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HomeMy WebLinkAbout20181824.tiffRESOLUTION RE: APPROVE PERA 415 REPLACEMENT BENEFIT ARRANGEMENT AND AUTHORIZE CHAIR TO SIGN WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the employees of the Department of Public Health and Environment are members of the Colorado Public Employees Retirement Association (PERA), and WHEREAS, the Internal Revenue Code (IRS) Code Section 415(b) imposes a dollar limit on the benefit amount a pension plan can pay a retiree, and WHEREAS, the Internal Revenue Code (IRS) Code Section 415(m) allows PERA to use a Replacement Benefit Arrangement (RBA) to provide relief for a member who exceeds the 415(b) limit, and WHEREAS, the Replacement Benefit Arrangement (RBA) will not have any financial impact on Weld County to accommodate a member who exceeds the 415(b) limit, and WHEREAS, the Director of Finance and Administration is recommending that Weld County approve the attached PERA Replacement Benefit Arrangement (RBA) and authorize the Chair to sign the RBA, and NOW, THEREFORE, BE IT RESOLVED by the Board of Weld County Commissioners that the attached PERA Replacement Benefit Arrangement (RBA) be, and hereby is, approved and the Chair is authorized to sign said RBA. The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 11th day of June, A.D., 2018. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: datifdA) ..eito;ok, Weld County Clerk to the Board unty Attorney Date of signature: 0? /A-/8 Steve Moreno, Chair EXCUSED Barbara Kirkmeyer, Pro -Tern Sean P. C•nway Mike Freeman Cc : F I (uw)) ACT (Esc), CACB8) v7-23 —l8 2018-1824 PE0032 NEFI RRANGEMENT INTRODUCTION Internal Revenue Code (I RC) Section 415(b) imposes a dollar limit on the benefit amount a pension plan can pay from tax -deferred trust funds Colorado PERA cannot pay a retiree any benefit amount that exceeds this federal tax limit Currently, this limit is set at $220,000 ($18,333 per month) for retirees who are age 62 or older This dollar amount is actuarially decreased for retirees younger than age 62 Any tax -paid contributions or tax -paid service credit purchases in a member's account will also affect these limits Since PERA members may retire as early as age 50 with a larger percentage of Highest Average Salary (HAS): a few highly paid members may exceed this limit For example, a PERA member who retires at age 50 is limited to an annual benefit of 599,839. A PERA member who retires at age 55 is limited to an annual benefit of $136,842. See the table on page 6, prepared by PERA's actuary, for the dollar limits at various ages This table is for those retiring in 2018, those retiring in later years may nave higher limits While 415(b) imposes a timit on a member's benefit, Section 415(m) allows PERA to use a replacement benefit arrangement (RBA) to provide relief for a member who exceeds the 415(b) limit PERA has adopted an RBA The governing document is contained in this booklet It may be amended from time to time to comply with future changes in the federal tax laws or their interpretations COLORADO PERkro PROCEDURES Prior to retirement, you may estimate whether your benefit may be affected by the 415(b) Limit as follows. 1 Request a retirement estimate from PERA Provide PERA with your best assumptions and estimates for your retirement date, salary until retirement, etc. 2 Compare the estimated Option 1 (PERA benefit structure) or Option A (Denver Public Schools IDPSI benefit structure) amount (single -life option) to the amount in the enclosed table for your anticipated age at retirement If you plan to select Option 2 or 3 (PERA benefit structure) or P2 or P3 (DPS benefit structure) (joint -life options) at retirement and name your spouse as your cobeneficiary, then compare the Option 2 or 3 or Option P2 or P3 amount to the enclosed table for your anticipated age at retirement 3 If your estimated benefit, using step 2 above, is less than the amount in the table, your benefit may not exceed the 415(b) limit and PERA will pay you the entire amount of your benefit directly 4 If your estimated benefit, using step 2 above, is more than the amount in the table, your benefit may exceed the 415(b) limit. Further analysis by PERA's actuary is required to determine if your actual benefit at retirement exceeds the 415(b) limit The actuary must determine the portion of your benefit resulting from tax -paid contributions and tax -paid purchases of service The tax -paid portion is added to the 415(b) Limit for your retirement age and the total becomes the new limit The 415(b) process considers cost -of -living increases to be made without jeopardizing your benefits. 