Table of Contents
PROGRAM FEATURES .................................................................................................................................. 2
Eligibility ........................................................................................................................................................... 2
Contributions.................................................................................................................................................... 6
Vesting ........................................................................................................................................................... 10
ADMINISTRATION ........................................................................................................................................ 12
Remittance..................................................................................................................................................... 12
Data File Submission ..................................................................................................................................... 14
Enrollment...................................................................................................................................................... 16
Escrow ........................................................................................................................................................... 21
Loans ............................................................................................................................................................. 22
Taxes ............................................................................................................................................................. 23
Additional Points ............................................................................................................................................ 26
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1
PROGRAM FEATURES
Eligibility
Category
Question
Answer
Eligibility
What is a newly
eligible employee?
An employee hired July 1, 2013 or later, who will earn at the salary rate* of
at least $75,000 and is unrepresented (not associated with a union), and
whose immediately preceding employment was not with another state
agency/employer.
Definition
*Salary rate will be considered in reaching the $75,000 threshold. For
example, if a part-time employee makes $45,000 working 60% of a
full-time schedule, then the salary rate would be $75,000, and would
qualify the employee to enroll in the VDC.
Eligibility
Determination
Who determines
eligibility?
The employer/agency determines eligibility (including vesting) based on
the rules of the plan and the information provided by the employee in
Retirement Plan History (entered into the Retirement Plan Election
Will TIAA-CREF establish
System by the employee).
what documents/proofs
are needed for an eligible NOTE: If an employee is unable to utilize the Retirement Plan Election
employee
System for any reason, please contact Retirement@Work by calling
to establish that they
866 271-0960 for assistance.
participated
in an agency/employer
retirement plan through
prior employers?
Is an ERS member from
a local municipality who
Defined Benefit
transfers to a state
Participant
agency/employer eligible
Moves to a NYS
to join the VDC?
agency/
employer
Eligibility
Yes, as long as the immediate prior employment was not with a
“state agency,” the employee is able to join (assuming they
meet requirements).
If an employee goes from one state agency to another state agency and
is enrolled in or a member of any defined benefit program, they are not
eligible for VDC.
If they move from one non-state, local municipality to another, they are
eligible to enroll in the VDC.
If an employee was in the
defined benefit plan at one
Switching Jobs
organization and then
starts a new job in a
different organization, can
they switch to the
VDC Program?
Eligibility
Yes, as long as the employee switch is not moving from one state
agency to another state agency, the employee is able to join the VDC
Program (assuming they meet the eligibility requirements).
If an employee goes from one state agency to another state agency and
is in any defined benefit plan, they are not eligible for VDC. If they move
from a non-state to non-state, they are eligible.
2
Eligibility
Temporary
Employee
Hired before
July 1, 2013
Will temporary employees No. They will not be eligible to participate. NYS Legislation defines
hired before July 1, 2013, eligibility as hired ON or AFTER July 1, 2013.
and who chose not to
participate in ERS be
qualified to participate in
the VDC on or after July
1, 2013?
What if they move from a
temporary to a permanent
position on or after July 1,
2013?
What about employees
who move from an
Move from
unrepresented to a
Unrepresented
represented position one
to Represented
or more times?
Position
Eligibility
Will a current Tier 6
employee hired prior to
Existing
July 1, 2013, whose
Employee Prior
salary is greater than
to
$75,000 be allowed to
July 1, 2013
participate in VDC?
Eligibility
Once the employer/
agency approves the
Next Step After
employee’s participation
Approval
in the NYS VDC
Program, what’s next?
Eligibility
They will not be eligible. Moving from a part-time to a full-time position
does not change the original hire date.
Represented = Covered by a union.
Non-represented = Not covered by a union.
If an employee is in an unrepresented position and in the VDC, then
moves to a represented position, the employee would be allowed to
remain in VDC (because the employee had elected to be in that plan).
Once in the program, the employee can’t be forced out of the program.
An employee cannot change plans during employment.
No.
Only employees hired on or after July 1, 2013, who have a subsequent
qualifying status change would be eligible to switch to the VDC.
The employee must have a qualifying change (e.g., moving from one
ineligible position to an eligible position and hired on or after 7/1/2013)
and they have a one-time opportunity to change plans within 30 days
of qualifying change.
If an employee is vested, his/her contributions must be submitted on the
Census Remittance File as soon as administratively feasible. If there is
any delay, both employer and employee contributions should be
recordkept by the employer/agency until they can be added to the
Census Remittance file and then remit all retroactive contributions.
Contributions for employees who have not met the 366-day vesting
period should be recordkept in a separate account. Required employer
contributions and employee salary reduction must begin and be held by
the employer in escrow. The employer must also begin to accrue the
8% employer contribution amount.
For state agencies whose payroll is administered by OSC, please see
Payroll Bulletin 1256.
Eligibility
Qualifying
Employment
Change
If an employee has a
qualifying change (e.g.,
moving from an
ineligible position to an
unrepresented one
earning at the annual
rate of at least $75,000),
will the employee have
a one-time opportunity
to change?
Yes, if hired on or after July 1, 2013.
The legislation is intended to cover employees newly hired on or after
July 1, 2013. So, an existing employee hired prior to July 1, 2013, is not
eligible unless he or she has a qualifying change (i.e., leave employment
and return to public employment under qualifying circumstances on or after
7/1/2013). Otherwise, the employee must maintain membership with their
current retirement program with no option to switch.
Non-represented = Not covered by a union.
3
Eligibility
Salary
Decreases
If an employee
was part of VDC,
(because his/her salary
rate was greater than
$75,000) but later has a
salary decrease to below
$75,000, can he/she still
be in VDC?
Once you’ve established membership in the VDC Program, you retain
membership in the VDC.
Contribution Table:
$45,000 or less = 3%
$45,000.01 to $55,000 = 3.5%
$55,000.01 to $75,000 = 4.5%
$75,000.01 to $100,000 = 5.75%
Greater than $100,000 = 6%
*While eligibility determination is based on salary rate (see page two),
contribution rate is based on actual wages.
All amounts are subject to the 415 limit set by law each year.
For additional information, please visit vdc.ny.gov.
Please refer to the SUNY Salary Bulletin; regarding Tier 6 Employer
Contribution Rate & Look Back section located at
https://www.tiaa-cref.org/public/pdf/SUNY_Bulletin_January_2015.pdf.
