HomeMy WebLinkAbout2011/11/15 Item 03CITY COUNCIL
AGENDA STATEMENT
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~ ` CHUL4 VISTA
NOVEMBER 15, 2011 Item 3
ITEM TITLE: RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
ADMINISTRATIVE SERVICES AGREEMENT WITH ICMA
RETIREMENT CORPORATION TO INCLUDE
ADMINISTRATIVE ALLOWANCE PROVISION
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
DEFERRED COMPENSATION PLAN ADMINISTRATIVE
AGREEMENT WITH NATIONWIDE RETIREMENT
SOLUTIONS, INC. TO PROVIDE FOR ADMINISTRATIVE
EXPENSE REIMBURSEMENT
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
NATIONWIDE RETIREMENT SOLUTIONS, INC.
GOVERNMENTAL MONEY PURCHASE PLAN AND
TRUST (401(A) PLAN) REVISING SECTIONS E2 AND ES
AND ADDING A FINAL PAY PROVISION
SUBMITTED BY: DIRECTOR OF FINANCE/TREASURER .~ ~~
REVIEWED BY: CITY MANAGER
ASSISTANT CITY ANAGER 5
4/STHS VOTE: YES ~ NO
SUMMARY
Nationwide Retirement Solutions Inc. (Nationwide) and ICMA Retirement Corporation are
the plan administrators for the City's Deferred Compensation Plan. These amendments
would add administrative expense reimbursement and administrative allowance provisions
to their plan agreements respectively. In addition, a final pay provision would be added to
the Nationwide Governmental Money Purchase Plan and Tnast (401(a) Plan).
ENVIRONMENTAL REVIEW
The Environmental Review Coordinator has reviewed the proposed activity for
compliance with the California Environmental Quality Act (CEQA) and has determined
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NOVEMBER 15, 2011 Item 3
Page 2 of 4
that the activity is not a "Project" as defined under Section 15378 (b)(4) of the State
CEQA Guidelines; therefore, pursuant to Section 15060(c)(3) of the State CEQA
Guidelines the activity is not subject to CEQA. Thus, no environmental review is
necessary.
RECOMMENDATION
Council approve the resolutions.
BOARDS/COMMISSION RECOMMENDATION
Not applicable.
DISCUSSION
ICMA
ICMA Retirement Corporation (ICMA) has been a plan administrator for the City's
Deferred Compensation Plan since 1986. At that time, the contract with ICMA was
established with an initial term of five years with an automatic renewal for each
succeeding year unless there was a 60-day written notice provided by either party. The
original Plan Administration Fee was set at 0.90% of the plan assets and over the years
was reduced to 0.29% due to the increasing size of the City's plan assets.
In November 2004, City Council approved the establishment of a five-year fixed term
agreement with automatic renewals for two succeeding years in exchange for 0.00% Plan
Administrative Fee thus yielding higher returns to employees participating in the plan.
This agreement is set to expire next month.
Staff is recommending approval of the proposed amendment to establish a new five-year
fixed term agreement with an automatic renewal for each succeeding year which will not
only keep the Plan Administrative Fee at 0% but also include an annual administrative
allowance of $8,200 payable to the City. This is a flat amount and doesn't change with
the value of the plan's assets. Under ERISA requirements, these funds can only be used
to reimburse the City for staff time and other costs incurred to administer the deferred
compensation plan. The payment would be paid to the City on a quarterly basis starting in
January 2012 and would have no negative impact on the plan participants.
Attached is the amendment to the Administrative Services Agreement outlining the
administrative allowance (Attachment A).
NATIONWIDE RETIREMENT SOLUTIONS
Deferred Compensation Plan
The City has offered a Deferred Compensation Plan through Great Western Savings (now
known as Nationwide Retirement Solutions, Inc.) to employees since 1975. Staff is
recommending that the City amend Nationwide Deferred Compensation Plan Agreement
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NOVEMBER 15, 2011 Item 3
Page 3 of 4
to include administrative expense reimbursement which is similar to ICMA's
administrative allowance described above. Annually, Nationwide would pay the City
0.004% of the value of the plan assets. Therefore the reimbursement would fluctuate as
plan assets increase or decrease in value. These funds would have the same use
restrictions as the ICMA funds and would have no negative impact to the plan
participants. The only differences between the two companies are how they calculate the
amount payable to the City, the frequency of the payment, and that Nationwide does not
require afive-year fixed term agreement.