2018-1824 December 2017 Colorado Public Employees Retirement Association 1301 Pennsylvania Street • Denver; Colorado 80203 • 1-800-759-PERA (7372) • www.copera org For federal tax purposes, PERA needs actual retirement information to analyze whether your benefit exceeds the 415(b) limit At retirement, PF RA will have its actuary perform this analysis with your exact benefit information If your benefit does not exceed this limit, PERA will pay you the entire amount of your benefit directly If PE RA's actuary determines that your benefit exceeds the 415(b) limit at retirement, PERA will pay you the maximum amount permitted by the tax limit. Also, PERA will work with your previous employer to establish an RBA with that employer After the previous employer agrees to participate in the RBA, PERA will pay your previous employer the difference between your PERA benefit amount (as determined under state law), without regard to the 415(b) tax limit and the 415(b) limit, your previous employer then will pay you this difference The RBA requires the cooperation of your employer who will need to sign PERA's Qualified Replacement Benefit Arrangement Adoption Agreement, which is included in this booklet Shortly before you decide to retire, make certain you have a current retirement estimate and also the most current information about the RBA You may direct your questions to a PERA Benefits Counselor at 1-800-759-7372 PERA also urges you to consult with your own tax professional who is familiar with your particular facts and circumstances, including any plans other than PERA-sponsored plans in which you may have participated PERKS QUALIFIED REPLACEMENT BENEFIT ARRANGEMENT The purpose of this Arrangement is to provide additional payments to the Benefit Recipients of PERA when the benefits paid under the Pension Plan are reduced due to the limitations imposed by Section 415 of the Internal Revenue Code of 1986. as amended. This Arrangement is intended to constitute a qualified governmental excess benefit arrangement as that term is defined in Code Section 415(m) 2 The Arrangement shalt be effective as of January 1, 1999, and shall apply to Members of PERA who retire with an effective date of retirement or who die on or after January 1, 1999 Article 1 —Definitions (Note. C. R. S refers to Colorado Revised Statutes ) 1.01 "Arrangement" means PE RA's Qualified Replacement Benefit Arrangement, as set forth herein and as amended or modified from time to time 1.02 "Association" or "PERA" means the Public Employees' Retirement Association, as established under the provisions of Article 51 of Title 24, C. R S. 1.03 "Benefit Recipient" means any individual who is a benefit recipient under Section 24-51-101(8), C R S 1.04 "Benefit" means a benefit under the Pension Plan, as that term is defined under the provisions of Article 51 of Title 24, C R S 1.05 "Board" means the Board of Trustees of PERA as established under the provisions of Article 51 of Title 24, C R.S 1.06 "Code" means the Internal Revenue Code of 1986, as amended (and corresponding provisions of any subsequent federal tax laws) and the regulations thereunder 1.07 "Effective Date" means January 1, 1999 1.08 "Eligible Member" means a Member who retires with an Effective Date of retirement on or after the Effective Date, or who dies on or after the Effective Date 1.09 "Employer" means an Employer with respect to its employees who are Members of PERA and with respect to Benefits paid by PERA under the provisions of Article 51 of Title ?4, C R S , provided that the employer signs an adoption agreement in the form specified by the Board 1.10 "Restricted Benefit" means the maximum Benefit permitted to be paid to a Benefit Recipient from the Pension Plan, as limited by Code Section 415, in accordance with Section 24-51-611, C R S "Member" means any individual who is a Member of PERA, as that term is defined under the provisions of Article 51 of Title 24, C R S 1.12 "Participant" means any Benefit Recipient who is eligible to participate in the Arrangement in accordance with Section 2 01. 1.13 "Pension Plan" means the defined benefit plan for PERA Members established under the provisions of Article 51 or Title 24, C.R.S., and qualified under Code Section 401. 1.14 "Retiree" means any individual who is a retiree under Section 24-51-101(39). C.R.S. 1.15 "Unrestricted Benefit" means the benefit that would be payable to a Benefit Recipient from the Pension Plan if the limits of Code Section 415 were not applicable in accordance with Section 24-51-611, C R S Article 2 —Eligibility and Payments 2.01 Eligibility to Receive Payments If. at the time an Eligible Member becomes a Retiree or dies or at any time thereafter, the Unrestricted Benefit of the Benefit Recipient under the Pension Plan exceeds the Restricted Benefit payable to the Benefit Recipient at that time, the Benefit Recipient shall become a Participant and shall be entitled to receive payments under this Arrangement, in accordance with the terms hereof, except as otherwise provided in the Employer's Adoption Agreement. 