Eligibility
30-Day
Requirement
Eligibility
Current Tier 6
Eligibility
Rehired with
No Retirement
Plan History
If it is optional for an
employee to join either
NY State sponsored
retirement plan or the
VDC (i.e., due to
part-time/ temporary
employment) and the
employee chooses not to
join either plan, but is
mandated to join a
retirement plan at a later
time (i.e., after switching
to full-time/permanent
employment), can the
employee still enroll in
the VDC?
Anyone hired
after July 1, 2013, can
participate in VDC, but
what about the other Tier
6 employees hired
previously? Aren’t they
allowed to participate in
the program?
For an employee hired
before July 1, 2013, and
who was not required to
join a Retirement System,
but then separated and
was rehired after
July 1, 2013, is he/she
eligible to participate in
the VDC?
Yes, as long as the election is made within 30 days of the appointment
in which enrolling in a retirement system becomes mandatory.
The 30-day enrollment requirement applies to part-time/temporary and
full-time employees.
Legislation dictates specifically that the VDC is only available to
employees that are newly hired on/after July 1, 2013. An existing
employee is not eligible unless he/she has a qualifying change (i.e.,
leave employment and return to public employment under qualifying
circumstances). Otherwise, the employee must maintain their
membership with the defined benefit retirement plan that they are
currently enrolled in.
If an employee was hired by a public agency before July 1, 2013, and
separated from service, and then returned to an eligible position—as long
as his/her immediate preceding employment was not with the same
agency/employer and he/she had not elected a retirement plan—he/she
is eligible for enrollment in the VDC assuming he/she meets all other
eligibility requirements.
4
Is a retiree from NYC
Pension System (like a
Retired Rehired
retired NYC Police
Officer) who comes to
work for the State in a
VDC-eligible position
eligible to participate in
the program?
Eligibility
Eligibility
Mandatory
Contributions
Eligibility
Transfers
between NY
State Entities
Can an employee enroll
in the VDC and a 457,
403(b) or 401(k) plan at
the same time?
If an employee is actively receiving a public pension benefit, he/she is
not eligible for the VDC Program unless he/she elects to suspend that
previous public benefit and otherwise meet eligibility requirements and
had not previously been offered the VDC as a retirement plan option
(i.e., through NYS employment prior to retirement while concurrently
employed by NYPD). Example: A retiree is collecting a pension from
TRS/ERS is rehired. He/she is not eligible for the VDC Program unless
he/she elects to suspend that previous public retirement benefit and
otherwise meets eligibility requirements, and had not previously been
offered the VDC Program as a retirement plan option (i.e., through NYS
employment prior to retirement.
Yes. The VDC Program is a pension plan and an employee can enroll in
the VDC as well as a voluntary tax deferred program such as a 457,
401k, 403b, etc. Also, because employee contributions to the VDC
Program are mandatory, they do not offset the 402(g) limits.
Does a person moving
A person moving from one NY State agency to another NY State
from one New York State agency that is currently enrolled in a state/city sponsored Retirement
Authority to another State Plan does not qualify to enroll in the VDC Program.
Authority qualify to enroll
in the VDC Program?
Scenario: Are they eligible for VDC Program?
1. Moving from one NY Authority
(non-state agency) to another
NY Authority
Yes
2. If a person is moving between NY
Authority and a NY State Agency
Yes
3. If a person is moving from one state
agency to another state agency
No, unless they were already
participating in the VDC with their
previous employer.
5
Contributions
Category
Question
Answer
Contributions
Are employers/
agencies responsible
for tracking the
employee and
employer contributions,
or will the Office of the
State Comptroller
do this?
If you have a centralized payroll administrator, the census remittance file,
including indicative data, contribution amounts, management of the escrow
contributions and funding, will be managed by that service provider.
Tracking
Contributions
Impact of
Family
Medical Leave
of Absence
(FMLA)
What happens if the
employee comes off
payroll, i.e., FMLA?
Would they have to
make catch-up
contributions?
NOTE: Centralized Payroll Administrators will calculate contributions for
vested and non-vested employees enrolled in the VDC Program and remit
vested contributions. If your payroll is not administered by a centralized
payroll administrator, you will calculate contributions and recordkeep escrow
contributions of non-vested employees.
FMLA is a non-paid benefit; meaning that there are no contributions
(employee or employer) during the period when an employee is not on
payroll. It is important to note that vesting credit will not be accumulated
while on unpaid leave or when an employee is not on an employer's payroll.
Generally, no contributions would be made for a period during which an
employee is on leave, with the exception of military leave. Employees who
return to work and become active on their employer's payroll will be
permitted to resume making contributions upon their return within applicable
timelines and guidelines.
If an employee is not being paid or active on the employer's payroll, you will
not accrue time toward the 366-day vesting requirement.
EXCEPTION: Employees on Disability
6
Contributions
Rates
What are the
contribution rates
for employees
participating in the
NYS VDC Program?
Employer contribution is 8% of annual wages and the employee
contributions are based on salary in accordance with the
following schedule:*
$45,000 or less = 3%
$45,000.01 to $55,000 = 3.5%
$55,000.01 to $75,000 = 4.5%
$75,000.01 to $100,000 = 5.75%
Greater than $100,000 = 6%
NOTE: These employee contributions are based on the rate of pay. For
example, if an employee was hired at a salary rate of $75,000, but works
part-time and actually earned $45,000, they would still be eligible to
participate. However, the employee contribution would be less than 4.5% as
noted above.
*While eligibility determination is based on salary rate (see page two),
contribution rate is based on actual wages.
Please refer to the section called "You must use a two-year look back
salary” for the calculation that can be found on the VDC website in the
Salary Summary Guide or at
www.tiaa-cref.org/public/pdf/VDC_Salary_Summary_Guide_FINAL.pdf.
All amounts are subject to the 415 limit set by law each year.
For additional information, please visit vdc.ny.gov.
Contributions
Impact on
other Plans
Contribution
Rates
Does the contribution
to the VDC Program
affect the employee's
ability to contribute to
a 457, 403(b) or
401(k) plan?
No. Employees can participate in the VDC Program and are encouraged to
save additional funds for retirement in their 457b, 403(b) or 40l(k) plan.
Additionally, because the employee contributions to the VDC Program are
mandatory (under 414(h)), they do not offset the maximum amount the
employee can tax defer to their employer's 457b, 403(b) or 401(k) plan.
Is there a cap on the
employee contribution
percentage? Can the
employee contribute
more than the
percentage required?
