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WHAT WE CAN DO FOR YOU

Pollard & Associates is an independent third-party administrator of tax qualified retirement plans. Because we're independent, we do not manage assets or collect commissions; we provide objective consultation and services. We work collaboratively with advisors (financial advisors, RIAs) chosen by the employer (plan sponsor), to help design and implement plans that best serve the client’s goals. Our service model consists of a team comprised of a senior administrator and an assistant administrator assigned to each client.  We fully disclose our fees and offer tiered pricing based on number of eligible participants.

Additional detail on what we can do for you can be found by clicking on the links below.

Plan Design

Plan Documents
Plan Implementation
Defined Contribution Administration
Compliance Testing
Government Reporting
Special Administrative Services
Defined Benefit Administration
Trustee / Fiduciary Consulting
Plan Expense Analyses
Consulting for Plans with Bundled Providers
Correcting Plan Errors
Participant Notice Distribution


Plan Design

Plan Design services include meeting with the plan sponsor to identify:

  • Business objectives
  • Most suitable plan types(s)
  • Effective plan features
  • Optimal investment platform

Pollard will provide illustrations of plan feasibility, costs and designs (e.g., 401(k), 401(k) Safe Harbor, Profit Sharing, New Comparability or Cross-Tested, Cash Balance, Defined Benefit, etc.) and will discuss effective plan features (e.g., eligibility and vesting provisions, employer contribution types, Roth deferrals, loan availability, etc.).

Effective plan design can:

  • Maximize tax deductions for the employer
  • Maximize tax deferred savings opportunities for the employer and employees
  • Minimize costs for establishing and maintaining the plan
  • Provide for attraction and retention of valuable employees

Plan Documents

A plan document is an essential component of establishing a qualified retirement plan, and serves as the foundation for the plan’s day-to-day operations. Pollard will prepare a new or restated plan and trust document for signature by the plan sponsor and trustee. Pollard Prototype and Volume Submitter Documents are pre-approved for clients by the IRS and are up-to-date with PPA and all regulatory requirements. Pollard can also provide individually designed plan documents that require more customization than a prototype can provide.

In addition to the plan document, Pollard will provide the following:

  • Corporate Resolution to adopt the plan
  • Summary Plan Description (SPD)
  • Plan Highlights
  • Loan Policy
  • Qualified Domestic Relations Order (QDRO) Policy

If your Plan is already established, Pollard will review your current document’s compliance with legislative and regulatory requirements, and will update or restate the document as required to incorporate changes to plan design or regulations.

Plan Implementation

After discussing your plan design and preparing or restating your plan document, Pollard will work with you and your advisors to establish the seamless implementation of your Plan, including:

  • Assistance with Plan set-up on new investment platform, including preparation of enrollment forms, beneficiary forms, and blackout notice for transfer of existing assets
  • Coordination of conversion with current plan providers, including preparation of conversion data files (existing plan only)
  • Obtain and review historical census files, prior year annual valuation report and non-discrimination testing results (existing plan only)  
  • Set-up employee data and plan specifications in Pollard’s recordkeeping system
  • Coordination with your advisors and in-house staff to establish streamlined administrative procedures
  • Assistance obtaining a Trust Identification number from the IRS (new plan only)
  • Assistance obtaining Fiduciary Bond coverage through your insurance agent, or a provider referred by Pollard
  • Reconciliation of existing participant balances (by contribution type) transferred to new investment platform (existing plan only)

Enrollment Meetings
If desired, Pollard will conduct enrollment/education meetings with your financial advisor to educate employees on plan benefits, the enrollment process, and how to access and manage their account.  Your financial advisor will educate employees on the investment options available under the plan.