2.02 203 2.04 2.05 BENEFITARRA' ENT Amount of Payments A Participant shall receive payments under this Arrangement equal to the difference between his Unrestricted Benefit and his Restricted Benefit, provided that the amount of payments so determined shall be subject to change and to such adjustments as PERA deems appropriate, from time to time. Form and Timing of Payments Payments under this Arrangement shall be paid by the applicable Employer to each Participant at the same time and in the same form and manner as Benefits are provided to such Participant under the Pension Plan Any election made by an Eligible Member with regard to the distribution of Benefits under the Pension Plan, including the designation of a cobeneficiary or a named beneficiary as defined in Section 24-51-101(10) and (33), C R S , shall be equally applicable to and binding on such Eligible Member in connection with payments under this Arrangement Effect on Pension Plan Any Benefit payable under the Pension Plan shall be paid solely in accordance with the terms and provisions thereof and shall be subject to the Section 415 and other applicable tax limitations, nothing in this Arrangement shall operate or be construed in any way to modify, amend or affect the Benefits payable thereunder. Tax Withholding All payments under this Arrangement shall be subject to and reduced by applicable federal, state and local income, payroll and estate tax withholding requirements and all other applicable deductions required by this Arrangement or by law 3 Replacement RANGEMENT Article 3 Administration 3.01 Administrator PERA shall be the Administrator of the Arrangement and shall be responsible for the supervision and control of the operation and administration of the Arrangement, except as otherwise provided herein. PERA shall have the exclusive right and full discretion to construe and interpret the Arrangement and to decide any and all questions of fact, actuarial valuation interpretation, definition or administration arising thereunder or in connection with the administration of the Arrangement The interpretation and construction of any provisions of the Arrangement by the Administrator and its exercise of any discretion granted under the Arrangement shall be binding and conclusive on all persons who at any time have or claim to have any interest whatever under this Arrangement 3.02 Contributions and Payments (a) As soon as administratively feasible following the receipt of Employer contributions, PERA shall segregate from each Division's contributions the portion of the contributions necessary to make the payments due to Benefit Recipients in that Division for the next payment period and any applicable expenses under this Arrangement. Notwithstanding the foregoing, if PERA determines, in its sole discretion, that the allocation of contributions to the Arrangement would jeopardize the actuarial soundness of the Pension Plan, PERA shall cease to segregate contributions for the Arrangement and shall notify the participating Employers and affected Benefit Recipients. (b) Contributions segregated for payments and expenses under the Arrangement shall he separately accounted for and shall be used exclusively for payments and expenses under the Arrangement 4 3.03 3.04 (c) Within a reasonable period of time before each payment date, PERA shall distribute to each participating Employer the gross amount necessary, as determined by PERA, to satisfy such Employer's liability for amounts due on such payment date under the Arrangement (d) The Employer from whom the Eligible Member retired or who employed the Eligible Member at his death shall be solely responsible for paying any amounts received from PERA and due to the Benefit Recipient under the terms of the Arrangement. PERA shall have no obligation to pay any amounts due under the terms of the Arrangement (e) The Employer shall be responsible for satisfying all tax withholding, payroll tax payments, other applicable tax payments and reporting requirements applicable to the Arrangement, if any, and shall be responsible for administering all payments due under the Arrangement Plan Unfunded The payments under this Arrangement shall not be funded Nothing contained herein shall be construed as providing for assets to be held in trust for the Participants PERA reserves the right in the future to establish and fund one or more trusts for the purpose of paying some or all of the amounts promised to Participants under the Arrangement Appeal Procedure If a dispute involving the interpretation of this Arrangement arises, the Administrator s decision shall be final, conclusive, and binding unless it is appealed and resolved in accordance with the administrative review procedures set forth in the Board rules Article 4 --Amendment and Termination 4.01 Amendment and Termination The Board reserves the right to amend or terminate the Arrangement at any time and from time to time Such amendment or termination may be retroactive to the ex*.ent that the Board deems such action necessary, in its sole discretion, to maintain the tax - qualified status of the Pension Plan or the status of this Arrangement as a qualified excess benefit arrangement as defined in Code Section 415(m) or to avoid jeopardizing the actuarial soundness of the Pension Plan In addition, the Arrangement may be amended or terminated to eliminate all payments with respect to any Member or other individual who has not become eligible to participate in the Arrangement as of the date of such