Compliance July 9, 2013

ASPPA Supports Forfeitures to Fund Safe Harbor Contributions

July 9, 2013 (PLANSPONSOR.com) - The American Society of Pension Professionals & Actuaries (ASPPA) sent a comment letter to the Internal Revenue Service (IRS) regarding the use of forfeitures to fund ADP test safe harbor contributions and certain other contributions.
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ASPPA is supplementing a May 2012 comment letter to (1) provide additional support for its position that forfeitures can be used to fund these contributions, and (2) request that, in the absence of a change in ruling policy, Internal Revenue Code (Code) §7805(b) be applied to provide transitional relief to plan sponsors who may have reasonably believed that, in the absence of an express prohibition, their plan’s language permitted forfeitures to be used in this way.

The Society recommended the IRS change its ruling policy and, to the extent necessary, issue sub-regulatory guidance that confirms forfeitures are permissible sources for qualified non-elective contributions (QNECs) and qualified matching contributions (QMACs) and that the non-forfeitable status of such amounts is determined at the time they become part of the accrued benefit of the recipient of the restricted contributions.

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The letter also said the IRS should apply the protections of Code §7805(b) liberally in circumstances where plan documents subject to a favorable opinion, notification or determination letter do not explicitly prohibit the use of forfeitures to fund these contributions.

The comment letter is here.

Deals and People July 9, 2013

Hartford Investment Management Announces Hires

July 9, 2013 (PLANSPONSOR.com) - Hartford Investment Management Company (HIMCO) hired two institutional sales representatives and a consultant relations head.
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Matthew Addesa and Michael Mondo joined the firm as institutional sales representatives covering the Central and East regions, respectively, and Christopher Miller is the firm’s new head of consultant relations.

Addesa was previously with Columbia Management for six years in institutional sales, most recently as an eastern region institutional sales representative. Prior to that, he was a manager of corporate planning at Bank of America/FleetBoston Financial, and began his career in financial services at State Street Corporation. Addesa earned a B.S. in business administration from Western Michigan University and holds the Series 3 license and the Series 7 and 63 FINRA registrations (held through Hartford Equity Sales Company, Inc.). He is based at HIMCO’s headquarters in Hartford, Connecticut.

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Mondo has been an institutional asset management sales professional since 1998. He was previously with Invesco Advisers LLC, where he was a senior director, Institutional Sales and Client Service, covering the Northeast. Prior to that, he held institutional sales roles with J.P. Morgan Asset Management, Evergreen Investment Management and State Street Corporation. Mondo began his career in financial services in 1986 as a financial consultant with Shearson Lehman Brothers. He earned his B.B.A. in marketing from Adelphi University and his M.B.A. in finance from St. John’s University. He also holds the Series 3 license and the Series 7 and 63 FINRA registrations (held through Hartford Equity Sales Company, Inc.). He is based in Boston, Massachusetts.

Miller was previously managing director and global head of consultant coverage for Credit Suisse Asset Management, where he was responsible for developing relationships with leading consulting firms around the world. With more than 30 years of experience, he has headed consultant relations and sales efforts with leading asset managers and banks including Citadel, Bear Stearns, Morgan Stanley Capital International/BARRA, Flemings and Bankers Trust. He received a B.A. in mathematics and economics from Hobart College, and holds the Series 7 and 63 FINRA registrations (held through Hartford Equity Sales Company, Inc.). He is also based in Hartford, Connecticut.

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