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HomeMy WebLinkAbout12. Approve an amended 401a Money Purchase Plan Adoption agreement with MissionSquare Retirement Page 1 of 18 Item 12. CENTRAL SAN BOARD OF DIRECTORS POSITION PAPER MEETING DATE: MAY 5, 2022 SUBJECT: APPROVE THE EXECUTION OF AN AMENDED 401A MONEY PURCHASE PLAN ADOPTION AGREEMENT WITH MISSIONSQUARE RETIREMENT SUBMITTED BY: INITIATING DEPARTMENT: KEVIN MIZUNO, FINANCE MANAGER ADMINISTRATION-FINANCE REVIEWED BY: TEJI O'MALLEY, HUMAN RESOURCES AND ORGANIZATIONAL DEVELOPMENT MANAGER PHILIP LEIBER, DIRECTOR OF FINANCE AND ADMINISTRATION Roger S. Bailey General Manager ISSUE Amendments are being proposed to the 401 a Money Purchase Plan Adoption Agreement with Mission Square (formerly I CMA-RC)to: 1) restate the plan pursuant to I RS regulations; 2) incorporate the provisions of a recently Board-approved employee elective deferral for Unrepresented at-will employees; and 3) allow for an additional elective but irrevocable deferral benefit to newly hired employees. BACKGROUND The following provides a synopsis of the changes proposed to the 401(a) Money Purchase Plan (401 a Plan)Adoption Agreement. The new Adoption Agreement is provided in Attachment 1, and all changes proposed to Appendix A of the 401 a Plan Adoption Agreement are shown in red in Attachment 2. Plan Restatement and Refinement Every six years Central San's 401 a Plan third party administrator(TPA), MissionSquare, is required (by the I RS)to submit (via a "volume submission")their Plan and Trust as well as the Adoption Agreement to the IRS for approval. MissionSquare then requires every plan sponsor with a 401 a Plan to restate the plan. May 5, 2022 Regular Board Meeting Agenda Packet- Page 90 of 261 Page 2 of 18 As part of this process, the I RS noted that any anomalies or amendments/addendums might be considered material enough to fall outside of the "volume submission" of the document, and accordingly would warrant separate consideration and reconciliation with their Plan and Trust document. As Central San's 401 a Plan Adoption Agreement includes such an addendum (i.e., AppendixA), the TPA's plan adoption services team undertook a deeper look for potential issues. While having an addendum that lists different contribution provisions is not considered a material change, the I RS noted that Central San uses slightly different language in the Adoption Agreement than what is on the Appendix A. Specifically, Section V of the 401 a Plan Adoption Agreement describes employees eligible to participate in the plan as "All regularemployees (full and part-time)"whereas AppendixA lists the "General Manager, Local 1, MSCG & Management". It is possible, though unlikely, that if the IRS were to audit the plan that they would not consider Central San to be using the TPA's plan document and could therefore be considered to be out of compliance. Accordingly, out of an abundance of caution, Mission Square recommends these differences be reconciled. Staff is in agreement with the TPA and recommends adopting the revised Adoption Agreement (Attachment 1)which now makes reference to AppendixA in section V and includes a new section in Appendix A to more clearly list each employee group. In consultation with the TPA, this change will not have any impact on how the Plan is administered for employee participation. Employee Deferral for Unrepresented At-Will Employees The 401 a Plan provisions were most recently updated on March 24, 2022 with the Board's approval of Resolution 2022-020 specifying the salary and benefits of the Unrepresented At-Will Employees' group. In addition to establishing new cost of living adjustment provisions for the term of the agreement and creating a Health Reimbursement Account funded by mandatory employee contribution requirements, the Resolution also established requirements for mandatory employee contributions to the 401 a Plan based on three categories (income levels) of Unrepresented employees. The terms of this Resolution took effect on April 18, 2022. Reflecting this latest change, Appendix A to the Adoption Agreement has been updated to include the new mandatory employee contribution requirements for Unrepresented At-Will employees as outlined in Resolution 2022-020. Irrevocable One-time Deferral Election for Newly Hired Employees As the 401 a Plan is being brought forth to the Board to consider an amendment for compliance purposes as outlined previously, staff considers it timely to consider one additional revision to the 401 a Plan Adoption Agreement that will create for a useful