The cap on the employee contribution percentage is 6% for employees at an
annual wage of over $100,000.00. The employee is not permitted to
contribute more than the percentage that is based on their salary. Additional
employee contribution can be made into the voluntary tax deferred saving
program such as a 457b, 403(b) or 401(k), up to the tax deferral limit under
402(g) and 415.
7
Contributions
Taxation
Are these
contributions
through payroll
deductions taxable?
Employee mandatory contributions are pretax, deducted from the employee’s
gross includable salary (annual salary plus pensionable factors [such as
location/stipends], excluding non-pensionable items (uniform allowance,
etc.). These contributions will be reported in the employee’s W-2 as a
separate item. The employee must include this amount on their NYS
Tax Return IT201.
Please refer to the
salary summary guide
and employer
NOTE ON DISTRIBUTIONS: Distributions will not be subject to New
resources located on York State taxation.
vdc.ny.gov/employer.
New York State tax law allows an annual state income tax exemption for
employees who are members of New York State public retirement plans. The
VDC Program is a NYS public retirement plan and the income paid from this
plan to New York State or city employees who reside in New York is exempt
from New York state taxes.
In order to claim this tax exemption, employees who receive income from the
VDC Program must be able to itemize the amounts received from SUNY,
differentiated from any other plan from which they may be receiving income.
We cannot offer tax or legal advice. Employees must seek the advice of their
own tax, legal or finance counsel.
Contributions
Salary Base
Contributions
Employer/
agency
Employer/
agency
Contribution
Management
Contributions
Interest on
Contributions
Are the employee
contributions
calculated on gross
minus the nontaxable
deductions, or on the
full gross amount?
Employee contributions are calculated based on employee’s gross includable
salary (annual salary plus pensionable factors [location/stipends], excluding
non-pensionable items (uniform allowance, etc. are excluded). Please refer
to salary summary located at vdc.ny.gov.
What is the
employer's cost of
contribution?
The employer/agency contributes 8%.
How often does the
employer/agency
submit the 8%
contribution? Are we
billed or do we
calculate ourselves?
Employer and employee contributions for vested employees are remitted to
the third-party program administrator (TIAA-CREF) on a payroll schedule
provided to TIAA-CREF by the employer/agency.
Does the 4%
interest accrue to
both the employer and
employee contribution?
Yes. The 4% interest accrues on both the employer and employee
contributions for the 366-day vesting period. It is calculated as 4% simple
interest at the end of the 366-day vesting period and remitted to
TIAA-CREF along with the retroactive employer and employee premiums
plus the first employer and employee premiums. The interest rate, in addition
to the simple interest formula is dictated in Education Law Article 8B section
392. If the employee terminates service prior to vesting (e.g. after six
months), the escrowed employee contribution plus 4% simple interest up to
the point of termination should be refunded to the employee. They are not
owed employer premiums or interest on the employer premiums. Please
visit the VDC website at vdc.ny.gov/employer.
Simple interest is paid on contributions at the completion of the 366-day
vesting period.
8
Contributions
414(h)
contributions
Contributions
Refund of
Employee
Contributions
During the vesting
period, are employee
contributions treated as
414(h) contributions?
Yes. During the vesting period, the employee contributions are treated as
414(h) contributions in the same manner as they would during the vesting
period for the Defined Benefit ERS, TRS, etc. plans. The treatment is the
same during and after vesting and the total employee contributions are
recordkept together at TIAA-CREF as remitted under 414(h). This is
important to note during employee tax filings.
If the employee does
not complete the
vesting period, how
are the contributions
handled after
they leave?
The contributions should not be remitted to TIAA-CREF as an
employee who has terminated or separated from employment before
meeting the vesting period is not considered to be a plan participant.
The refund to the employee will include only the employee contributions
along with 4% simple interest up to the date of termination. The Employee
unvested pretax contributions should be refunded to the employee
and returned on their final separation check (along with simple
interest), so that it may be reported correctly on their wage and tax
statement at year-end.
– The refunded EE contributions would be reported as gross income on the
W2 and the 4% interest would be reported on a 1099INT.
Keep in mind that this is a 414h(2) plan and is treated similar to the ERS DB
plan in regards to tax reporting, if you would like additional tax reporting
advice on how to report the contributions/distributions we advise you to
consult with your legal department and/or internal tax advisor.
Contributions
VDC Refund
Application
How should an
employee request a
contribution refund?
Refunds can be requested by the employee completing the APPLICATION
FOR REFUND OF VOLUNTARY DEFINED CONTRIBUTION PROGRAM
found on the VDC website, which must be notarized, and returned to the
employing institution. A refund will be made only after the employee has
been off the payroll for two full payroll periods. – The refunded employee
contributions would be reported on the W-2 and the 4% interest would be
reported on a 1099INT. The link to the Refund Application Form is
https://www.tiaa-cref.org/public/pdf/VDCRefundApp.pdf.
9
Vesting
Category
Question
Answer
Vesting
How will the employer/
agency know if an
employee has already
met the vesting period
from a previous
employer (public
or private)?
Employees are required to complete the Retirement Plan Election (RPE)
form as part of the enrollment process. The RPE will ask the employee to
provide prior plan participation in a specific retirement system and with
specific plan providers. The Employer's/Agency’s Benefits Administrators
should track each EE’s Plan Entry Date provided so the 366-day period can
be appropriately calculated. If the employee notes he or she has an existing
contract with one of the investment providers under the VDC Program, you
will contact that investment provider. In addition, the employee may provide
a statement from the approved investment provider that should show vesting
percentage equal to 100%.
Validation
When the employees enroll, they’ll be asked a series of questions, e.g.:
1. Have you ever worked for a public employer in New York?
Note: If transferring from another NYS public employer with past
ERS/TRS history, this service can be counted toward the 366-day
vesting period.
2. Are you presently receiving a retirement benefit from any public
Retirement System of New York State?
3. Do you currently own a vested employer-sponsored retirement contract
with: TIAA-CREF, Voya, MetLife, VALIC or Fidelity?
You will use the responses to these questions to validate the employee’s
eligibility and vesting.
Vesting
Verification
How can we be
expected to validate
what a new staff
member presents
as their history for
verifying vesting?
Employees will provide their employee history when they elect to join the
VDC Program.
If the employee indicates participation in any of the public pension plans
offered in New York State, you will contact the retirement plan to confirm
their membership status.