amendment or termination by reason of retirement or death in accordance with Section 2 01 The Board reserves the right to modify this Arrangement as it relates to a specific Employer by written agreement of the Board and such Employer as evidenced in the Adoption Agreement of that Employer Article 5 —General Provisions 5.01 Applicable Law All questions pertaining to the validity. construction, and administration of the Arrangement shall be determined in conformity with the laws of the state of Colorado, except to the extent federal law preempts state law BENEFI II II t Replacement 5.02 Construction (a) The titles and headings of the Articles and Sections in this instrument are for convenience only In case of ambiguity or inconsistency, the text rather than such titles or headings shall control. (b) If any provision of the Arrangement or the application thereof to any circumstance or person is invalid, the remainder of the Arrangement and the application of such provision to other circumstances or persons shall not be affected thereby. 5.03 Nonalienation Benefits under this Arrangement shall not be subject to alienation or legal process, except to the extent permitted under Section 24-51-212, C.R S 5.04 5 05 No Enlargement of Employment Rights The establishment of the Arrangement shall not confer any legal rights upon any employee or other person for a continuation of employment, nor shall it interfere with the rights of the Employer to discharge any employee and to treat the employee without regard to the effect which that treatment might have upon the employee as a Participant in the Arrangement. Information Required By Arrangement Benefit Recipients, other individuals and Employers shall furnish to the Administrator such evidence, data, and information as the Administrator considers necessary or desirable for the purpose of administering the Arrangement 5 Rep emen RRANGEMENT COLORADO PERA 2018 SECTION 415(b) LIMITS Retirement Age (Years) 0 50 99,839 51 106,176 52 112,999 53 120,351 54 128,280 55 136,842 56 146,084 57 156,059 58 166,850 59 178,544 60 191.237 61 205,026 62 220.000 63 220,000 64 220,000 65 220,000 66 220,000 67 220,000 68 220.000 69 220,000 70 220,000 1 100,367 106,744 113,611 121,012 128,994 137,612 146,915 156,958 167,825 179,602 192,386 206,274 220,000 220.000 220,000 220,000 220.000 220.000 220,000 220,000 2 100,895 107,313 114,224 121,673 129,707 138,382 147.746 157,857 168,799 180,659 193,535 207,522 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 This table is provided by PE RA's actuary 3 101,423 107,881 114,837 122,334 130,421 139,152 148,577 158.757 169,774 181,717 194,684 208,769 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 4 101,951 108,450 115,449 122,994 131,134 139,923 149,409 159,656 170,748 182,775 195,833 210,017 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 Months 5 102,479 109,019 116,062 123.655 131,848 140,693 150,240 160,555 171,723 183,833 196,982 211,265 220,000 220,000 220,000 220,000 220.000 220,000 220,000 220,000 6 103,007 109.587 116,675 124,316 132,561 141,463 151,071 161,454 172,697 184,890 198,131 212,513 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 7 103,535 110,156 117,288 124,977 133,275 142,233 151,902 162,354 173,672 185,948 199.280 213/61 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 8 104,063 110,724 117,900 125,637 133,988 143,003 152.734 163,253 174.646 187,006 200,430 215,009 220,000 220,000 220,000 220,000 220,000 220,000 220.000 220,000 9 104,592 111,293 118.513 126,298 134,702 143,773 153,565 164,152 175,621 188,064 201,579 216,256 220,000 220,000 220,000 220,000 220.000 220,000 220.000 220,000 10 105,120 111.861 11`126 126,959 135,415 144,543 154,396 165,052 176.595 189,121 202.728 217,504 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 11 105,648 112,430 ' 19 739 127,620 136.129 145,314 155,227 165,951 177,569 190.179 203,877 218,752 220,000 220,000 220,000 220,000 220,000 220,000 220,000 220,000 This booklet provides general information about the effect of Internal Revenue Code Section 415(b) limits on PERA benefits Your rights, benefits, and obligations as a PERA member are governed by Title 24, Article 51 of the Colorado Revised Statutes, and the Rules of the Colorado Public Employees' Retirement Association, which take precedence over any interpretations in this booklet 6 General information Arbpti'on of Arranzernent Agreement to be Bound by Terms of Arrangement dbl)natons_ of Employer PERks Qualified Replacement Benefit Arrangement Adoption Agreement Colorado Public Employees' Retirement Association PO Box 5800, Denver, Colorado 80217.5800 1-800-759-PERA (737?) • Fax: 303-863-3727 • www copera.org 0% COLORADO PERA. Employer 61.1,172 . /44/c.1 Employer Address Employer Contact Employer No. Please Print 1 1 o 861.6 /jco 6reee ee �i la .4, Street /et SZ)) City State ny (le �. r rte -(w7 t 0 1)1‘5° / 3 Telephone Number ( 9 ZIP Code 1/4; e rrrr The undersigned Employer hereby adopts Colorado PERA's Qualified Replacement Benefit Arrangement ("Arrangement") with respect to employees of the Employer who are Members