benefit option for newly hired employees. The I RS presently allows for an employer to include (in the adoption agreement) an opportunity for employees to make a one-time irrevocable election to contribute to the 401 a Plan. This election must remain in effect (regardless of circumstance) until the employee severs employment with the agency. Furthermore, if the employee returns within five years of employment the election must remain in effect. Based on guidance from Central San's benefits counsel, this choice will be limited to the first day of employment, and the form will specify this limitation. Human Resources intends to provide material related to this selection in advance of the first day of work so that new employees are informed and can make a thoughtful and suitable choice on their first workday. There are a few rational for amending the Adoption Agreement to allow for this new benefit for newly hired future employees. It is the general understanding that the original intent of establishing Central San's 401 a Plan was to provide a social security replacement, and not necessarily to find other means for employees to defer dollars for retirement, which is what the 457b Deferred Compensation Plan was intended to accomplish. Furthermore, the establishment of the 401 a Plan predates the state legislature's rollout of the Public Employee Pension Reform Act (PEPRA), which significantly reduced both employer costs and employee benefits attributable to public pensions for employees hired on or after January 1, 2013, that do not have reciprocity with another pension system. Given the significantly reduced pensions for future newly hired PEPRA employees, those employees could benefit greatly from the opportunity to save more for retirement and defer additional taxes at no additional cost to Central San. Unfortunately, this particular May 5, 2022 Regular Board Meeting Agenda Packet- Page 91 of 261 Page 3 of 18 elective provision is not legally an option for any current employee of Central San pursuant to I RS regulations. I n accordance with the provisions described, it is proposed that the 401 a Plan Adoption Agreement also be amended in Section VI.B., allowing for"mandatory opt-in contributions" ranging from 1% -20% (the legal maximum). This change was discussed by the Deferred Compensation Advisory Committee at their regular quarterly meeting on February 2, 2022. Following a presentation of this matter by the Plan Administrator and TPA and a discussion thereafter, the Advisory Committee voted unanimously in favor of this modification and submission to the Board for approval. This proposed change to the 401 a Plan is scheduled to be brought to the Board for adoption on May 5, 2022. If approved, the deduction option would be available for all eligible employees hired on or after May 5, 2022, immediately following Board approval. ALTERNATIVES/CONSIDERATIONS The Board may elect not to amend the 401 a Plan Adoption Agreement to allow for newly hired employees to voluntarily, but irrevocably, defer income for retirement. This is not recommended, as the new provision would improve optional benefits for future employees at no additional cost to Central San. Furthermore, not amending the plan to reconcile the terminology difference between Article V of the Adoption Agreement and Appendix A may result in compliance issues in the future. The Board may also elect to allow for an extended election window of up to 60 days for newly hired employees (hired after May 5, 2022)to make a one-time irrevocable election to defer income to the 401 a Plan. While the TPA does allow for this provision and provides it for other public agencies, this is not the recommendation of staff in consultation with labor counsel to avoid potential I RS audit findings. Lastly, there is also a provision in the I RS code of regulations allowing for employers to designate mandatory 401 a Plan employee contributions for newly hired or existing employees. Central San would designate an eligible group (or all employees)that would be required to contribute the same amount that is determined and noted in the adoption agreement. This alternative is not recommended by staff as it is not expected to be a popular provision with employees as the existing pension formulas already have mandatory employee contributions requirements. FINANCIAL IMPACTS Adoption of the proposed amendments to the 401 a Plan Adoption Agreement is not expected to have any direct financial impact on Central San. Some staff time will be necessary to modify existing processes to allow newly hired