State agencies can contact their payroll processors (e.g., the Office of the
State Comptroller for New York State or the Office of Labor Relations for
New York City).
If the employee notes he or she has an existing contract with one of the
investment providers under the VDC Program, you will contact that
investment provider to verify contract information provided by the employee.
Alternately, the employee may provide a statement from the approved
investment provider that should show vesting percentage equal to 100%.
Visit vdc.ny.gov website for contact information of each investment provider.
10
Vesting
Date
Vesting
Vested
Employee
Contributions
Vesting
Nonvested
Employee
Contributions
Is the vesting date
based on the date the
employee applied
for enrollment?
The vesting date for full-time employees is based on hire date, not
election date.
Where are employee
contributions located
once the first year of
vesting is achieved?
Employee/employer contributions are held in escrow (a segregated
account) by the employer until the employee becomes vested, upon
achieving 366 days participation in the program.
If the employee does
not complete the
vesting period, is the
employer/agency
required to refund
the employee
contributions directly
to the employee?
No two circumstances will be identical. NO, an employer/agency is not
required to refund employee contributions. The employee has the option to
leave their funds in escrow if the employer approves.
Employee contributions should not be remitted to TIAA-CREF, since an
employee who has terminated before meeting the vesting period is not
considered to be a plan participant.
Refunds requested by an employee will include only the employee
contributions along with 4% simple interest up to the date of termination.
The Employee unvested pretax contributions should be refunded to the
employee and returned on their final separation check (along with simple
interest), so that it may be reported correctly on their wage and tax
statement at year-end. – The refunded EE contributions would be reported
on the W-2 and the 4% interest would be reported on a 1099INT.
If the employee does not complete the vesting period, the employer/agency
will refund (if requested by the employee and approved by the
employer) the employee contributions directly to the employee plus 4%
simple interest.
How does vesting
affect the funds that
have been
During the
accumulated during
Escrow Phase
the escrow phase?
Vesting
Prior to vesting, employee/employer contributions are held in escrow by the
employer until the employee becomes vested, upon achieving 366 days.
Upon becoming vested, funds are then transmitted (plus 4% simple interest)
to the investment provider(s).
11
ADMINISTRATION
Remittance
Category
Question
Answer
Remittance
The Payroll
Administrator for my
institution is centralized
(Office of the State
Comptroller (OSC),
Office of Payroll
Administration (OPA)
or the Office of Labor
relations (OLR)).
No.
Census
Remittance
File
Requirement
Do I have to submit a
file for my institution?
Your Payroll Administrator will submit the Census Remittance File (indicative
data and contribution information file).
If you work with the OSC, refer to Payroll Bulletin 1256.
REMINDER:
Once the employer/agency approves the employee’s plan election, the
employer/agency must ensure that the employee is added to the Census
Remittance File. Each employer is responsible for coordinating this action
step with their centralized payroll administrator, third-party service providers,
or within your own institution when payroll is administered within the
institution.
If an employee is vested, his/her contributions must be submitted on the
Census Remittance File as soon as administratively feasible. If there is any
delay, both employer and employee contributions should be recordkept by
the employer/agency until they can be added to the Census Remittance File
then retroactively remit all appropriate contributions.
Contributions for employees who must meet the 366-day vesting period
should be recordkept in a separate account.
Remittance
Timing of the
Census
Remittance
File
Can the Census
Remittance File
be submitted less
than three days before
a payroll date?
The standard and recommended time frame is three days in order to have the
best processing experience and time to review the files.
Day 1 – Employer/agency submits the Census Remittance File. If the data is
received and is deemed to be in good order, it will be disbursed to the
investment providers. Otherwise, the employer/agency will receive notification
that the file cannot be processed. If the data is received after 4 p.m. (ET), it will
be processed and disbursed to providers the following business day.
NOTE: Adjustments received after the data has been disbursed will be
processed with the next remittance file cycle.
Day 2 – Employer/agency will receive a Funding Request and/or Confirmation
of Good Order.
Day 3 – Employer/agency will remit funding as applicable to each investment
provider. For agencies remitting funding to the third-party administrator
(TIAA-CREF), the funds must be received before 12 p.m. (ET).
The trade date for the contributions will be determined by the good order
assessment of each investment provider.
12
Remittance
Compliance
Are contributions to
NYS VDC subject to
limits monitoring?
Yes, depending on the characterization of the contributions and the IRC Code.
Employee mandatory contributions to the NYS VDC Program are not
considered to be elective deferrals and are not subject to 402(g) limits.
Employer contributions to the NYS VDC Program are not subject to the
Governor’s Cap. Employer contributions to the NYS VDC Program are subject
to the 401(a)(17) limit on compensation that may be counted for benefits under
the plan.
All contributions are subject to the IRC Section 415 annual limit. For 2015,
the 415(c) limit is 100% of compensation or $53,000 (index), whichever is
less. All contributions and forfeiture allocations are included in the limit.
Whether your payroll is administered by a centralized payroll administrator or
directly by your agency, limits monitoring is the role and responsibility of the
employer. You should work with the centralized payroll administrator and
TIAA-CREF, the Program recordkeeper, as needed.
Remittance
Remitting
Contributions
Remittance
Remittance
for Vested
Employee
Contributions
Is the 8% contribution
monthly or can we
remit at the end of
the year?
Contributions should be made based on an employer’s payroll schedule.
Should I include both Yes.
the employee and
Employer and employee contributions that are associated with an employee
employer contributions
that has not vested are held in escrow (a separate account) and recordkept
of a vested employee?
by the employer until the vesting period has been completed.
The employer and employee contributions and interest on those
contributions (simple interest calculated at 4%) are remitted in the pay cycle
following employee vesting.
13
Data File Submission
Category
Question
Answer
Data
Administration
What file format
should be
used?
The SPARK Census Remittance (CR) File must be used for any institution with
more than 250 plan participants.
File Format
If you anticipate that your eligible population will be 50 or more within
the next two to five years, you must submit your data using the SPARK
CR Format.
For employers/agencies whose number of plan participants will not exceed 250 within
the next two to five years, you may use the PlanFocus Online Contribution List.
Data
Administration
File Format
Data
Administration
Reporting
Can we choose Yes.
to use the
SPARK Census
Remittance File
format even if
we have less
than 250
enrollees?
Should I include
employees who
do not meet the
366-day vesting
requirement on
the data
administration
file when they
elect to
participate
in the
VDC Program?
No.