Attached is the amendment to the Deferred Compensation Plan Agreement outlining the
administrative expense reimbursement (Attachment B).
Governmental Money Purchase Plan and Trust (401 (a) Plan)
Staff is also recommending the inclusion of a final pay provision for all eligible
participating employees. Upon an eligible employee's termination of employment, if
there is accumulated vacation pay due to that employee, the City would contribute that
accumulated vacation pay into the 401(x) Plan rather than paying it directly to the
employee. Often, long time employees accumulate significant amounts of vacation time
throughout their careers, and this provision would deposit the value of those many hours
into atax-deferred program to be accessed by the employee at a later date. This inclusion
would be at no cost to the City, and in fact there would be a slight savings as the 1.45%
FICA tax would not be paid on the funds deposited into the 401(a) Plan. In addition, the
amendment revises Sections E2 and ES of the agreement, so that it accurately reflects the
current status of the Plan contributions.
Attached is the amended Adoption Agreement for the Governmental Money Purchase
Plan and Trust (401(a) Plan) outlining the final pay provision (Attachment C).
DECISION MAKER CONFLICT
Staff has reviewed the decision contemplated by this action and has determined that it is
not site specific and consequently the 500 foot rule found in California Code of
Regulations section 18704.2(a)(1) is not applicable to this decision.
CURRENT FISCAL IMPACT
The current fiscal impact of the administrative allowance and administrative expense
reimbursement would be an increase of $21,900 in General Fund revenues to offset costs
incurred in administering the Deferred Compensation Plan. The current fiscal impact of
the final pay provision would be insignificant and difficult to determine as it would be
based on the number of eligible employees separating from the City this year and the
value of their accumulated vacation time. However, in any case it would be a savings to
the City.
ONGOING FISCAL IMPACT
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NOVEMBER 15, 2011 Item~_
Page 4 of 4
The ongoing fiscal impact of the administrative allowance and administrative expense
reimbursement would be an increase of $22,000 in General Fund revenues to offset costs
incurred in administering the Deferred Compensation Plan. This amount is subject to
change as Nationwide plan assets increase or decrease in value. The ongoing fiscal
impact of the final pay provision would be insignificant and difficult to determine as it
would be based on the number of eligible employees separating from the City this year
and the value of their accumulated vacation time. However, in any case it would be a
savings to the City.
ATTACHMENTS
A) Amendment to ICMA Administrative Services Agreement
B) Amendment to Nationwide Deferred Compensation Plan Agreement
C) Amendment to Adoption Agreement for Nationwide Governmental Money Purchase
Plan and Ttvst (401 (a) Plan)
Prepared by: Nadine Mandery, Senior Management Analyst, Finance Department
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THE ATTACHED AGREEMENT HAS BEEN REVIEWED
AND APPROVED AS TO FORM BY THE CITY
ATTORNEY'S OFFICE AND WILL BE
FORMALLY SIGNED UPON APPROVAL BY
THE CITY COUNCIL
,.
len R~ Go' s
~~~/Attorney
Dated: ~ ~ ~ ~l ~ / J
~-~
ADMINISTRATIVE SERVICES AGREEMENT
BETWEEN
THE CITY OF CHULA VISTA, AND
ICMA RETIREMENT CORPORATION
FOR PLAN NUMBER 2438
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ATTACHMENT A
AMENDMENT
TO THE
Administrative Services Agreement
for Plan Number 2438
This Amendment to the Administrative Services Agreements ("Agreement") for Plan number
302438 (the "Plan') is entered by and between City of Chula Vista ("Employer") and ICMA
Retirement Corporation ("ICMA-RC"), effective as of the date of execution by the Employer
below ("Execution Date").