employees to make a one-time irrevocable election to defer income into the 401 a Plan. This additional staff time would is not expected to result in any additional incremental, unbudgeted cost to Central San. It is reasonably possible that Central San's Enterprise Resource Planning consultant, Emtec, will need to be engaged to help develop and test minor new system requirements for this modification. This additional consultant cost, if even needed, is not expected to be significant. COMMITTEE RECOMMENDATION This matter was not discussed by a Board Committee. Pursuant to the advice of Labor Counsel, this item is being brought directly to the Board for approval to expedite amendments to the 401 a Adoption Agreement with MissionSquare to reflect provisions already approved by the Board on March 24, 2022. For efficiency purposes, staff is also including two other changes in this action item as those items do not have any direct financial impacts to neither Central San nor its current workforce. The restatement only includes one minor revision to ensure the Adoption Agreement's consistency with Appendix A, and the new provision allowing for an optional one-time irrevocable deferral election only impacts future employees. The one-time irrevocable election option is not available to current employees of Central San pursuant to I RS regulations, which states said one-time irrevocable election must (A) be allowable in the May 5, 2022 Regular Board Meeting Agenda Packet- Page 92 of 261 Page 4 of 18 Plan document and (B) be made when the employee becomes eligible for plan participation, generally the date of employment. RECOMMENDED BOARD ACTION Staff recommends Board adoption and execution of the attached 401 a Plan Adoption Agreement, which includes the following proposed changes: 1. Revises terminology used in Section V to describe eligible participants to be consistent with the existing and unmodified Appendix A. 2. Revisions to Section V1.1.B establishing mandatory participant contributions for"unrepresented at- will" employees consistent with the previously adopted Resolution No. 2022-020. 3. Revisions to Section V1.1.B - C. allowing for"mandatory opt-in contributions" ranging from 1% - 20% (the legal maximum)for newly hired employees on their date of hire with no extended election window. Strategic Plan re-In GOAL THREE: Fiscal Responsibility Strategy 2—Ensure integrity and transparency in financial management GOAL FOUR: Workforce Development Strategy 2—Foster relationships across all levels of Central San ATTACHMENTS: 1. 401 a Plan Adoption Agreement (Amended) 2. 401 a Plan Adoption Agreement-Appendix A (changes in red) May 5, 2022 Regular Board Meeting Agenda Packet- Page 93 of 261 Page 5 of 18 Attachment 1 ICMA Retirement Corporation doing business as MissionSquare Retirement Governmental Loney Purchase Plan Adoption Agreement Missit.u-,enSquare RETIREMENT May 5, 2022 Regular Board Meeting Agenda Packet- Page 94 of 261 Page 6 of 18 MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement Plan Number 10-9623 The Employer hereby establishes a Money Purchase Plan to be known as: Central Contra Costa Sanitary District 401(a) Plan (the"Plan")in the form of the MissionSquare Retirement Governmental Money Purchase Plan. New Plan or Amendment and Restatement(Check One): ® Amendment and Restatement This Plan is an amendment and restatement of an existing defined contribution money purchase plan. Please specify the name of the defined contribution money purchase plan which this Plan hereby amends and restates: Central Contra Costa San! Dist Effective Date of Restatement.The effective date of the Plan shall be: February 1. 2022 (Note:The effective date can be no earlier than the first day of the Plan Year in which this restatement is adopted. If no date is provided, by default, the effective date will be the first day of the Plan Year in which the restatement is adopted.) ❑ New Plan Effective Date of New Plan.The effective date of the Plan shall be the first day of the Plan Year during which the Employer adopts the Plan, unless an alternate effective date is hereby specified: (Note:An alternate effective date can be no earlier than the first day of the Plan Year in which the Plan is adopted.) I. EMPLOYER:Central Contra Costa Sanitary District (The Employer must be a governmental entity under Internal Revenue Code§414(d)) 11. SPECIAL EFFECTIVE DATES Please note here any elections in the Adoption Agreement with an effective date that is different from that noted above. Required Mandatoa Contributions in Section V1.1.13 are effective 6pril 