Appo Group Solution Streamlines Participant Communication

The new solution aims to cut costs and reduce compliance risks by integrating the creation, delivery and management of multimedia communication materials through one platform.

Appo Group, a communications technology provider focusing on the retirement services industry, is rolling out a new solution designed to integrate the creation and management of multimedia communications including print, email and Web into a single platform.  

The Appo solution is comprised of two components. The Appo Toolset allows designers to drag and drop variable content into various documents, while storing content replicated across different media channels as “modules” for future use. All elements used to create communications are stored in the Appo Portal, a secure website where internal and external users can manage and order materials with varying security and approval processes in place.

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The firm says the solution aims to cut time and costs while improving efficiency of the participant communication process, a challenge and increasingly important task in the retirement services space.  

“Participant engagement can be difficult and expensive, especially when it means integrating complex data sources and working across multiple platforms,” explains Steve Wigler, president of Appo Group. 

He adds, “Unlike many of the existing solutions on the market, Appo is first and foremost a technology solution, not a print solution. In fact, clients appreciate that we are agnostic as to which fulfillment provider they use, so bringing us in doesn’t cause disruption to existing relationships.”

The firm says it’s currently working with one major plan provider and considering others to find ways to apply the solution to other data-driven objectives including annual plan reviews, enrollment materials, fund fact sheets, participant statements and compliance communications.

While the fate of the DOL’s conflict of interest rule remains uncertain under the administration of President Donald Trump, many industry experts note that firms are still widely preparing for a more fiduciary-focused industry. Moreover, related compliance issues remain a large part of ERISA litigation that’s likely to continue as well. 

(b)lines Ask the Experts – 3401(a) Definition of Compensation

“Our recordkeeper-provided documents for our 403(b) plan states that we should be using a ‘3401(a)’ definition of compensation.

“What in the world is 3401(a) compensation? I know what W-2 wages are obviously, but how is this definition different?” 

David Levine and David Powell, with Groom Law Group, and Michael A. Webb, vice president, Retirement Plan Services, Cammack Retirement Group, answer: 

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First of all, the Experts commend you for reviewing the compensation definition in your plan and understanding it, since one of the most significant areas where plan defects occur is the failure to properly administer the plan’s definition of compensation.

Along with W-2 compensation, 3401(a) compensation, is one of the most common definitions of compensation found in retirement plans. Named for the Section of the Code that defines “wages” for certain purposes, Code Section 3401(a) wages are defined as compensation that is subject to federal income tax withholding at the source of the compensation. In practice, such a definition will include less pay codes than a W-2 compensation definition, because wages subject to withholding are generally only those wages included on an employee’s pay stub (in fact, 3401(a) compensation, is sometimes known as “pay stub” compensation). Thus, compensation items that do NOT appear on an employee’s paystub but are included in year-end W-2 reporting, such as the taxable cost of group-term life insurance in excess of $50,000, are NOT included in Section 3401(a) wages.

Section 3401(a) wages are a popular definition of compensation in retirement plans for good reason. Along with W-2 compensation, Section 3401(a) wages are an alternative safe harbor definition of compensation, meaning that this definition can be used to calculate the 415 limit as well as related compliance limits.

Of course, your plan is not REQUIRED to use a Section 3401(a) wages definition of compensation. If you feel that, say, a W-2 compensation definition is more appropriate and/or more compatible with your retirement plan operating systems, most vendor prototype plan documents (coming soon for 403(b)s) will offer W-2 compensation as an option (and, if not, there is always an option of an individually designed plan document that would include this definition). Regardless of the definition you choose, someone should regularly review all of your pay codes to confirm that each pay type is properly included/excluded from the plan compensation definition, based on the definition of compensation that is being used.

It should also be noted that other compensation definitions may apply to your retirement plan as well. For purposes of calculating the contribution limits to a 403(b) plan, for example, there is a special definition of “includible compensation” under 403(b)(3), which also allows the ability to make employer contributions for up to five years following termination of employment, a feature unique to 403(b) plans.

 

NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.  

Do YOU have a question for the Experts? If so, we would love to hear from you! Simply forward your question to Rebecca.Moore@strategic-i.com with Subject: Ask the Experts, and the Experts will do their best to answer your question in a future Ask the Experts column.
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