WHEREAS, the Employer sponsors the Plan on behalf of its eligible employees and retirees;
and
WHEREAS, the Employer entered the Agreement to engage ICMA-RC to provide
administrative services and investments for the Plan under the terms specified in the Agreement;
and
WHEREAS, the parties wish to amend the Agreement to provide for the continued elimination
of the Plan Administration fee and Mutual Funds Fee under the Agreement for the Plan over the
term of the Agreement contingent on the Employer's use of EZLink for enrollment and
contribution processing over the term of the Agreement and contribution funds are submitted
through wire transferor ACH; and
WHEREAS, Section 10(a) of the Agreement provides that the Agreement may be amended
pursuant to a written instrument signed by the parties;
NOW, THEREFORE, the Agreement is hereby amended as follows
FIRST
Section 6 of the Agreement, titled "Compensation and Payment" is amended by replacing
all subsections with the following:
(a) There shall be no asset-based or per-participant fees charged under this
Agreement. ICMA-RC's compensation under this Agreement shall be as set forth
in subsection (b) below.
(b) Compensation for Management Services to the Trust, Compensation
for Advisory and other Services to The Vantagepoint Funds and Payments
from Third-Party Mutual Funds. Employer acknowledges that in addition to
amounts payable under this Agreement, ICMA-RC receives fees from the Trust
for investment management services furnished to the Trust. Employer further
acknowledges that certain wholly owned subsidiaries of ICMA-RC receive
compensation for advisory and other services furnished to The Vantagepoint
Funds, which serve as the underlying portfolios of a number of Funds offered
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through the Trust. The fees referred to in this subsection are disclosed in the
Retirement Investment Guide. These fees are not assessed against assets invested
in the Trust's Mutual Fund Series. In addition, to the extent that third party
mutual funds are included in the investment line-up for the Plans, ICMA-RC may
receive payments from such third party mutual funds or their service providers,
which may be in the form of 12b-1 fees, service fees, or compensation for sub-
accounting or other services provided by ICMA-RC on behalf of the funds.
(c) Administrative Allowance. ICMA-RC shall pay an annual
administrative allowance of $8,200, which shall be paid quarterly to the Employer
or to the Plan. Such payments reflect ICMA-RC's assumptions regarding the
aggregate level of revenue received from funds offered by the Plan at the
initiation of this Agreement. In the event that the Employer chooses to replace
funds during the term of this Agreement, the revenue assumptions with respect to
the new funds will be re-evaluated and the administrative allowance will be
adjusted commensurately. Employer understands that the Plan administrative
allowance is to be used only to pay for reasonable plan administrative expenses of
the Plan or allocated to participant accounts under the Plan at the instruction of
the Employer.
(d) Redemption Fees. Redemption fees imposed by outside mutual funds in
which Plan assets are invested are collected and paid to the mutual fund by
ICMA-RC. ICMA-RC remits 100% of redemption fees back to the specific
mutual fund to which redemption fees apply. These redemption fees and the
individual mutual fund's policy with respect to redemption fees are specified in
the prospectus For the individual mutual fund and referenced in the Retirement
Investment Guide.
(e) Payment Procedures. All payments to ICMA-RC pursuant to this Section 6
shall be paid out of the Plan assets held by the Trust and shall be paid by the
Trust, to the extent not paid by the Employer. The amount of Plan assets held in
the Trust shall be adjusted by the Trust as required to reflect such payments. In
the event that the Employer agrees to pay amounts owed pursuant to this section 6
directly, any amounts unpaid and outstanding after 30 days of invoice to the
Employer shall be withdrawn from Plan assets held by the Trust.
The compensation and payment set forth in this section 6 is contingent upon the
Employer's use of ICMA-RC's EZLink system for contribution processing and
submitting contribution funds by ACH or wire transfer on a consistent basis over the
term of this Agreement.
Employer further acknowledges and agrees that compensation and payment under this
Agreement shall be subject to re-negotiation in the event that the Employer chooses to
implement additional mutual funds outside of the ICMA-RC Mutual Fund Alliance.