The employer/agency must recordkeep the escrow contributions on a per-pay
period basis. Once the employee vests, you must add the employee to your
remittance file and report the escrowed employer and employee contributions
(including the 4% simple interest and the first contribution).
If your payroll is performed by a central payroll administration, please contact them
regarding this function (see OSC payroll bulletin No. 1256 at
http://www.osc.state.ny.us/agencies/pbull/agencies/2013_2014/bulet1256.htm).
Example:
Employee must meet the 366-day vesting period if hired on August 1, 2013.
Vesting Date: August 1, 2014.
Date Added to Data Administration file: Not before August 1, 2014.
My institution
has other plans
with TIAA-CREF;
can we use the
Consolidating same file to
report
Files
participation
in the
VDC Program?
Data
Administration
No.
If your Centralized Payroll Administrator (e.g., OSC or OLR/OPA) currently submits
a data file to TIAA-CREF for other plans, TIAA-CREF will work directly with the
Centralized Payroll Administrator to determine if that file meets format/layout
specifications. However, different Plans may have differing data elements and
layouts that may not support the VDC Program requirements.
14
Continued Consolidating
Files
If your payroll is not administered by a Centralized Payroll Administrator and
your institution participates in other TIAA-CREF plans, TIAA-CREF will work
with you to establish a separate file in support of remittances specifically for the
VDC Program.
If you are using the SPARK Census Remittance Format, you must create
a new file for the NYS VDC Program. The NYS VDC Program has a
different Plan number and follows a different naming convention.
If you are not using the SPARK Census Remittance Format and the participation in
the NYS VDC Program will exceed 250 participants in the next two to five years,
you must implement the SPARK CR Format. Otherwise, you have the option to
submit your data using the remittance module within PlanFocus, the Online
Contribution List (OCL). TIAA-CREF will work with you to establish the proper
protocols that will enable you to establish remittance files using the SPARK file
process. Larger institutions may benefit by using the SPARK format even if they
have less than 250 participants.
Data
Administration
Submitting
Your File
Data
Administration
Distributions
When do I
submit
my file?
Each employer/agency or payroll administrator will submit a schedule to
TIAA-CREF, the third-party administrator based on your payroll schedule and the
three-business-day Common Remitter Cycle.
What is the
difference
between a
payroll date and
a check date?
The data is submitted three days prior to your pay period ending date or your
check date.
If an employee
terminates from
employment,
how are escrow
funds
disbursed?
If an employee terminates and has not met the vesting requirement, the employee
contributions plus 4% simple interest up to the point of termination only would be
refunded through a final pay check. The employee may elect to keep the
contributions in escrow with employer approval.
The date that you submit your file is based on the schedule that you provide to
TIAA-CREF, the third-party administrator.
Employer/agency contributions and corresponding interest are not included in
the refund.
For further information please consult with your legal counsel and/or tax advisor.
Administration
Distributions*
What are the
types of
distribution
options
available?
Distribution* options available, once vested, include:
Options available at separation of service:
• Single and joint life lifetime retirement income
• Single and/or systematic lump-sum withdrawals
• Minimum Distribution payments
• Interest payments
• Rollovers
Options available in-service:
• Loans
• Death Benefits
Distributions
At what age are
employees able
to take lump
sum or periodic
payments
(distributions)?
The VDC is designed to allow retirement at any age. Distributions from VDC
contracts are permitted any time after separation from services, subject to an IRS
10% penalty for distributions prior to age 59½, unless separating from service after
reaching the normal retirement age of 55.
15
Enrollment
Category
Question
Answer
Enrollment
What is the
enrollment process
for employees who
are not able to
access or utilize the
Retirement Plan
Election (RPE)
System?
If an employee is unable to access or utilize the Retirement Plan Election
System (RPE), you can take them through the process online or they should
contact TIAA-CREF Retirement@Work consultants by calling 866 271-0960
for guidance.
Will the employer/
agency enter
employees into the
Retirement Plan
Election System or
will the employees
enter themselves,
and we will
receive notification?
Employees must enroll online themselves through the RPE website located at
vdc.ny.gov.
Once the employee completes his/her election (including Retirement Plan
History), the employer/agency will receive a message to review a new item on
his/her work list in PlanFocus.
The employer/agency may contact TIAA-CREF to verify prior retirement plan
participation, for TIAA-CREF contracts. All other retirement plan contract/service
history verifications must be completed by the employer/agency with each
individual investment provider and/or state retirement plan.
IMPORTANT: The action to review is time sensitive because any delay in
approving the employee delays the downstream process to pass the
contributions to the recordkeeping system. The employer/agency approves or
declines the employee’s election. If the employee is not eligible, the
employer/agency must notify the employee.
An online report will identify who has completed the Retirement Plan
Election process.
Exception To
Online
Enrollment
Using
Retirement
Plan Election
(RPE) System
Enrollment
Retirement
Plan Election
(RPE)
For those employers/agencies beginning the onboarding process, your
employees will not have immediate access to the site until your institution's
onboarding is final. Manual forms will be provided in these situations.
For questions on enrolling into the plan, assistance on using Retirement@Work
or to complete the investment provider election, employees can contact the
TIAA-CREF Retirement@Work consultants at 866 271-0960.
16
Enrollment
Retirement
Plan Election
Will TIAA-CREF,
the plan recordkeeper,
inform the employer/
agency that the
employee has not
enrolled in/selected a
retirement plan
within 30 days of
his/her hire date?
No. The employer/agency must monitor retirement plan election. Access
Retirement Plan System through the TIAA-CREF Secure PlanFocus.
Each new hire must be provided with the How to Enroll Card, as well as an
additional reminder from the employer/agency to take action within 30 days
from his/her hire date; otherwise, the employee will default into the N.Y.S. or
N.Y.C. defined benefit plan (e.g. ERS, TRS, etc.).
IMPORTANT: The action to review "the Retirement Plan Election" is time
sensitive, as any delay in approving the employee delays the downstream
process and the employee’s first contribution.
NOTE: If the employee elects to participate in the VDC but does not
complete the enrollment with an investment provider, the employee will be
default enrolled to a provider as determined by the plan sponsor.
Enrollment
Retirement
Plan Election
(RPE)
Enrollment
Notifications
Will the election form
have an option to
decline VDC
participation?
Are notifications
sent from the site
to let us know
when someone
has completed
his/her elections in
the system, or do
we need to manually
check the site
for alerts?
Not at this time.