of PERA and with respect to benefits paid by PERA under the provisions of Article 51 of Title 24, Colorado Revised Statutes. The signatories represent that they have the authority to sign this Agreement and bind the Employer to the terms hereof The signatories further represent that they and the Employer have taken all actions necessary to effectuate the terms of this Agreement, including but not limited to obtaining any approval required by the Employer's board or other body. The Employer agrees to be bound by the terms of the Arrangement, as the same may be amended from time to time. The Employer further agrees to be bound by all actions, decisions, and interpretations of PERA or the Board of Trustees of PERA, in connection with the administration of the Arrangement. The Employer acknowledges that it shall be solely responsible for paying any amounts received from PERA and due under the terms of the Arrangement to the Benefit Recipients for the Eligible Members who retired from the Employer or who died while employed by the Employer The Employer agrees to pay to each such Benefit Recipient on each payment date the amount remitted to the Employer by PERA to satisfy the Employer's obligation to each such Benefit Recipient, reduced by all applicable federal, state and local income, payroll and estate tax withholding amounts, if any. The Employer acknowledges that it shall be solely responsible for satisfying all tax withholding, payroll tax payments, other applicable tax payments, and reporting requirements applicable under the Arrangement, if any ti AGREED, oy�,this Al(4 day of --T u en- , ZO / Sign Here 4 By 5/25-rba (REV 12 U) On Behalf of Signature fe Thee,fice) e (d.„4 Boa 2 Name d Title( �eZGai Ty` Cr, C% Employer Name ale lc/ 4,46,71 TP 1€/e/ Cy. ,fl (S• 5 �ay/�, 1Z S �,1 Esther Gesick From: Sent. To: Subject: Attachments. Don Warden Friday, June 1, 2018 1 59 PM Esther Gesick FW PERA Replacement Benefit Arrangement Resolution for PERA 415 RBA docx, PERA 415 limits (002) pdf Will you put the attached resolution and PERA agreement on the BOCC agenda for Monday, June 11th, when I am there? The email below explains it Thanks, and have a great weekend' Donald D Warden Director of Finance and Administration Finance and Administration PO Box 758 1150 O Street Greeley, CO 80632 tel 970-356-4000 Extension 4218 email dwarden@co weld co us Confidentiality Notice This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited From. Don Warden Sent: Friday, June 01, 2018 1 44 PM To: Steve Moreno <smoreno@weldgov corn>, Sean Conway <seanconwayweld@gmail corn>, Mike Freeman <mfreeman@weldgov corn>, Barbara Kirkmeyer <bkirkmeyer@weldgov corn>, Julie Cozad <Jcozad@weldgov corn> Cc: Bruce Barker <bbarker@weldgov corn>, Barb Connolly <bconnolly@weldgov corn> Subject. PERA Replacement Benefit Arrangement Since you are all at CCI next week I wanted to run by you something PERA needs from us I plan putting it on the BOCC agenda on Monday, June 11th when I am there to explain it more fully and answer questions We have been contacted by PERA indicating there will be a Weld County Department of Public Health and Environment former employee (Trevor Jincek we are assuming) retiring at age 50 The Internal Revenue Code (IRS) Code Section 415 (b) imposes a dollar limit on the benefit amount a pension plan can pay a retiree The amount is limited by the benefit amount and the age a person takes the benefit In this case because of the benefit amount and retiring at the early age of 50 the amount PERA can pay from its trust exceeds the IRS amount until the retiree reaches a higher age actuarially However, the Internal Revenue Code (IRS) Code Section 415 (m) allows PERA to use a replacement benefit arrangement 1 (RBA) to provide relief for a member who exceeds the 415 (b) limit, in other words to pay the difference between the benefit earned and the limit The way the RBA works PERA would pay a portion of the benefit up to the IRS limit allowed, and then through the RBA Weld County would pay the difference to the retiree Weld County would then withhold the amount paid from the PERA contribution Weld County makes each month As a result, the replacement benefit arrangement (RBA) will not have any financial impact on Weld County to accommodate a member who exceeds the 415 (b) limit We have had a RBA in place for the Weld County Retirement Plan for nearly 20 years, but have never needed to have one for any PERA retiree I am recommending that Weld County approve the attached PERA replacement benefit arrangement (RBA) and authorize the Chair to sign the RBA If any of you have question let me know and we can talk I will plan on having the resolution and RBA on the June 11th BOCC agenda, unless I hear otherwise from any of you Thanks, and have a great weekend and CCI Conference' Donald D Warden Director of Finance and Administration Finance and Administration PO Box 758 1150 O Street Greeley, CO 80632 tel 970-356-4000 Extension 4218 email dwarden@co weld co us Confidentiality Notice This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited 2 Hello