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SECOND
This Agreement shall be in effect and commence on the date all parties have
signed and executed this Agreement ("Inception Date"). The term of this
Agreement will commence on the Inception Date and extend five (5) years from
that date. This Agreement will be renewed automatically for each succeeding year
unless written notice of termination is provided by either party to the other no less
than 60 days before the end of such Agreement year. The Employer understands
and agrees that, in the event the Employer terminates this Agreement (or replaces
the VantageTrust PLUS Fund as an investment option in its investment line-up),
ICMA-RC retains full discretion to release Plan assets invested in the
VantageTrust PLUS Fund in an orderly manner over a period of up to 12 months
from the date ICMA-RC receives written notification from the Employer that it
has made a final and binding selection of a replacement for ICMA-RC as
administrator of the Plan (or a replacement investment option for the
VantageTrust PLUS Fund).
The fee amendment specified in section 6 of the Agreement will take effect following the
Retirement Corporation's receipt of one fully-executed copy of this Amendment.
In all other respects, the Agreement is hereby ratified and affirmed.
IN WITNESS WHEREOF, Employer has caused this Amendment to be executed by its duly
authorized officer this day of , 2011.
CITY OF CHULA VISTA
By:
Print Name:
Title:
Section 9 of the Agreement, titled "Term" is amended to provide as follows:
INTERNATIONAL CITY/COUNTY MANAGEMENT ASSOCIATION
RETIREMENT CORPORATION
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i,1~lr..,4~
I..TI
sy
Angela C. Montez
Assistant Corporate Secretary
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THE ATTACHED AGREEMENT HAS BEEN REVIEWED
AND APPROVED AS TO FORM BY THE CITY
ATTORNEY'S OFFICE AND WILL BE
FORMALLY SIGNED UPON APPROVAL BY
THE CITY COUNCIL
~_--~ tiL % ~l~
G~~n R. oogins
,~ ~~ty Attorney
i
Dated: I ~ ~ ~ ~i
r
AMENDED DEFERRED COMPENSATION PLAN AGREEMENT
BETWEEN
THE CITY OF CHi_II,A VISTA, AND
NATIONWIDE RETIREMENT SOLUTIONS, INC.
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ATTACHMENT B
Amended Deferred Compensation Plan Agreement for the City of Chula
Vista, CA
This Amendment to the Deferred Compensation Plan Administration Agreement
("Agreement") is entered into and effective this day of ,
between the City of Chula Vista (hereinafter, "the EMPLOYER") and Nationwide
Retirement Solutions, Inc., a wholly owned subsidiary of NFS Distributors, Inc., and a
Delaware Corporation (hereinafter, "NATIONWIDE")
RECITALS
WHEREAS, the EMPLOYER desires to contract with NATIONWIDE to provide
administrative services to the PLAN; and
WHEREAS, NATIONWIDE desires to provide such services subject to the terms
and conditions set forth herein;
NOW, THERFORE, in consideration of the mutual promises contained herein the
parties agree as follows:
1. The above recitals are expressly incorporated by reference and made a part of
this Amendment.
2. ADMINISTRATIVE EXPENSE REIMBURSEMENT is added to the Agreement to
read as follows:
NATIONWIDE agrees to pav to the EMPLOYER 0.04 percent (4 basis points)
on an annual basis on the EMPLOYER'S plan assets that are being
administered by Nationwide as of September 30'" of that year, for as long as
NATIONWIDE is both a 457 and 401(a) provider for the EMPLOYER.
The EMPLOYER acknowledoes the purpose of the expense reimbursement is
to be used solely for the exclusive benefit of the plan, its participants and/or
their beneficiaries or as otherwise permitted pursuant to the terms of the plan
document The EMPLOYER will indemnify and hold Nationwide harmless for
the improper use of any reimbursement pavments.
The annual reimbursement is payable at the end of September then annually
thereafter All pavments will be made within thirty (301 days of September
NATIONWIDE one-twelfth of the annual reimbursement for each month
remaining in the year in which the agreement is terminated.
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In all other respects, the Agreement shall remain the same. The Agreement, as hereby
amended, is hereby ratified and confirmed and shall remain unmodified and in full force
and effect except as herein expressly amended.
IN WITNESS WHEREOF, the parties have executed this Agreement on the day and
year below.
NATIONWIDE RETIREMENT SOLUTIONS, INC.