The election form (RPE) currently collects only affirmative participation in the
VDC only.
The answer is both.
Yes, email alerts are sent to you, but as Program administrator, you will
need to log on to the TIAA-CREF secure web center, PlanFocus
(www.tiaa-cref.org/public/plansponsors) and check for “alerts” in the For
Attention Section routinely regarding employee Retirement Plan Election
(RPE) submissions. These will show up in your work queue.
It’s a good habit to visit the secure Plan Focus Website routinely as
an administrator, but not less frequently than each payroll period.
17
What is the average
time frame between
Administration
when an employee
Enrollment –
enrolls online and the
Alert
administrator
receives notification?
Enrollment
Once an employee enrolls online, information is fed to the TIAA-CREF Plan
Focus website and will be available the next business day if it was input
during normal operating business hours. Concurrently, the employer/agency
will receive a notification to review the new item on his/her work list each day
that there is an action item to complete.
IMPORTANT: The action to review is time sensitive as any delay in approving
the employee participation can result in the first contribution being delayed.
Each new hire must choose his/her retirement plan within thirty (30) days of
his/her hire date. For any employee that is not mandatory, participation will
begin upon election. For further information, please consult with your
benefits administrator.
Enrollment
Alerts
Once the employer/
agency approves the
employee’s
participation in the
NYS VDC Program,
what’s next?
The employer/agency must ensure that the employee is added to the data
Census Remittance File.
The employer/agency is responsible for coordinating this action step with
centralized payroll administrators, third-party payroll agency administrators
such as the OSC or the OLR/OPA, or within their own institution when
payroll is administered in-house.
If an employee is vested, his/her contributions must be submitted on the
Census Remittance File as soon as administratively feasible. If there is any
delay, both employer and employee contributions should be recordkept by
the employer/agency until they can be added to the Census Remittance File
then retroactively remit all appropriate contributions.
Contributions for employees who have not met the 366-day vesting period
should be recordkept by the employer/agency in escrow.
For State Agencies whose payroll is administered by OSC, please refer to
Payroll Bulletin 1256 by pasting the following link into your web browser:
http://www.osc.state.ny.us/agencies/pbull/agencies/2011_2012/bulet11
56.htm.
Enrollment
Requirements
if No Hiring
My institution will not
be hiring for the
foreseeable future.
Is any action required
at this time?
The NYS VDC Program is effective for new hires as of July 1, 2013.
IMPORTANT: Yes, action is required. Please keep in mind that the
onboarding process takes time to establish an institution/employer/agency in
the program regardless of whether your institution's payroll is handled
internally, by a centralized administrator or a third-party payroll
administrator. We would advise you to complete the Administrator Access
form to at a minimum allow us to communicate with you about any VDC
Program changes. The form can be found on the administrator section of the
VDC website at vdc.ny.gov.
If your institution is eligible for the VDC Program, you are required by law to
immediately notify employees of their eligibility to participate in the
retirement plan options and also provide the employee with materials to
make an election within thirty (30) days of his/her hire date.
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Enrollment
Effective Date
Enrollment
Plan Election
Irrevocable
How is the effective
date determined if an
employee enrolls in
the VDC? Is it the
day he/she enrolls, or
is it retroactive back
to their hire date
since he/she has 30
days to enroll?
What are the
consequences of
an employee who
does not choose a
retirement plan within
30 days from his/her
date of hire?
It is retroactive back to the employee’s hire date for mandatory (full-time
employees) membership.
If he/she is an optional (part-time) member, then it’s done prospectively from
the date the application was received.
As of July 1, 2013, new hires who meet the eligibility criteria for the NYS
VDC Plan must by law be provided with information about this program and
the option to enroll in it. It is the employer's responsibility to give all eligible
employees information about the VDC Program upon hire so they may make
an informed decision about which plan to select. If the employee has not
been provided with VDC information upon hire, the employer must do so as
soon as possible and permit the employee to participate retroactively to their
original eligibility date.
The retirement plan choice is irrevocable during employment.
If the employee does not take action within 30 days, he/she will be DEFAULT
enrolled in one of the NY State or NYC defined benefit systems (e.g. ERS,
TRS, etc.), if in a position that requires retirement plan participation.
Can you help the new
Employee who
New Hire
cannot access the
Employee
Retirement Plan
cannot Access
Election System?
Retirement
@Work
Enrollment
Yes, we can help; however, the employer/agency must ensure that the
employee selects a retirement plan.
The employee can contact the Retirement@Work help line at
866 271-0960 to speak with a representative who can walk him/her through
the process of selecting the VDC Program as their retirement plan.
If the employee needs assistance enrolling in the VDC Program, a
Retirement@Work representative will provide that assistance. For
enrollment with an approved investment provider, a Retirement@Work
representative will introduce the employee to the investment provider
(TIAA-CREF, VOYA, VALIC, MetLife, Fidelity) or instruct the employee to
make direct contact.
NOTE: If you have an employee who is limited under ADA and
cannot use the automated system to select a retirement plan, they may
contact the Retirement R@W telephone center at 866 271-0960 to speak
with a representative we can complete the Retirement Program Election
Form on their behalf. To select a retirement plan, you may use the
Retirement Program Election Form and Investment Provider Election Form
that will be located on the Administrator Information Resource Center found
at vdc.ny.gov. An alternative for ADA employees only are paper forms that
are located on the Administrator Resource center found at vdc.ny.gov.
Paper forms cannot be used for non-ADA employees.
19
Enrollment
30 days
Enrollment
Withdrawal
How do we give an
employee a 30-day
election period
between VDC and the
default retirement
system? An employee
is paid on a weekly
basis and payroll
deductions are
started immediately.
Many agencies know they are going to hire an employee in advance, and
would send the materials to them prior to payroll. This allows the employee
to review the materials in advance in order that he/she may make an
informed decision in selecting a retirement plan.
Can the employee
withdraw from the
VDC Program?
No. While the employee is with their current employer, they cannot withdraw
from the VDC Program. However, if they terminate service with their current
employer, please refer to the question "switching jobs" located on page two
under eligibility.
If the employee doesn’t take action, the employer/agency is required to
enroll him/her in the Defined Benefit Plan (e.g. ERS, TRS, etc.), depending
on title.
Should an employee elect to enroll in the VDC Program, after the first payroll
cycle, the employer must process retroactive deductions. For full-time
employees, deductions should be retroactive to the first date of employment.
