made promptly, we thought even though the ACC Retirement Plan is not subject to ERISA, we do follow the recommended guidelines from the DOL so it would be helpful to highlight the requirements.

The Department of Labor ("DOL") has written strict guidelines on how long an employer can hold elective deferrals before depositing them into the plan. The general rule requires that contributions and loan repayments be deposited into the plan as soon as it is reasonably possible to segregate them from the company's assets, but no later than the 15th business day of the month following the month amounts are withheld from pay. The 15th business day rule is not a safe harbor. The DOL emphasizes that the "real" deadline is the earliest date on which contributions can be segregated, and they may look to prior payrolls to determine what is possible.

Example

An employer has a biweekly payroll and historically has reconciled and forwarded contributions by the 5th business day after payroll. For the current payroll period, it takes the employer 10 days to deposit amounts withheld into the plan. The DOL will likely consider the 10-day period as unreasonable, even though the contribution was made prior to the 15th business day of the next month.

Small Plan Safe Harbor

For plans with fewer than 100 participants on the first day of the plan year, the DOL created a safe harbor standard that states any deposits made within seven business days of a pay date are considered timely. This safe harbor is optional—small plans may use the seven-business-day safe harbor period or the general deadline.

Mistakes May Occur

If it's discovered that certain salary deferral or loan payment deposits have been "late," prompt action will help to minimize the financial impact and exposure to the plan.