By:
Title:
(Name Printed)
Date:
Chula Vista, CA
By:
Title:
(Name Printed)
Date:
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ATTACHMENT C
Amendment to Adoption Agreement for
Nationwide Retirement Solutions Governmental Money Purchase Plan and
Trust for The City of Chula Vista
WHEREAS the City of Chula Vista (City/Employer) adopted the NRS
Governmental Money Purchase Plan and Trust (Plan) effective Januazy 1, 2002; and
WHEREAS, the Plan was most recently amended in 2009; and
WHEREAS, the City now wishes to further amend the Plan as set forth below,
NOW THEREFORE, the Plan is amended as follows:
1. Effective Date of this Amendment is: November 15, 2011.
2. This Amendment shall not apply to any Employee who severed employment
before the effective date of this Amendment. The accrued benefit and vesting
percentage of each Participant who is an Employee on the effective date of this
Amendment shall be no less than before the Amendment.
3. Section E2 of the Adoption Agreement titled "FORMULA FOR DETERMINING
EMPLOYER'S CONTRIBUTION", subsection "FOR ANON-INTEGRATED
PLAN" is hereby deleted and replaced as follows:
"FOR ANON-INTEGRATED PLAN
• Class One: The amount equal to 100% of the maximum 4571imit of the
current plan year.
• Class Two: Suspended.
• Class Three: Suspended.
• Class Four: The amount equal to 200% of the maximum 4571imit for the
current plan year.
• Class Five: 5% of the Participant's Compensation.
4. Section ES of the Adoption Agreement titled "PARTICIPATING EMPLOYEES'
MANDATORY EMPLOYEE CONTRIBUTIONS" is hereby deleted and
replaced as follows:
"PARTICIPATING EMPLOYEES' MANDATORY EMPLOYEE
CONTRIBUTIONS
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Class One and Class Four: Subsequent to their Entry Date and on an annual
basis, an eligible Employee shall contribute to the Plan the amount of their
Compensation equal to 100% of the maximum 4571imit of the current plan
year, but when added to the Employer's contribution, shall not exceed the
maximum 4151imit
Class Two and Three: Subsequent to their Entry Date and on an annual basis,
an eligible Employee shall contribute 0% of their Compensation to the Plan.
• Class Five: Subsequent to their Entry Date and on an annual basis, an eligible
Employee shall contribute 5% of their Compensation to the Plan.
In addition to the above contribution, upon an eligible Employee's termination of
employment, if there is accumulated vacation pay due to that Employee,
Employer shall contribute that accumulated vacation pay into the Plan, rather than
paying it directly to the Employee. An "eligible Employee" is defined as a
permanent employee who is actively participating in the 401(a) Plan. This
contribution shall not exceed the 415 limit when combined with all other
contributions from the 401(a) Plan.
Note: The Mandatory Contribution shall be considered "picked up" by the
Employer under Sections 414(h) of the Code. All Eligible Employees are
required to make a Mandatory Contribution as a condition of employment."
In Witness Whereof, the Employer, Trustee and Administrator hereby cause this
Amendment to be executed.
CITY OF CHULA VISTA NATIONWIDE RETIREMENT
SOLUTIONS (NRS)
Cheryl Cox
Mayor
Date:
Attest:
City Clerk
TRUSTEE
Maria Kachadoorian
Date:
Printed Name
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Approved as to Form:
City Attorney
3-15
RESOLUTION NO. 2011-
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
ADMINISTRATIVE SERVICES AGREEMENT WITH ICMA
RETIREMENT CORPORATION TO INCLUDE
ADMINISTRATIVE ALLOWANCE PROVISION
WHEREAS, ICMA Retirement Corporation (ICMA) has been a plan administrator for
the City's Deferred Compensation Plan since 1986; and
WHEREAS, at that time, the contract with ICMA was established with an initial term of
five years with an automatic renewal for each succeeding year, unless there was a 60-day written
notice provided by either party; and
WHEREAS, the original Plan Administration Fee was set at 0.90% of the plan assets and
over the years was reduced to 0.29% due to the increasing size of the City's plan assets; and
WHEREAS, in November 2004, City Council approved the establishment of a five-year
fixed term agreement with automatic renewals for two succeeding years in exchange fora 0.00%
Plan Administrative Fee, thus yielding higher returns to employees participating in the plan; and
WHEREAS, this agreement is set to expire next month; and
WHEREAS, staff is recommending approval of the proposed amendment to establish a
new five-year fixed term agreement, with an automatic renewal for each succeeding year, which
will keep the Plan Administrative Fee at 0% and will include an annual administrative allowance
of $8,200 payable quarterly to the City; and
WHEREAS, administrative allowance is a flat amount that will not change with the value
of the plan's assets; and
WHEREAS, under ERISA requirements, these funds can only be used to reimburse the
City for staff time and other costs incurred to administer the deferred compensation plan; and
WHEREAS, the payment would be paid to the City on a quarterly basis starting in
January 2012 and would have no negative impact on the plan participants.