18,2022-See Appendix A. Employee Opt-In Mandatory Contributions in Section V1.1.13 are effective on Restatement adoption date. (Note:provision and effective date.) III. PLAN YEAR The Plan Year will be: V January 1 - December 31 (Default) ❑ The 12-month period ending: Month Day MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 2 May 5, 2022 Regular Board Meeting Agenda Packet- Page 95 of 261 Page 7 of 18 IV. Normal Retirement Age shall be age 50 (not less than 55 nor in excess of 65). Important Note to Employers: Normal Retirement Age is significant for determining the earliest date at which the Plan may allow for in-service distributions. Normal Retirement Age also defines the latest date at which a Participant must have a fully vested right to his/her Account.There are IRS rules that limit the age that may be specified as the Plan's Normal Retirement Age.The Normal Retirement Age cannot be earlier than what is reasonably representative of the typical retirement age for the industry in which the covered workforce is employed. In 2016, the Internal Revenue Service proposed regulations that would provide rules for determining whether a governmental pension plan's normal retirement age satisfies the Internal Revenue Code's qualification requirements.A normal retirement age that is age 62 or later is deemed to be not earlier than the earliest age that is reasonably representative of the typical retirement age for the industry in which the covered workforce is employed.Whether an age below 62 satisfies this requirement depends on the facts and circumstances, but an Employer's good faith, reasonable determination will generally be given deference.A special rule, however, says that a normal retirement age that is age 50 or later is deemed to be not earlier than the earliest age that is reasonably representative of the typical retirement age for the industry in which the covered workforce is employed if the participants to which this normal retirement age applies are qualified public safety employees(within the meaning of section 72(t)(1 0)(13)). These regulations are proposed to be effective for employees hired during plan years beginning on or after the later of: (1) January 1, 2017; or (2) the close of the first regular legislative session of the legislative body with the authority to amend the plan that begins on or after the date that is 3 months after the final regulations are published in the Federal Register. In the meantime, however, governmental plan sponsors may rely on these proposed regulations. In lieu of age-based Normal Retirement Age, the Plan shall use the following age and service-based Normal Retirement Age Important Note to Employers:Before using a Normal Retirement Age based on age and service, a plan sponsor should review the proposed regulations(81 Fed. Reg.4599(Jan.27,2016))and consult counsel. V. COVERED EMPLOYMENT CLASSIFICATIONS 1. The following group or groups of Employees are eligible to participate in the plan: ❑ All Employees ❑ All Full Time Employees ❑ Salaried Employees ❑ Non-union Employees ❑ Management Employees ❑ Public Safety Employees ❑ General Employees ® Other Employees(Specify the groups)of eligible Employees below. Do notspecify Employees by name. Specific positions are acceptable.),See groups listed in Appendix A The group specified must correspond to a group of the same designation that is defined in the statutes, ordinances, rules, regulations, personnel manuals, or other material in effect in the state or locality of the Employer.The eligibility requirements cannot be such that an Employee becomes eligible only in the Plan Year in which the Employee terminates employment. Note: As stated in Sections 4.08 and 4.09, the Plan may, however, provide that Final Pay Contributions or Accrued Leave Contributions are the only contributions made under the Plan. MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 3 May 5, 2022 Regular Board Meeting Agenda Packet- Page 96 of 261 Page 8 of 18 2. Period of Service required for participation ® N/A — The Employer hereby waives the requirement of a Period of Service for participation. Employees are eligible to participate upon employment. ("N/A"is the default provision under the Plan if no selection is made.) ❑ Yes.The required Period of Service shall be months(not to exceed 12 months.) The Period of Service selected by the Employer shall apply to all Employees within the Covered Employment Classification. 