403(b) Regulation Resources
for Churches and
Church-Related Organizations*

*Does not include Non-Qualified Church-Controlled Organizations
("Non-QCCO" defined - click here)

[Employer Plan:  Exclusive use of the Church of God Retirement Plan]

The Church of God Retirement Plan that your organization (i.e. church or other church-related organization) provides to its ministers and employees is a valuable benefit to them and for your organization as you seek to retain talented, energetic staff.  The Board of Pensions is prepared to provide information to help your organization understand and comply with certain new requirements that apply to this plan so that your organization and plan participants avoid adverse tax consequences.

The IRS published new regulations that fully take effect on Jan. 1, 2009.  These regulations — which impact all 403(b) plans, including church plans — are not difficult to implement if your organization’s retirement plan is solely the Church of God Retirement Plan provided by the Board of Pensions. In fact, to become fully compliant, most organizations will need to invest less than an hour.  Below, you will find explanations of the regulations along with resources that will help you move toward compliance.

Written plan document requirement

The Church of God Retirement Plan is operated as a retirement income account program under Internal Revenue Code Section 403(b)(9).  Organizations that provide a 403(b)(9)-type plan must maintain written documents that describe all material plan provisions. The Board of Pensions provides general plan documentation for the Church of God Retirement Plan.  However, since each organization in this plan has flexibility related to certain plan provisions, your organization must develop and maintain additional written rules and procedures that address:

• Which employees are eligible to participate in the retirement plan; and
• What contributions the organization will make on behalf of employees.

The Board of Pensions makes compliance easy!

To help you with this, the Board of Pensions has prepared an Eligibility and Participation Schedule to document the additional written rules and procedures, unique to your organization, that relate to your use of the Church of God Retirement Plan.  In order to comply with the new regulatory requirements, your organization needs to take the following steps:

Step 1 — Annually review your copy of the Church of God Retirement Plan v.20100626 (pdf).
Step 2 — Print, complete and retain a copy of the Eligibility and Participation Schedule (pdf) to document the additional written rules and procedures, unique to your organization, that must be addressed.  This Schedule is considered part of your organization’s pension plan.  You do not have to send this Schedule to the Board of Pensions but you do need to be sure to keep an updated copy in your files at all times.  And, of course, you will need to be sure that you follow the rules and procedures that you set out in the Schedule.

If you make contributions to the Church of God Retirement Plan as your sole retirement plan, that is all you have to do.  But if you use multiple vendors, or if any contributions were made after 2004 to a 403(b) vendor that will not be authorized to receive contributions on January 1, 2009, there are special rules you have to follow.  Please review the information prepared for organizations using multiple vendors.

The Board of Pensions has been dedicated to enhancing the financial security of our plan participants for well over 50 years.  Our employees stand ready to help you.  Please email us at Info@COGpension.org or call 1-800-844-8983 for additional information.

Additional resources:
Summary of the Final Regulations
Frequently Asked Questions about the 403(b) Regulations
Advantages of the 403(b)(9) Church of God Retirement Plan
Eligibility and Participation Schedule (WORD format)
Retirement Plan Summary Booklet

Board of Pensions of the Church of God
P. O. Box 2559
Anderson, IN  46018
(800) 844-8983      (765) 642-3880      FAX (765) 642-3942      TeleTouch (800) 547-7754