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Resolution No.
Page 2
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Chula Vista
does hereby approve the Amendment to the Administrative Services Agreement with ICMA
Retirement Corporation to include an administrative allowance provision, a copy of which is on
file in the Office of the City Clerk.
Presented by
Maria Kachadoorian
Director of Finance/Treasurer
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RESOLUTION NO.2011-
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
DEFERRED COMPENSATION PLAN ADMINISTRATIVE
AGREEMENT WITH NATIONWIDE RETIREMENT
SOLUTIONS, INC. TO PROVIDE FOR ADMINISTRATIVE
EXPENSE REIMBURSEMENT
WHEREAS, the City has offered a Deferred Compensation Plan through Great Western
Savings (now known as Nationwide Retirement Solutions, Inc.) to employees since 1975; and
WHEREAS, staff is recommending that the City amend the Nationwide Deferred
Compensation Plan Agreement to include an administrative expense reimbursement; and
WHEREAS, annually, Nationwide would pay the City 0.004% of the value of the plan
assets, to reimburse the City for its expenses and costs incurred in administering the plan; and
WHEREAS, the reimbursement would fluctuate as plan assets increase or decrease in
value; and
WHEREAS, these funds would have use restrictions, and would have no negative impact
to the plan participants; and
WHEREAS, Nationwide does not require afive-year fixed term agreement.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Chula Vista
does hereby approve the Amendment to the Deferred Compensation Plan Administrative Services
Agreement with Nationwide Retirement Solutions, Inc. to include an administrative expense
reimbursement provision, a copy of which is on file in the Office of the City Clerk.
Presented by
Maria Kachadoorian
Director of Finance/Treasurer
Ap roved as to form by
~ Gfe' R. Goo'ins
City Attorney
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RESOLUTION NO. 2011-
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA APPROVING AN AMENDMENT TO THE
NATIONWIDE RETIREMENT SOLUTIONS, INC.
GOVERNMENTAL MONEY PURCHASE PLAN AND TRUST
(401(A) PLAN REVISING SECTIONS E2 AND ES AND
ADDING A FINAL PAY PROVISION
WHEREAS, Staff is recommending that the City's Governmental Money Purchase Plan
(401(a) Plan) be amended to include a final pay provision for all eligible employees who are
actively participating in the Plan; and
WHEREAS, the proposed provision requires that, for any employee who is actively
participating in the 401(a) Plan when the employee separates from employment with the City, the
City shall contribute the employee's accrued vacation payout to the 401(a) Plan; and
WHEREAS, for those employees to which the proposed final pay provision would apply,
the provision would mean that the employees' accumulated vacation pay would be paid into a
tax-deferred program, rather than paid directly to the employees; and
WHEREAS, the it is not anticipated that the City would incur any costs as a result of the
proposed final pay provision and, in fact, there may be a slight savings because the 1.45% FICA
tax would not be paid on the funds deposited into the 401(a) Plan; and
WHEREAS, staff is also recommending that Sections E2 and ES of the 401(a) Plan be
amended to accurately reflect the current status of the plan contributions.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Chula Vista
does hereby approves the Amendment to the Nationwide Retirement Solutions, Inc.
Governmental Money Purchase Plan and Trust (401(a) Plan), a copy of which is on file in the
Office of the City Clerk.
Presented by
Maria Kachadoorian
Director of Finance/Treasurer
Approved as to form by
1 Q,~~~
~ ~Gle .~ e g~ns
-~C1C Attorney
3-19