Defined Contribution Administration

Consulting and administrative services are performed by Pollard in conjunction with participant-level recordkeeping completed by the Plan's investment provider. 
Annual administrative services include:

Plan Document Maintenance

  • Automatic provision of all required compliance Amendments to adopting clients of our Prototype and Volume Submitter Documents to ensure continued plan qualification based on changing legislative and/or regulatory requirements

Basic Consulting

  • Notification of legislative and regulatory changes which may have an impact on the Plan
  • Bi-monthly newsletter for plan sponsors providing information on a current topic of interest
  • Ongoing consultation on the operations of the Plan
  • Consultations on the continued appropriateness of Plan provisions in the context of the employer’s current business situation and/or changing objectives
  • Pre year-end testing and contribution projections for assistance with year-end tax planning (if requested)

Basic Annual Administration

  • Collection (via electronic medium), and maintenance of, employee census data
  • Determination of participant eligibility status
  • Computation of participant service and vesting credits
  • Calculation, allocation and reconciliation of employer contributions and forfeitures
  • Compliance testing
  • Government reporting
  • Processing employee enrollments, distributions, hardship withdrawals, and other in-service withdrawals in coordination with investment provider
  • Participant loan setup, including determination of available loan limit, preparation of promissory note and amortization schedule, and maintenance for the life of the loan
  • Age 70 ½ Required Minimum Distribution processing
  • 1099R tax reporting for participant distributions if not completed by investment provider
  • Trust accounting, including balance sheet and income statement preparation if not performed by investment provider
  • Coordination with accountant for plans subject to independent audit requirement (generally plans with >100 participants)

Annual Valuation Report

  • Preparation of annual valuation report to include: contribution summary, Plan highlights, employee census report, summary of participant accounts, testing results and corrections, bonding requirements and sufficiency, and reconciliation of trust assets
  • Annual meeting to present and discuss valuation report and perform a Trustee check

Compliance Testing

Each year, Pollard provides the compliance and non-discrimination tests required for qualified retirement plans to ensure that the plan is operated in accordance with IRS and Department of Labor rules and regulations. These tests help to verify that contributions are being allocated properly and in a timely and nondiscriminatory manner and that a cross section of employees is afforded the opportunity to participate in the plan.

Pollard’s compliance testing services include:

  • Determination of Highly Compensated Employees
  • Determination of Key Employees
  • Compliance testing as follows:
    • §410(b) testing for coverage and participation
    • §401(a) testing for non-discrimination
    • §401(k) and (m) testing (ADP/ACP) for salary deferrals and employer matching contributions
    • §404 testing for aggregate deduction limits
    • §415 testing for individual participant allocation limits (employee, employer, and forfeiture allocations)
    • §416 testing for Top Heavy status
  • Identification of alternatives and instructions for correction of compliance testing failures
  • Pre year-end testing for assistance with year-end tax planning, if requested

Government Reporting

Plan sponsors are required to file an annual report/return, known as the Form 5500, with the Department of Labor (DOL). The Form 5500 discloses information about the plan and its operations to the DOL, the plan’s participants, and the public.

Pollard’s Government Reporting services include:

  • Completion and filing of Form 5588 for filing extension (automatically extends Form 5500 deadline 2½ months to 9½ months after plan year end)
  • Preparation of "signature ready" Form 5500 and applicable attachments
  • Actuarial certification of Schedule SB for defined benefit plans
  • Preparation and filling of Form 8955-SSA
  • Preparation of Summary Annual Report (required to be distributed annually to all plan participants)

Electronic Filing
Beginning in January 2010 for the 2009 Form 5500, annual reports must be filed with the Department of Labor through an electronic filing system known as EFAST2. The EFAST2 system is a collaboration between multiple government agencies, including the DOL, IRS, and Pension Benefit Guarantee Corporation. Under this new system, plan sponsors must obtain e-filing credentials and follow specific EFAST2 filing procedures to properly file their Form 5500 and required attachments, unless the plan sponsor authorizes Pollard to file on their behalf.

