Bringing a 36-Campus State University System into 403(b) Compliance

SBA was retained by a state to bring its public university system into compliance with the first new 403(b) regulations in 40 years. The state’s system consisted of 36 individual universities. Over decades, the system had grown unmanaged and uncontrolled until 78 separate 403(b) investment vendors had become entrenched. Numerous issues existed, including excessive participant investment fees, no investment oversight, no vendor management, no plan documents or policies and an inability to comply with the new government regulations.

SBA designed a new, system-wide structure, eliminated 75 vendors, implemented the compliance structure across the three remaining vendors and developed plan documents, investment policy statements, plan procedures and employee communications. SBA assisted each of the 36 colleges in the sizable transition, providing education and training on the compliance requirements. Later, SBA audited all 36 colleges to ensure all documents and procedures were in place and all compliance processes were being appropriately executed.

SBA transformed an uncontrolled and unmanageable situation that spanned an entire, statewide university system into a streamlined approach for serving participants in a cost-efficient manner while maintaining full compliance with the new 403(b) regulations.