For part-time employees, deductions should be retroactive to the date of
program election.
20
Escrow
Category
Question
Answer
Escrow
What is an escrow
account and who
manages it?
Escrow is a separate account established for the purpose of holding funds
on behalf of the employees. The employee’s contributions are held in
escrow until the employee vests with the VDC Program (366 days after hire).
Definition
If your payroll is managed by a centralized payroll administrator (e.g., OSC
and or OLR/OPA), they will recordkeep the per pay period escrow employer
and employee contributions. Once the employee vests, the centralized
payroll administrator will remit the escrowed contributions and simple
interest on both the employer and employee contributions at the rate of 4%.
If your payroll is not administered by a centralized payroll, you must create an
escrow account. The employer/agency must recordkeep the employer and
employee contributions and apply the required interest at the time of vesting.
Please check with your Finance Dept. (CFO, Chief Accounting Officer).
They can help determine if there’s an existing escrow account to hold VDC
Program contributions. Essentially, you’re segregating these funds from
creditor accounts.
Escrow
How Many?
Is one escrow
account needed
for all employees
in the vesting wait
period or one per
each employee?
Can the employer/
agency earn interest
Interest earned
on the funds in the
escrow account?
Escrow
One per employer/agency, as long as the institution tracks the Escrow
balance per employee.
Your obligation is the 4% interest rate on employer and employee
contributions if the employee is required to go through the 366-day vesting
period. If an employee is immediately vested, contributions will be submitted
as soon as administratively feasible. If your funds are accruing greater than
4%, the excess earnings can simply benefit the overall escrow of the
employer/agency.
Please see your legal counsel and/or tax advisor for further information. For
more information, please copy and paste the following website into your
browser: https://www.tiaa-cref.org/public/pdf/Chapter-18_2012-PensionReform.pdf.
Escrow
Interest
Is the 4% interest in
escrow in addition to
the 8% Employer
contribution?
Yes. The employer contribution of 8% is in addition to the 4% escrow interest.
NOTE: For additional information refer to Education Law Article 8-B section
392 for guidance on crediting interest rate. For more information, please
copy and paste the following website into your browser: https://www.tiaacref.org/public/pdf/Chapter-18_2012-Pension-Reform.pdf.
21
Where do we get the
legislation information
on the 4% interest
rate on funds in the
escrow account?
This is noted in New York Education - Article 8-B - § 392 Rates
of Contribution For more information, please copy and paste the following
website into your web-browser: https://www.tiaa-cref.org/public/
pdf/Chapter-18_2012-Pension-Reform.pdf.
ESCROW
Interest
Legislation
An employee leaves
City/State service
prior to vesting in
VDC and withdraws
their contributions. A
year later they return
to City/State service.
Must they participate
in VDC or can they
elect to join the
pension system?
The VDC Program and ERS (plus the other Defined Benefit programs) are
both pension systems. The distinction is that VDC is a Defined Contribution
plan and ERS, TRS, etc. are Defined Benefit plans. The answer to your
question depends on their status upon re-hire. If your office is a city agency
and not a state agency/employer, employees who are newly hired or
employees that are re-hired after a break in service, would be eligible to join
the VDC as long as they are in an eligible group at hire (or re-hire). They can
be offered either the VDC or the ERS (or appropriate Defined Benefit pension
system). There are different rules for employees moving from one state
agency/employer immediately preceding another state agency/employer. This
does not impact city employees but is mentioned in the event you saw a
reference to it in the VDC legislation. For additional details, please refer to the
Eligibility section of this FAQ, page 2.
ESCROW
During the Escrow
process, what
happens if a person
receives a salary
increase before the
funds are remitted to
TIAA-CREF? Does
the increased
Employer
Contribution take
affect simultaneously
when the increase
occurs? Does it take
place in the same
fiscal year or will the
NYSERS process of
a two-year delay be
utilized?
During the Escrow process, if an employee’s salary is increased prior to
vesting and before remittance of funds, the employer/agency should make the
appropriate adjustments to the contribution amount that should be withheld
from the employee. The employer/agency will then place the original
withholding amount, plus the additional funds that correspond to the salary
increase, into the Escrow account.
Escrow
Interest
Legislation
Calculations
and Salary
Increases
Yes, the increased Employer Contribution should take place at the same time
the salary increase takes effect.
The increase in both Employee and Employer contributions should take place
at the same time as the salary increase. NO, the NYSERS two-year delay
process does NOT apply.
Reference: SUNY Payroll Bulletin:
https://www.tiaa-cref.org/public/pdf/SUNY_Bulletin_January_2015.pdf
22
Loans
Category
Question
Answer
Loans
Can employees take
loans from the VDC
Program?
Yes. Employees are allowed to take loans from the Program once they
become vested.
If employees can
take loans through
the VDC, are they
eligible during the
first 366 days?
Employees may NOT take loans during the 366-day escrow period. VDC
funds are available for loan once the vesting requirement has been satisfied.
Loan availability is subject to the provisions of the plan and IRS guidelines.
Employees may borrow up to 50% of the accumulated value of their contracts,
subject to Internal Revenue Service regulations and rules promulgated by the
investment providers. Current IRS regulations set a maximum aggregate loan
balance of $50,000. Employees who wish to request a loan should contact the
applicable investment provider(s). For additional information about the
program, please review the Summary Plan Description located on
vdc.ny.gov. https://www.tiaa-cref.org/public/pdf/Voluntary-DefinedContribution-Plan-SPD.pdf
23
Taxes
Category
Question
Answer
Taxes
Is the employer
contribution reported
on a W-2?
Because TIAA-CREF is not an institutional tax advisor, we cannot legally
advise you on employee tax reporting. However, normally, employer
contributions are not reported on a W-2 since there is no impact to the
employee’s tax status during the contribution stage. When the employee
takes distributions from the VDC, TIAA-CREF or the financial provider that
the employee selected, will issue a 1099 that reports the entire distribution
which includes employer and employee contributions plus earnings.
Are these
contributions
through payroll
deductions taxable?
Employee mandatory contributions are pretax, deducted from the
employee’s gross includable salary (annual salary plus pensionable
factors [location/stipends], excluding non-pensionable items (uniform
allowance, etc.). These contributions will be reported in the employee’s W-2
as a separate item. The employee must include this amount on his/her NYS
Tax Return.