Pollard is facilitating the EFAST2 filing process for clients by using the FT Williams Web Portal. 
The Web Portal program enables Pollard to work collaboratively with clients to efficiently:

  • Gather all required information
  • Obtain e-filing credentials from the DOL (signature IDs and PINs)
  • Electronically sign the Form 5500
  • Electronically file the Form 5500 and required attachments with the DOL

Special Administrative Services

Special administrative services are those that are non-recurring and not included as part of Pollard’s basic annual administration. These services are provided and charged for on a usage basis as required:

  • Review and approval of Qualified Domestic Relations Orders (QDROs) for payment to an alternate payee under marital divorce procedures
  • Preparation of voluntary plan amendments to incorporate plan design changes (compliance amendments are automatically provided)
  • Assistance with correction procedures for compliance related issues (e.g., late contribution deposits, missed deposits, etc.)
  • Preparation of Form 5330 for payment of penalty and excise taxes, as may be required for prohibited transactions, late contribution deposits, etc.
  • Assistance with IRS or DOL Audits by an on-staff Enrolled Retirement Plan Agent (ERPA) who can represent the Plan Sponsor before the IRS
  • Plan termination processing, including preparation of participant notices and IRS filings, and participant distribution processing

Defined Benefit Administration

Pollard provides traditional defined benefit plan and cash balance plan administration, including benefit calculations. Pollard’s defined benefit clients receive the same annual administrative services as defined contribution clients, plus the following:

  • Annual actuarial valuation
  • Actuarial certification of Form 5500 Schedule SB
  • Determination of minimum required and maximum deductible contributions
  • Annual benefit calculation statements
  • Calculation of participant benefits at termination of employment or retirement
  • Preparation of required Pension Benefit Guarantee Corporation forms and filings

Trustee / Fiduciary Consulting

Because we’re independent (not affiliated with any investment companies), Pollard is able to provide objective consulting services to plan sponsors and fiduciaries of qualified retirement plans. These services include:

Due Diligence Investment Provider Fee & Service Review
Following the initial selection of an investment provider, the fees and expenses charged by the provider to the plan, participants, and the plan sponsor, should be reviewed periodically to determine whether they continue to be reasonable in consideration of the services provided. Pollard will review your investment provider’s fees, (e.g., hard-dollar recordkeeping fees, investment fees, other asset-based fees, transaction-based fees, broker fees), revenue sharing credits, and plan sponsor and participant service levels as compared to those proposed by prospective service providers in the marketplace to assist fiduciaries in documenting their due diligence and monitoring of the plan’s investment provider. This analysis provides a basis for determining whether the plan will continue to use the current provider or will consider alternatives.

Fiduciary Support/Training

Plan fiduciaries ordinarily include the employer and its officers and directors (to the extent they exercise discretion or control over the administration of the plan), the plan’s trustee, investment advisers, and members of the plan’s retirement or investment committee.

Fiduciaries have important responsibilities and are subject to certain standards of conduct under federal law. Fiduciaries who don’t follow the basic standards of conduct may be held personally liable to restore any losses to the plan resulting from breach of fiduciary duty. Pollard can help fiduciaries understand and fulfill their duties by conducting fiduciary training for plan trustees and/or the plan’s retirement or investment committee. Training covers fiduciary responsibilities, potential liability, and ways to minimize risk.

404(c) & QDIA Compliance Checklists
Under Section 404(c) of ERISA, fiduciaries can limit their liability by allowing plan participants to control their own investment choices in the plan. In addition, by selecting a qualified default investment fund (QDIA) to be used in the absence of an affirmative election by plan participants, fiduciaries can limit their liability for any losses that result from the participant investing in the QDIA.

Each of these fiduciary protections requires compliance with certain conditions under ERISA Section 404(c). Pollard can help fiduciaries meet these conditions by completing checklist exercises to ensure that all requirements (e.g., notification requirements, disclosure requirements, investment structure requirements) are met.