3. Minimum Age (Select One) - A minimum age requirement is hereby specified for eligibility to participate. ❑ Yes.Age not to exceed age 21.) ® N/A—No minimum age applies("N/A"is the default provision under the Plan if no selection is made.) VI. CONTRIBUTION PROVISIONS 1. The Employer shall contribute as follows:(Choose all that apply, but at least one of Options A or B. If Option A is not selected, Employer must pick up Mandatory Participant Contributions under Option B.) Fixed Employer Contributions With or Without Mandatory Participant Contributions. (If Option B is chosen, please complete section C.) IZI A. Fixed Employer Contributions.The Employer shall contribute on behalf of each Participant See App. A %of Earnings or$ forthe Plan Year(subjectto the limitations of Article V of the Plan). Mandatory Participant Contributions ❑ are required ®are not required to be eligible for this Employer Contribution. ® B. Mandatory Participant Contributions for Plan Participation, Required Mandatory Contributions. A Participant is required to contribute (subject to the limitations of Article V of the Plan)the specified amounts designated in items(i)through (iii) of the Contribution Schedule below: 0 Yes ❑ No Employee Opt-In Mandatory Contributions. To the extent that Mandatory Participant Contributions are not required by the Plan, each Employee eligible to participate in the Plan shall be given the opportunity when first eligible to participate in the Plan or any other plan or arrangement of the Employer described in Code section 219(g)(5)(A), to irrevocably elect to contribute Mandatory Participant Contributions by electing to contribute the specified amounts designated in items (i) through (iii) of the Contribution Schedule below for each Plan Year (subject to the limitations of Article V of the Plan): ®Yes ❑ No MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 4 May 5, 2022 Regular Board Meeting Agenda Packet- Page 97 of 261 Page 9 of 18 Contribution Schedule (Any percentage or dollar amount entered below must be greater than 0%or$0.) i, See App-A%of Earnings, ii. $ or a whole percentage of Earnings between the range of 1-20% (insert range of percentages between 1%and 20%inclusive(e.g.,3%6%, or 20%;5%to 7%)),as designated by the Employee in accordance with guide- lines and procedures established by the Employer for the Plan Year as a condition of participation in the Plan.A Participant must pick a single percentage and shall not have the right to discontinue or vary the rate of such contributions after becoming a Plan Participant. Employer "Pick up". The Employer hereby elects to "pick up" the Mandatory Participant Contributions' (pick up is required if Option A is not selected). ®Yes ❑ No ("Yes"is the default provision under the Plan if no selection is made.) 0 C. Election Window(Complete if Option B is selected:) Newly eligible Employees shall be provided an election window of 1 days(no more than 60 calendar-days) from the date of initial eligibility during which they may make the election to participate in the Mandatory Participant Contribution portion of the Plan. Participation in the Mandatory Participant Contribution portion of the Plan shall begin the first of the month following the end of the election window. An Employee's election is irrevocable and shall remain in force until the Employee terminates employment or ceases to be eligible to participate in the Plan. In the event of re-employment to an eligible position,the Employee's original election will resume.In no event does the Employee have the option of receiving the pick-up contribution amount directly. 2. The Employer may also elect to make Employer Matching Contributions as follows: ❑ Fixed Employer Match of After-Tax Voluntary Participant Contributions.(Do not complete this section unless the Plan permits after-tax Voluntary Participant Contributions under Section VI.3 of the Adoption Agreement.). The Employer shall contribute on behalf of each Participant % of Earnings for the Plan Year (subject to the limitations of Article V of the Plan) for each Plan Year that such Participant has contributed-%of Earnings or$ . Under this option, there is a single,fixed rate of Employer Contributions, but a Participant may decline to make the Voluntary Participant Contributions in any Plan Year, in which case no Employer Contribution will be made on the Participant's behalf in that Plan Year. Neither an IRS opinion letter nor a determination letter issued to an adopting Employer is a ruling by the Internal Revenue Service that Participant contributions that are 'picked up" by the Employer are not includable in the Participant's gross income for federal income tax purposes. Pick-up contributions are