Contribution
Reporting
Taxes
Contributions
NOTE ON DISTRIBUTIONS:
New York State tax law allows an annual state income tax exemption for
employees who are members of New York State public retirement plans. The
SUNY Optional Retirement Plans (ORPs) and the VDC Program are New
York State public retirement plans; therefore, income paid from these plans to
New York State or City employees who reside in New York are exempt from
New York State taxes.
In order to claim this tax exemption, clients who receive income from the
SUNY plan or the VDC Program must be able to itemize the amounts
received from SUNY VDC Program, differentiated from any other plan from
which they may be receiving income. We cannot offer tax or legal advice.
Employees must seek the advice of their own tax, legal and finance counsel.
Please refer to salary summary located on vdc.ny.gov/employer.
If an employee leaves Because TIAA-CREF is not an institutional tax advisor, we cannot legally
before vesting, does
advise you on employee tax reporting.
1099 Reporting the employer/agency
Please consult with your personal tax advisor.
issue a 1099R? If yes,
are the employee
contributions and
interest on the same
1099 or separate?
Taxes
24
Taxes
Handling of
nonvested
contributions
Taxes
1099R
reporting
If the employee does
not complete the
vesting period, what
is the process that
should be followed by
the agency/employer
and what are the tax
implications?
If an employee
leaves before
vesting, does the
employer/ agency
issue a 1099R? If
yes, are the
employee
contributions and
interest on the same
1099 or separate?
The contributions should not be remitted to TIAA-CREF as an
employee who has terminated before meeting the vesting period is not
considered to be a plan participant.
Refunds requested by an employee will include only the employee
contributions along with interest up to the date of termination. The
Employee unvested pretax contributions should be refunded to the
employee and returned on their final separation check (along with "4%"
simple interest), so that it may be reported correctly on their wage and tax
statement at year end. The refunded EE contributions would be reported on
the W-2 and the 4% interest would be reported on a 1099INT.
Because TIAA-CREF is not an institutional tax advisor, we cannot legally
advise you on employee tax reporting. That said, you would follow the same
process as followed when you return employee contributions to an employee
who terminated prior to vesting in the ERS plan. Note that the employee
would report the employee contribution on the IT 201 during annual filing.
Because the City of NY holds the VDC funds during the vesting period, and
ERS holds the funds during the vesting period for ERS participants, you may
wish to speak with an ERS representative to ask how they process the
refund. Other employer institutions that participate in the VDC confirmed to
us that they will be issuing a 1099 to return employee contributions to
employees who terminate prior to vesting. Please confirm with your payroll
or tax reporting advisor.
For employees for the city of NY, the NY City Office of Labor Relations holds
the VDC funds during the 366 days leading to vesting.
Taxes
W2 reporting
Is the employer
contribution reported
on a W-2?
Because TIAA-CREF is not an institutional tax advisor, we cannot legally
advise you on employer/agency tax reporting. That said, normally,
employer/agency contributions are not reported on a W-2 for a vested
employee since there is no impact to the employee’s tax status during the
contribution stage. When the employee takes distributions from the VDC,
TIAA-CREF, or the investment provider that the employee selected, will
issue a 1099 that reports the entire distribution, which includes employer
and employee contributions plus earnings.
25
Additional Points of Clarification
Category
Question
Answer
Retirement
Calculator
Is there a retirement
calculator that an
employee can use to
estimate retirement
income?
Yes, please copy the attached link into your computer’s web-browser.
https://www.tiaa-cref.org/public/calcs/retirementgoalevaluator
Calculator sourced from TIAA-CREF public website for Retirement Goal
Evaluator. The calculator is for illustration purposes only and should not be
relied upon to determine actual numbers. Please consult with your financial
and or tax advisor for calculations specific to your circumstances.
Plan Types
What is the difference Governmental plans under Internal Revenue Code Section 401(a): Under
between a 401(a)
Internal Revenue Code Section 414(d), a governmental plan is an IRC Section
401(a) retirement plan established and maintained for the employees of:
and 401(k) plan?
• the United States or its agency or instrumentality;
The United States or
• a state or political subdivision, or its agencies or instrumentalities
its agencies or
• an Indian tribal government or its subdivision, or its agencies or
subdivision, or its
instrumentalities (participants must substantially perform services
agencies or
essential to governmental functions rather than commercial activities.)
instrumentalities
Source: http://www.irs.gov/Retirement-Plans/Governmental-Plans-Under(participants must
Internal-Revenue-Code-Section-401-a
substantially perform
services essential to
People often refer to a 401(a) plan as an "employer only" contribution plan, i.e.,
governmental
the plan participants make no elective contributions. Usually when someone
functions rather than
says 401(a), they mean a profit sharing plan, employee stock ownership plan or
commercial activities.) money purchase pension plan. But in reality, any qualified pension plan is a
401(a) plan, including a 401(k) plan. A 401(k) plan is a type of profit sharing
plan and is a qualified plan under section 401(a) of the Internal Revenue code.
The information provided here is intended to help you understand the
general concept and does not constitute any tax, investment or legal advice.
Consult your financial, tax or legal advisor regarding your own unique
situation and your company's benefits representative for rules specific to
your plan. Source: 401Khelpcenter.com
Investment
Provider
Selection
Can an employee
contribute to multiple
investment providers
or only one?
An employee may choose to allocate his/her employer and employee
contributions to one or more of the approved investment providers offered by
the VDC Program.
26
Rollover(In) –
Employee
Transactions
Will the employee be
able to roll over
outside assets (e.g.
401(k), 403(b), etc.)
at any time (after the
vesting period is
complete) into the
VDC account?
No. The VDC Program does not have a rollover provision at this time.
The State University of New York has assembled a list of questions that were asked during webinars introducing the
VDC Program to State Agencies. These questions address a variety of areas such as eligibility, vesting and
administration. Each question is accompanied by a brief answer.
Please watch an online presentation at www.brainshark.com/tiaa-cref_direct/NYSVDC to learn more about the Defined
Contribution Program and what is required of you.
Also, visit vdc.ny.gov, the retirement plan website for the VDC Program.
This is only a general guide and responses are not meant to capture every scenario. The material provided in this
booklet is for general information purposes only. Although every effort has been made to ensure its accuracy, the rules
of SUNY’s Optional Retirement Program are binding.
Specific questions should be directed to the Plan Administrator, The State University of New York or the Plan
Recordkeeper, TIAA-CREF.
For Institutional Investor Use Only. Not for Use With or Distribution to the Public.
Revised September 24, 2015
Job: 141008962
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