Investment Policy Statement
Although an investment policy statement is not explicitly required by ERISA, the Department of Labor has indicated that the adoption and maintenance of an investment policy statement is “consistent with the fiduciary obligations set forth in ERISA.” Pollard can help fiduciaries construct an investment policy statement that reflects the goals of the plan, defines the roles of the parties involved in the management of plan assets, outlines the approach to selecting and monitoring investment options, and is consistent with the terms of the plan document. A well-constructed investment policy statement can serve as a roadmap for plan fiduciaries.

Review of Potential Prohibited Transactions
Certain transactions are prohibited under the law to prevent dealings with parties who may be in a position to exercise improper influence over the plan (e.g., business owners, plan fiduciaries). Prohibited transactions between the plan and these parties-in-interest include but are not limited to sales or exchanges, lending money or extending credit, and furnishing goods or services.

If you are concerned about the nature of a transaction that has occurred or that is under consideration, Pollard can help identify – with legal counsel if required – the potential prohibited nature of the transaction and any associated remedies. If a prohibited transaction has occurred, Pollard can help correct the transaction, identify any associated penalties, and complete the required government filings/reporting.

Plan Expense Analyses

Following the initial selection of an investment provider, the fees and expenses charged by the provider to the plan, participants, and the plan sponsor, should be reviewed periodically to determine whether they continue to be reasonable in consideration of the services provided. Pollard will review your investment provider’s fees, (e.g., hard-dollar recordkeeping fees, investment fees, other asset-based fees, transaction-based fees, broker fees), revenue sharing credits, and plan sponsor and participant service levels as compared to those proposed by prospective investment providers in the marketplace to assist fiduciaries in documenting their due diligence and monitoring of the plan’s investment provider. This analysis provides a basis for determining whether the plan will continue to use the current provider or will consider alternatives.

Consulting for Plans with Bundled Providers

If your Plan is serviced by a bundled provider (i.e., one organization provides plan administration, compliance, investment management, employee education, and participant recordkeeping services), you may require additional consulting services not “included” in the package by your bundled provider. As a fully independent third-party, Pollard can provide:

  • Assistance with more flexible/complex plan designs, including contribution calculations and §401(a) non-discrimination testing for New Comparability or Cross-Tested plans
  • Assistance with ongoing administrative and operational issues
  • Plan document maintenance
  • Independent, comprehensive fee and service review to help fiduciaries document their due diligence and monitoring of the plan’s bundled service provider

Correcting Plan Errors

The Department of Labor and the IRS have correction programs available to help plan sponsors and fiduciaries correct plan errors, protect participants, and maintain the plan’s tax-qualified benefits.

Pollard can help plan sponsors and fiduciaries correct plan errors via the appropriate program:

  • Self Correction Program (SCP) – Permits a plan sponsor to correct certain plan failures without contacting the IRS or paying a fee
  • Voluntary Correction Program (VCP) – Permits a plan sponsor to, any time before audit, pay a limited fee and receive IRS approval for correction of plan failures
  • Audit Closing Agreement Program (Audit CAP) – Permits a plan sponsor to pay a sanction to the IRS and correct a plan failure while the plan is under audit
  • Voluntary Fiduciary Correction Program (VFCP) – Outlines procedures for plan fiduciaries who may be liable for fiduciary violations under ERISA to correct violations and receive relief from certain penalties and enforcement actions

Participant Notice Distribution

Sponsors of all 401(k) plans are required to distribute basic plan Notices annually to plan participants.  Plans with special features, such as Safe Harbor, QDIA & Automatic Enrollment have additional notice requirements as well.   Pollard prepares all required plan Notices annually as part of our basic administrative fees and will forward to you with instructions for distributing prior to the due date.  We also provide an enhanced service level whereby we will directly distribute to participants both the basic Notices, as well as the special Notices applicable to their plan, including the 404a-5 Participant Fee Disclosure Notice, Summary Annual Report, Safe Harbor, QDIA, and Automatic Enrollment Notices (as applicable).