not mandated to receive private letter rulings, however, if an adopting Employer wishes to receive a ruling on pick-up contributions, they may request one in accordance with Revenue Procedure 2012-4(or subsequent guidance). Mission5quare Retirement Governmental Money Purchase Plan Adoption Agreement 5 May 5, 2022 Regular Board Meeting Agenda Packet- Page 98 of 261 Page 10 of 18 ❑ Variable Employer Match of After-Tax Voluntary Participant Contributions. (Do not complete this section unless the Plan permits after-tax Voluntary Participant Contributions under section VI.3 of the Adoption Agreement.) The Employer shall contribute on behalf of each Participant an amount determined as follows (subject to the limitations of Article V of the Plan): of the Voluntary Participant Contributions made by the Participant for the Plan Year(not including Voluntary Participant Contributions exceeding % of Earnings or PLUS % of the contributions made by the Participant for the Plan Year in excess of those included in the above paragraph (but not including Voluntary Participant Contributions exceeding in the aggregate %of Earnings or$ J. Employer Matching Contributions on behalf of a Participant for a Plan Year shall not exceed $ or %of Earnings,whichever is❑ more or❑ less ❑ Fixed Employer Match of Participant 457(b) Plan Deferrals.The Employer shall contribute on behalf of each Participant % of Earnings for the Plan Year (subject to the limitations of Article V of the Plan)for each Plan Year that such Participant has deferred % of Earnings or$ to the Employer's 457(b) deferred compensation plan. Under this option,there is a single,fixed rate of Employer Contributions, but a Participant may decline to make the required 457(b) deferrals in any Plan Year, in which case no Employer Contribution will be made on the Participant's behalf in that Plan Year. ❑ Variable Employer Match of Participant 457(b)Plan Deferrals. The Employer shall contribute on behalf of each Participant an amount determined as follows (subject to the limitations of Article V of the Plan): %of the elective deferrals made by the Participant to the Employer's 457(b)plan for the Plan Year(not including Participant contributions exceeding % of Earnings or PLUS % of the elective deferrals made by the Participant to the Employer's 457(b) plan for the Plan Year in excess of those included in the above paragraph (but not including elective deferrals made by a Participant to the Employer's 457(b) plan exceeding in the aggregate %of Earnings or$ ). Employer Matching Contributions on behalf of a Participant for a Plan Year shall not exceed $ or %of Earnings,whichever is ❑ more or❑ less 3. Each Participant may make a Voluntary Participant Contribution,subject to the limitations of Section 4.06 and Article V of the Plan: ❑Yes m No ("No"is the default provision under the Plan if no selection is made.) 4. Employer contributions for a Plan Year shall be contributed to the Trust in accordance with the following payment schedule (no later than the 15th day of the tenth calendar month following the end of the calendar year or fiscal year(as applicable depending on the basis on which the Employer keeps its books) with or within which the particular Limitation Year ends, or in accordance with applicable law): ❑Weekly 0 Biweekly ❑ Monthly ❑Annually in: Specify Month MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 6 May 5, 2022 Regular Board Meeting Agenda Packet- Page 99 of 261 Page 11 of 18 5. Participant contributions for a Plan Year shall be contributed to the Trust in accordance with the following payment schedule (no later than the 15th day of the tenth calendar month following the end of the calendar year or fiscal year(as applicable depending on the basis on which the Employer keeps its books) with or within which the particular Limitation Year ends, or in accordance with applicable law): ❑Weekly 10 Biweekly ❑ Monthly ❑Annually in: Specify Month 6. In the case of a Participant performing qualified military service(as defined in Code section 414(u)) with respect to the Employer: A. Plan contributions will be made based on differential wage payments: ®Yes ❑ No ("Yes"is the default provision under the Plan if no selection is made.) B. Participants who die or become disabled will receive Plan contributions with respect to such service: ❑Yes ® No ("No"is the default provision under the Plan if no selection is made.) VII. EARNINGS Earnings,as defined under Section 2.09 of the Plan,shall include: 1. Overtime Z Yes ❑ No ("No"is the default provision under the Plan if no selection is made.) 2. