Disclosure Assist User Guide: Creating and delivering your ... · Disclosure Assist® User Guide:...
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Disclosure Assist ® User Guide: Creating and delivering your annual fee disclosure notice May 2020 Note: TIAA cannot and does not offer legal advice and we recommend that you consult with your own legal advisors for such advice. For institutional investor use only. Not for use with or distribution to the general public.
Transcript of Disclosure Assist User Guide: Creating and delivering your ... · Disclosure Assist® User Guide:...
Disclosure Assist® User Guide: Creating and delivering your annual fee disclosure noticeMay 2020
Note: TIAA cannot and does not offer legal advice and we recommend that you consult with your own legal advisors for such advice.
For institutional investor use only. Not for use with or distribution to the general public.
1 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Table of contentsCompliance with your annual participant fee disclosures 2
Section One—Disclosure Assist 3 Overview—Fee Disclosure and COVID-19 State of Emergency 3
Customization features 3
Did you know? 4
Defining plan participant 5
Your participant data delivery file 5
Information for plans with multiple service providers 5
Section Two—Before you start 6 Accessing Disclosure Assist 6
Navigating 6
Useful tips 7
Section Three—Instructions for creating your participant disclosure (Plan and Investment Notice) 8 Your delivery options 8
eDelivery—Recommended best practice 8
Option 1: Self-delivery 9
Option 2: Self-delivery + online access 10
Option 3: TIAA Delivery Assistance + online access 13
Section Four—Additional resources for Option 3: TIAA delivery assistance 18 Participant delivery data file instructions 18
Option 3: TIAA Delivery Assistance participant disclosure delivery schedule 20
Frequently asked questions about undeliverable or returned disclosure notices 20
For institutional investor use only. Not for use with or distribution to the general public.
Compliance with your annual participant fee disclosuresThe Department of Labor (DOL) established regulation section 404a-5 which requires plan sponsors to send plan- and invested-related information annually to all eligible plan participants, including terminated participants that have account balances. ERISA’s rules are designed to help participants make more informed investment decisions when managing their account and planning for retirement. They require that you provide sufficient information about the plan and its investment options on an annual basis.
TIAA offers Disclosure Assist, an online tool, to assist in the management, creation, and delivery of your annual participant Plan and Investment Notice, which includes two sections:
W Section I: Summary of Plan Services and Costs
W Section II: Investment Options Comparative Chart
The information contained in this guide will help you:
W Understand how to use Disclosure Assist to help you meet your annual disclosure requirement
W Develop an accurate and thorough participant data delivery file
W Successfully provide plan and investment information to your participants
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
2 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
COVID-19 State of Emergency and your deadline:Due to the Covid-19 National Emergency, the DOL is providing relief from the typical 14-month fee disclosure filing deadline. This Relief Period applies to fee disclosure notices due after March 1, 2020 and up until 60 days after the announcement of the end of the COVID-19 National Emergency or another date announced by the DOL in the future.
The new guidelines state that “ERISA-required notices, disclosures or documents that must be provided to plan participants and beneficiaries during this Relief Period will not be considered late as long as the plan and responsible fiduciary act in good faith and furnish them as soon administratively practicable under the circumstances.” Good faith acts include use of electronic alternative means of communicating with plan participants and beneficiaries who the plan fiduciary reasonably believes have effective access to electronic means of communication, including email, text messages, and continuous access websites.”
Familiarize yourself with the revised guidelines for delivering your notices during the COVID-19 State of Emergency.
Section One—Disclosure AssistOverviewDisclosure Assist is TIAA’s online tool that allows you to manage, create and deliver your annual fee disclosure and other plan-related notices. By using this tool for your annual fee disclosure notices, you can:
W Choose the level of service that best meets your needs: Self-delivery (Options 1 or 2) or Option 3: TIAA Delivery Assistance
W Access historical disclosure documents and their published dates for all of your plans recordkept by TIAA for the last seven years
W Customize the plan name displayed on your disclosure notice, update the cover letter with your own return address, your institution’s logo and unique messaging, and add a unique signature and closing. Customization is available if you select Option 3: TIAA Delivery Assistance.
W Combine other service provider information, if applicable, to create a consolidated disclosure notice
W Review your plan’s participant data delivery file, which identifies all the participants TIAA has on record
W Coordinate the distribution of your disclosure notice to all eligible participants and beneficiaries, and track the delivery status
The step-by-step instructions on the following pages will guide you through the creation, review and delivery of your annual Plan and Investment Notice from start to finish.
Customization featuresDisclosure Assist offers features to better connect plan sponsors with their participants. With Option 3: TIAA Delivery Assistance, you have the ability to customize your participant disclosure notice so the information is coming from you, the employer. You can:
W Update the way your plan name appears on your Plan and Investment Notice
W Create a custom cover letter with your own personalized closing and signature. You can include your institution’s logo, TIAA’s logo or choose not to include one. A customized return address helps manage any returned mail and helps ensure that your records are up-to-date.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
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3 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Did you know?You can use Disclosure Assist to deliver other notices such as QDIA Notices and Plan Change Notices to your employees and plan participants.
Disclosure Assist can help simplify the notification process and make it easier for you to meet your responsibilities. With Disclosure Assist, you can:
W View participant notices and documents
W Choose your level of delivery service
W Track delivery for audit purposes
W View history of current and past notices
To learn more, refer to the Disclosure Assist Reference Guide: Participant notices and documents.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
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4 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Defining “plan participant”To help you understand your responsibilities and who needs to receive these notices and documents, keep these definitions in mind:
W Eligible participants: Employees who are actively participating in the plan or eligible but not participating
W Terminated participants: Employees who are no longer employed at your institution but still have account balances in the plan
W Participants on file with TIAA: Participants who have an account balance with TIAA; we use the contact information on file with us to deliver the notices and documents
W Participants not on file with TIAA: Participants who don’t have an account balance with TIAA so we don’t have their contact information on file
Your participant delivery data fileNo matter which delivery option you select, your file should include all employees who are required to receive the annual fee disclosure notice. Your TIAA representative can answer questions you might have about your participant delivery data file.
What is it?
Who is included?
What data is needed?
How does TIAA help?
W An Excel file that consolidates data on all employees who are required to receive the disclosures
W All eligible employees, including nonparticipating employees
W Terminated participants with account balances at TIAA
W Employer name and plan ID
W Employee first and last names
W Social Security number
W Work email address
W Home address
W Provides file formatting guidelines
W Provides a spreadsheet of all participants TIAA has on file
W Maintains information on terminated participants, if you provided previously
Information for plans with multiple service providersDisclosure Assist enables you to combine information from other service providers into one disclosure, allowing your participants to make more meaningful comparisons. If you have multiple providers, you will need the following information:
W Other service provider information The service provider(s) contact information will be displayed on the Investment Options Comparative Chart in your Plan and Investment Notice and fulfills the obligation to provide participants a source for additional investment-related information.
The contact information you provide for your other service provider(s) will complete the following sentence: “To request additional plan information from <insert provider name> or a paper copy of information available online, free of charge, contact <insert contact information/address/phone/web>.” In addition you should provide a website address where additional investment-related information (including more current performance) can be found.
W Ticker and/or CUSIP numbers from other service providers Having the ticker and/or CUSIP numbers will allow for easier entry of your mutual fund information, but you’ll need to manually enter all information for the plan’s variable annuities and other non-mutual fund investment options.
W TIAA Plan and Investment Notice Your notice includes two sections: “Summary of Plan Services and Costs” and “Investment Options Comparative Chart.” You can use our disclosure as a template for consolidating your other provider information.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
5 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Section Two—Before you startDisclosure Assist was developed to make compliance with fee disclosure regulations as simple as possible for you. The step-by-step instructions on the following pages will guide you through the creation, review, and delivery of your annual Plan and Investment Notice from start to finish.
Accessing Disclosure Assist:
Log in to
PlanFocus®
Go to the Compliance
tab
Choose Disclosure
Assist
Select Annual Fee Disclosures
Navigating: W You can move between screens using the navigation bar located under your plan name on each screen.
W Remember to click Save and Continue before moving to the next screen.
W You can find historical disclosures and their publish dates under “View/Download Disclosure History.” This historical information will be retained for seven years.
W The delivery option you used last year will be preselected. You can select a different option when you begin.
W If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
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Useful tips W If you are entering a significant amount of information, periodically click SAVE so you don’t lose your work if the system
times you out.
W Download, create/edit and save your participant delivery data file at the start of the process. Refer to pages 18 and 19 in this guide for more information on how to create a file with all the information needed to deliver your disclosures.
W You can download the TIAA sample cover letter and use it to notify participants that their Plan and Investment Notice is available. This sample letter is available under “View/Download Disclosure Resources.”
W Quarter-end performance for variable-return investments is updated on or around the tenth business day after the end of each quarter and is only available with Delivery Options 2 and 3.
W If you are using Delivery Options 2 or 3, disclosure notices can be viewed online. Go to: TIAA.org > Resources > Research performance & news > Retirement investments. Select your plan name and your Plan and Investment Notice will be under “Helpful links specific to this product.”
W Use Option 2: Self-delivery + online access within Disclosure Assist to republish your disclosures to the TIAA website more than once in the required period. Use Option 3: TIAA Delivery Assistance to deliver disclosures to your participants once in each allowable period.
TIAA has resources to help you
Fee Disclosure Tutorial Access any time to learn more about fee disclosure, the DOL regulations and for information on how to use Disclosure Assist
Fee Disclosure Center Insights and resources about meeting your fee disclosure responsibilities
Disclosure Assist Checklist A helpful list of tasks to help you prepare and stay on track to meet your annual deadline
If you have any questions about Disclosure Assist, please contact your client services manager or relationship manager. If your plan is serviced by the Administrative Telephone Center, you can speak with one of our experienced consultants at 888-842-7782, weekdays, 8 a.m. to 8 p.m. (ET).
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
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7 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Section Three—Instructions for creating your annual participant disclosure (Plan and Investment Notice)The process for creating your participant disclosure depends on which delivery option you choose.
Your delivery optionsThrough Disclosure Assist, we offer three different delivery options from do-it-yourself to full delivery assistance. This flexibility enables you to choose the level of assistance that best meets your plan’s needs. The chart below outlines the features of each of the available options.
Delivery options
OptionOption 1: Self-delivery
Refer to page 9Option 2: Self-delivery + online access
Refer to page 10Option 3: TIAA Delivery Assistance + online access
Refer to page 13
Description You are responsible for downloading the Plan and Investment Notice prepared by TIAA and delivering it to your participants.
Same as self-delivery with these added features:
W Ability to combine plan and investment information from multiple service providers
W Ability to post the disclosure online at TIAA.org
TIAA delivers the Plan and Investment Notice to all of your eligible participants on your behalf. You can also:
W Combine plan and investment information from multiple service providers
W Customize your disclosures—plan name and cover letter
W Post the disclosure online at TIAA.org
Best option when:
You want to manage the delivery process or are working with another service provider who may be consolidating information from multiple providers.
W You want to manage the delivery process and also want your participants to have online access to the information.
W You want the ability to update your Plan and Investment Notice more than once per period and post the most current information on TIAA.org for your participants.
W You want to update the name that is displayed on your Plan and Investment Notice and customize the cover letter for your participants.
W You want to increase your use of eDelivery.
W You want TIAA to distribute your Plan and Investment Notice.
Note: TIAA Delivery Assistance is only available once per period. You are responsible for delivering any additional disclosures, as needed.
eDelivery—Recommended best practiceeDelivery is the preferred delivery option as it is the fastest, most efficient and environmentally friendly way to distribute disclosure notices to your participants. (eDelivery is available with Option 3 - TIAA Delivery Assistance.) As a reminder, the DOL safe harbor regulations allow you to use work email addresses for employees who use a computer as an integral part of their job duties and have the ability to effectively access documents furnished in electronic form at any location where they are reasonably expected to perform their duties as employees. Please visit TIAA’s eDelivery FAQ’s to get started.
Safe harbor also applies to other participants (e.g., retirees, former employees and active employees who do not use a computer as an integral part of their duties), beneficiaries and other persons entitled to disclosures under Title I of ERISA who affirmatively consent to receiving disclosures through electronic media in the manner prescribed by the regulation.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
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8 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Who can receive the notice electronically? W Participants and eligible employees who use computer as an integral part of their job duties and who
have the ability to effectively access documents furnished in electronic form
W Those who have provided consent to receive documents electronically
Employees with work email addresses
Employees with a TIAA account and no
work email
Employees with a non-TIAA account and
no work email
Receive an email notification when notice is available
TIAA will deliver the information via email if consent given to receive documents electronically
Delivered by mail to the address provided in the
participant data file
Option 1: Self-delivery It’s your responsibility to download the Plan and Investment Notice prepared by TIAA and to deliver it to your participants.
Click on the icon to jump back to Section Two—Before you start.
Step 1
Select Option 1: Self-delivery
Step 2
Scroll down to view and download your Plan and Investment Notice.
Access and download your participant data delivery file. This is the starting point for creating/editing the file you’ll need to distribute your annual disclosure notice.
You are now ready to distribute your Plan and Investment Notice using your participant data delivery file. If you have more than one ERISA plan, you can return to the main Disclosure Assist screen and repeat the process for your other plans.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
9 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Option 2: Self-delivery + online access
You are responsible for downloading the Plan and Investment Notice prepared by TIAA and for delivering it to your participants. You can combine plan and investment information from multiple service providers and post your disclosure notice online at TIAA.org.
Click on the icon to jump back to Section Two—Before you start.
Step 1
Select Option 2: Self-delivery + online access
Step 2
Scroll down to view and download the Plan and Investment Notice.
Access and download your participant delivery data file. Refer to page 18 for more information on how to create a file with all the information necessary to deliver your disclosures.
Scroll up and select Continue to Set Up.
Step 3
Answer the question, “Does this plan have assets with other retirement service providers?” If no, complete Steps 4-6. If yes, complete Steps 7-11.
Reminder:
Complete Steps 4-6 if you do NOT have assets with other retirement service providers.
Step 4
Review and edit TIAA service provider information in Section II: Investment Options Comparative Chart of the Plan and Investment Notice. Then, click Save & Continue.
Quick tip: The majority of our clients include TIAA’s contact information so their participants can request additional information about the plan’s investment options, obtain prospectuses and financial statements or lists of portfolio assets. However, this contact information can be changed if you choose.
Step 5
Preview your Plan and Investment Notice and check the Service Agreement box. If everything looks correct, click Publish Disclosure.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
10 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Important:
Once you publish your disclosure, no changes can be made.
Step 6
View the delivery confirmation and instructions for your disclosure notice. Then, print the confirmation page for your records.
Since TIAA is your exclusive service provider, this completes the creation process. You are now ready to distribute your Plan and Investment Notice using your participant delivery data file. Your disclosure will be available on TIAA.org within three days. If you have more than one ERISA plan, you can return to the main Disclosure Assist screen and repeat this process for your other plans.
Reminder: You only need to complete Steps 7-11 if your plan has assets recordkept by other service providers.
Step 7
Review and edit TIAA and your other service providers’ contact information, including their addresses and phone numbers. Then, click Save & Continue.
Step 8
Add plan-related information from all other providers. This information will be included in Section I: Summary of Plan Services and Costs of the Plan and Investment Notice. To add the information, choose the appropriate “Heading” from the pull-down menu, and then either copy and paste or type the applicable text from each provider’s disclosures.
Click Save after you have finished entering the information. Then click Save & Continue.
Quick tips: W Keep your other providers’ disclosures handy to use as a reference when completing this step.
W The headings in the pull-down menu align with specific DOL content requirements. While your other service providers may use different headings, we suggest aligning the information to the headings in our pull-down menu for consistency and a better participant experience.
Step 9
Add information for the investment options that have recordkeeping services by other service providers by entering the ticker symbol or CUSIP number for each investment option. You will have to manually enter the investment data for investment options that do not have a Ticker Symbol or CUSIP number. Be sure to manually enter investment data for Retirement Annuity Investments. Enter footnotes for all investment options as needed.
Once the data is entered, click Save, then Preview Report to view your entire Plan and Investment Notice. After you are done reviewing, close the report, make any necessary changes and click Save & Continue.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
11 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Quick tips: W If you enter any data manually, make sure the performance information is for the same time period as the
performance figures automatically provided.
W Ticker and/or CUSIP numbers allow for easier entry of mutual fund investment information. You will need to manually enter all investment information for the plan’s variable annuities and other non-mutual fund investment options.
Step 10
Preview your Plan and Investment Notice and check the Service Agreement box. If everything is correct, click Publish Disclosure.
Important: Once you publish your disclosure, no changes can be made.
Quick tip: If there are investment and/or plan-related changes after your annual disclosure has been sent, you may want to update the disclosure information using Option 2 and then direct your participants to TIAA.org to view current fees, expenses and/or performance information. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance.
Step 11
View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records.
This completes the creation process and you are now ready to distribute your Plan and Investment Notice using your participant delivery data file. Your disclosure will be available on TIAA.org within three days. If you have more than one ERISA plan, you can return to the main Disclosure Assist screen and complete the process for your other plans.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
12 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Option 3: TIAA Delivery Assistance + online accessTIAA will deliver the Plan and Investment Notice to all of your eligible participants on your behalf. In addition, you can combine plan and investment information from multiple service providers and post your disclosure online at TIAA.org.
Reminder: To help ensure your Plan and Investment Notice is successfully delivered to work email addresses, refer to page 20 for more details.
With this delivery option, you have the ability to customize aspects of your Plan and Investment Notice and, with this option, you can use edelivery.
Click on the icon to jump back to Section Two—Before you start.
Step 1
Select Option 3: TIAA Delivery Assistance + online access
Step 2
Scroll down to view and download the Plan and Investment Notice.
Access and download your participant delivery data file, which contains eligible participants (including terminated participants) with an account balance at TIAA. This is the starting point for creating/editing the file that is needed to distribute your annual disclosure notice. Refer to page 18 for more information on how to create a file with all the information needed to deliver your disclosures.
Scroll up and select Continue to Set Up.
Step 3
Review the Plan Name that will appear on your Plan and Investment Notice. Click edit to make any changes.
Review and edit the following information to create your custom letter.
W Return Address—any returned disclosures will be sent to this address
W Select one of the available logo options—the TIAA logo, your institution’s logo (if currently available) or no logo
W Edit the standard language that is included on the cover letter
W Optional signature—add your personalized closing, signature and select your preferred style
Once finished, click Save, and then review your cover letter by clicking Preview. If you are satisfied with how your cover letter appears, click Save & Continue.
Quick tips: W The content in Sections A and B have character limitations. You are limited to 110 characters per line with
a total of 16 lines. If you exceed the limit, your content will be truncated and will not display correctly on your cover letter. Always preview the cover letter for typos and spelling errors.
W If your institution’s logo is not on file, you will receive a message that your logo is unavailable. Call your client services manager or the Administrator Telephone Center who will work with you to upload your logo to PlanFocus. Please note that it takes approximately three-four weeks to load a logo into PlanFocus.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
13 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Step 4
Answer the question, “Does this plan have assets with other retirement service providers?”
If no, complete Steps 5-8. If yes, complete Steps 9-14.
Reminder: Complete Steps 5-8 if you do NOT have assets with other retirement service providers.
Step 5
Review and edit TIAA Service Provider information that will appear in Section II: Investment Options Comparative Chart of the Plan and Investment Notice. Then, click Save & Continue.
Step 6
One of two delivery options is available for your plan:
W TIAA delivery to all participants
W TIAA delivery to terminated participants only
If you want delivery to all participants, follow Step 6A.
If you want to deliver to terminated participants only, follow Step 6B.
Step 6A
Select TIAA delivery to all participants and upload your participant delivery data file. Refer to page 18 for more information on how to create a file with all the information needed to deliver your disclosures. Then click Save & Continue.
You have two options to access your participant delivery data file:
W Click the Download File Template button to create your participant file using the blank template provided.
W Click TIAA’s participant data file to use a prepopulated file that contains postal addresses for all active participants and terminated participants with a balance at TIAA. Terminated participants without a balance will not receive a disclosure from TIAA.
Note: Any changes made to your participant delivery data file only impact this communication. You are still responsible for notifying TIAA of any participant changes (i.e., address, status, etc.).
After you have successfully uploaded your participant delivery data file, you can view a date/time stamp by hovering your cursor over the “File Uploaded” link. This shows the date and time of the last file uploaded into the system and allows you to view the updated participant data.
Quick tips: If there is an error in your participant delivery data file, you will receive a message stating the reason and location of the error. This message will be displayed in red at the top of the page. Refer to the participant delivery data file specifications on page 19 for additional information.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
14 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Step 6B
Select TIAA delivery to terminated participants only. Then click Save & Continue.
Quick tip: If you select this option, TIAA will only deliver the Plan and Investment Notice to the terminated participants that are included in the participant data delivery file you uploaded. The Delivery Audit Report will include the delivery status of your disclosure notices. You will need to distribute the information to all other participants and eligible employees.
Step 7
Preview the Plan and Investment Notice and check the Service Agreement box. Then, click Publish Disclosure.
Important: Once you publish your disclosure, no changes can be made.
Quick tip: If there are investment and/or plan-related changes after your annual disclosure notices have been sent, you may want to update the disclosure information using Option 2 (see page 10) and direct your participants to TIAA.org to view current fees, expenses and/or performance. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance.
Step 8
View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records.
This completes the creation process and your Plan and Investment Notice will be distributed to all employees required to receive it within 30 calendar days after you publish. The disclosure will also be available on TIAA.org within three days. If you have more than one ERISA plan, you can return to the main Disclosure Assist screen to complete the process for your other plans.
Reminder: Complete Steps 9-14 if your plan has assets recordkept by other service providers.
Step 9
Review and edit TIAA and your other service providers’ contact information, including their addresses and phone numbers. Then, click Save & Continue.
Step 10
Add plan-related information from all other providers. This information will be included in Section I: Summary of Plan Services and Costs of the Plan and Investment Notice. To add the information, choose the appropriate “Heading” from the pull-down menu, and then either copy and paste or type the applicable text from each providers’ disclosures.
Click Save after you have finished entering the information. Then, click Save & Continue.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
15 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Quick tips: W Keep your other providers’ disclosures handy to use as a reference when completing this step.
W The headings in the pull-down menu align with specific DOL content requirements. While your other service providers may use different headings, we suggest aligning the information to the headings in our pull-down menu for consistency and a better participant experience.
Step 11
Add information for the investment options with recordkeeping services performed by other service providers by entering the ticker symbol or CUSIP number for each investment option. You will have to manually enter the investment data for investment options that do not have a Ticker Symbol or CUSIP number. Be sure to manually enter investment data for Retirement Annuity Investments. Enter footnotes for all investment options as needed.
Once the data is entered, click Save, then Preview Report to view your entire Plan and Investment Notice. After you are done reviewing, close the report, make any necessary changes and click Save & Continue.
Quick tips: W If you enter data manually, make sure the performance information is for the same time period as the
performance figures automatically provided.
W Ticker and/or CUSIP numbers allow for easier entry of mutual fund investment information. You will need to manually enter all investment information for the plan’s variable annuities and other non-mutual fund investment options.
Step 12
One of two delivery options is available for your plan:
W TIAA delivery to all participants
W TIAA delivery to terminated participants only
If you want delivery to all participants, follow Step 12A.
If you want to deliver to terminated participants only, follow Step 12B.
Step 12A
Select “TIAA delivery to all participants” and upload your participant delivery data file. Refer to page 18 for more information on how to create a file with all the information needed to deliver your disclosures. Then click Save & Continue.
You have two options to access your participant delivery data file:
W Click the Download File Template button to create your own participant file using the blank template provided.
W Click TIAA’s participant data file to use a prepopulated file that contains postal addresses for all active participants and terminated participants with a balance with TIAA. Terminated participants without a balance will not receive a disclosure from TIAA.
Note: Any changes to your participant delivery data file only impact this communication. You are still responsible to for notifying TIAA of any participant changes (i.e., address, status, etc.).
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
16 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
After you have successfully uploaded your participant delivery data file, you can view a date/time stamp by hovering your cursor over the “File Uploaded” link. This latest enhancement shows the date and time that the last file was uploaded into the system and allows you to view the updated participant data.
Quick tip: If there is an error in your participant delivery data file, you will receive a message stating the reason and location of the error. This message will be displayed in red at the top of the page. Refer to the participant delivery data file specifications on page 18 for additional information.
Step 12B
Select “TIAA delivery to terminated participants only.” Then click Save & Continue.
Quick tip: If you select this option, TIAA will deliver the Plan and Investment Notice only to terminated participants included in the participant data delivery file. The Delivery Audit Report will include the delivery status of the disclosure notices. You will need to distribute the information to all other participants and eligible employees.
Step 13
Preview the Plan and Investment Notice and check the Service Agreement box. If all appears to be correct, click Publish Disclosure.
Important: Once you publish your disclosure, no changes can be made.
Quick tip: If there are investment and/or plan-related changes after your annual disclosure has been sent, you may want to update the disclosure information using Option 2 (see page 10) and direct your participants to TIAA.org to view current fees, expenses and/or performance information. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance.
Step 14
View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records.
This completes the creation process and your Plan and Investment Notice will be distributed to all employees required to receive it within 30 calendar days after you publish. The disclosure will also be available on TIAA.org within three days. If you have more than one ERISA plan, you can return to main Disclosure Assist screen to complete the process for your other plans.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
17 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Section Four—Additional resources for Option 3: TIAA Delivery AssistanceParticipant delivery data file instructionsIf you are using Option 3: TIAA Delivery Assistance, we will need current contact information for all employees required to receive the Plan and Investment Notice to help ensure successful delivery.
Below are the step-by-step instructions for creating the participant delivery data file that you will need to upload into Disclosure Assist. The file specifications are on the following page.
Steps to build the participant delivery data file
Step Action Quick tip
1Access and download the TIAA participant delivery data file from Disclosure Assist.
Access this file from the bottom of the Delivery Option Selection page in Disclosure Assist. As a best practice, download, create/edit and save your participant delivery data file at the start of the process.
2 Save the file to your computer. Use this suggested file format: “Plan#_PlanYearEnd_FD_Participant_Delivery_File.xls”
3
Add work email addresses for all employees who use a computer as an integral part of their job duties and have the ability to effectively access documents furnished in electronic form at any location where the employee is reasonably expected to perform their duties as employees.
Requirements for using work email addresses are outlined in the DOL safe harbor guidelines.
4Remove participants who do not have access to a computer as part of their job.
We will automatically mail paper disclosure notices to the addresses on file for these employees unless we have received their approval to receive electronic documents via an alternate email address.
5Add employees who are eligible but not currently participating. If an employee meets the DOL safe harbor guidelines for electronic delivery, provide their email
address. Otherwise, provide their home address.
6
If you have other service providers, add employees who do not have accounts with TIAA, but have accounts with these other providers.
If an employee meets the DOL safe harbor guidelines for electronic delivery, provide their email address. Otherwise, provide their home address.
7
Save your participant delivery data file to your computer. Make sure your file:
W Is saved as an “.xls” file; other file extensions are not compatible
W Meets the required file specifications on page 19 of this guide
W Has the correct 9-digit SSN format under Column C*
W Does not contain number signs, hyphens, symbols, periods, etc. in any “alphanumeric” data fields. (See page 19)
W Does not contain any duplicate records
W Contains only one worksheet
8Once your participant delivery data file is completed, upload it into Disclosure Assist.
Refer to Step 6A or Step 14A for Delivery Option 3 for more details.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
18 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
Have questions about your participant data delivery file?Contact your client services manager or relationship manager. If your plan is serviced by the Administrator Telephone Center, call 888-842-7782, weekdays, 8 a.m. to 8 p.m. (ET).
Participant delivery data file formatting
Column Column Name Max Length Data Type Example Required/
Optional Comments
A Employer Name 64 Alphanumeric ABC Nonprofit Required The name of the employer
BEmployer Plan ID
6 Alphanumeric 123456 Required The Employer Plan ID uniquely identifies the Plan on TIAA’s recordkeeping system.
CEmployee SSN * 9 Numeric 123456789 Required The participant’s SSN will be used to identify the
participant. *See page 18 for details.
DEmployee First Name
35 Text John Required Employee first name to be used for fee disclosure, or other purposes as agreed by TIAA and employer.
EEmployee Middle Name
35 Text B Optional Employee middle name to be used for fee disclosure, or other purposes as agreed by TIAA and employer.
FEmployee Last Name
35 Text Sample Required Employee last name to be used for fee disclosure, or other purposes as agreed by TIAA and employer.
G Address 1 50 Alphanumeric 123 Central St Required Employee home address
H Address 2 50 Alphanumeric Apartment 34 Optional Second address line if needed for employee home address.
I Address 3 50 Alphanumeric Optional Third address line if needed for employee home address.
JCity 32 Alphanumeric Somewhere Conditional,
required for employees in U.S.
Employee city. For foreign addresses, no city is required.
KState 2 Alphanumeric AZ Conditional,
required for employees in U.S.
Employee state. For foreign addresses, enter “FN” for the state. For APO addresses, enter “NA” for the state.
L
Zip 9 Numeric 76543
or
765431234
Conditional, required for employees in U.S.
Employee zip code. For foreign addresses, no zip code is required.
MWork Email Address
255 Alphanumeric [email protected]
Conditional/Required
Employee’s work email address if the employee has access to a computer and a work email address as part of their integral job duties (refer to safe harbor details).
N
Employee Plan Status
1 Text E, P, X, N, D, A, T, R
Optional E = Eligible, not participating P = Eligible and participating (self-elected) X = Excluded class N = Not eligible D = Default enrolled A = Auto enrolled T = Terminated R = RetiredAny updates to the Employee Plan Status Code will not change a participant’s status in our records.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
* To format the SSN column, use the Excel “format cells” feature. Select Column C, press Ctrl+1 and go to the Number tab in the dialog box. Select the “custom” category and enter the format as 000000000. Click OK to set the format.
19 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
Option 3: TIAA Delivery Assistance participant disclosure delivery schedule Your Plan and Investment Notice will be delivered to your participants within 30 calendar days after you publish it. If you select Option 3: TIAA Delivery Assistance, we will deliver your required disclosures as follows:
Group 1 All employees with work emails listed in the participant delivery data file.
Group 2 Employees with a TIAA account and no work email. We will deliver the information electronically if we have received “affirmative consent” from the employee as outlined by the DOL. Otherwise, a paper copy will be sent via regular mail to the address on file.
Group 3 Employees with a non-TIAA account and no work email. We will send a paper copy via regular mail to the address you provided in your participant delivery data file.
Frequently asked questions about undeliverable or returned disclosure noticesAs the plan sponsor, you are responsible for making a “good faith” effort to locate any eligible, participating or terminated employees who have not received the participant disclosure due to undeliverable U.S. mail. There are several reasons why the disclosure may be returned as undeliverable, including:
W The employee recently moved.
W The forwarding address has expired.
W The address on file is not correct.
Below are some frequently asked questions to help you understand how the “returned to sender” mail process works and resources to help you locate a missing participant or beneficiary.
1. Is there a report that shows the delivery method and whether delivery was successful?
Yes, you will receive a Delivery Report that includes:
W A summary of the success rate for each delivery method, including eDelivery and hard copy
W Participant details by delivery method, sorted by delivery status (successful/unsuccessful) and then last name
(You can access your Delivery Report online via Disclosure Assist in both pdf and csv (EXCEL) formats and it will be available for seven years.)
W Participants with an Undeliverable/Bad Address: A disclosure was not mailed as the address on file is invalid; mail was previously returned from that address and TIAA has not received an updated address from the employee or the U.S.P.S.
W Participants with an Undeliverable/No Address: A disclosure was not mailed as TIAA does not have an address on file
2. What happens to the participant disclosures that are returned as undeliverable?
Returned mail will be sent back via U.S.P.S. to the return mail address listed on the cover letter. If it has been determined that the address on file is invalid, we will not mail the disclosure. The employee will be listed on the Delivery Report as Undeliverable/Bad Address. You will then need to make a good faith effort to locate the employee’s address and deliver the disclosure.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
20 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
3. What do I need to do after receiving the returned mail?
The DOL does not provide any specific guidance on this issue. It only states that a “good faith effort” must be made to deliver the disclosures. There are no penalties imposed for undelivered mail but, as a part of your fiduciary process, you should document your efforts to redeliver the disclosures.
To help manage your returned mail, consider providing TIAA with work email addresses for employees who used a computer as an integral part of their job duties, and who have the ability to effectively access documents furnished in electronic form at any location where the employee is reasonably expected to perform their duties as employees.
4. How can I locate individuals who have mail returned?
The DOL suggests a number of options in the Field Assistance Bulletin for locating missing participants and beneficiaries. You can also try:
W Sending disclosures via certified mail
W Checking the records of related plans to the extent not precluded by privacy requirements
W Checking with the designated plan beneficiary
W Using free electronic search tools
5. How do I make sure that disclosures sent electronically via work emails get past my organization’s internal email firewall?
To successfully deliver your notice to work email addresses, your system must recognize the From email and IP addresses that TIAA uses when delivering the notices. Make sure your IT department has the current information to ensure emails are not blocked from TIAA. Refer to the TIAA Email Delivery Alert for more information.
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
21 Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
This material is for informational or educational purposes only and does not constitute investment advice under ERISA. This material does not take into account any specific objectives or circumstances of any particular investor, or suggest any specific course of action. Investment decisions should be made based on the investor’s own objectives and circumstances.
The TIAA group of companies does not provide legal or tax advice. Please consult your legal or tax advisor.
TIAA-CREF Individual & Institutional Services, LLC, Member FINRA, distributes securities products.
©2020 Teachers Insurance and Annuity Association of America-College Retirement Equities Fund, 730 Third Avenue, New York, NY 10017
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38821_411816(05/20)
TIAA is here to help youDisclosure Assist was developed to help make compliance with the fee disclosure regulation as simple as possible. If you have any questions about Disclosure Assist, please contact your client services manager or relationship manager. If your plan is serviced by the Administrator Telephone Center, you can speak with one of our experienced consultants at 888-842-7782, weekdays, 8 a.m. to 8 p.m. (ET).
Disclosure Assist User Guide: Creating and delivering your annual fee disclosure notice
For institutional investor use only. Not for use with or distribution to the general public.
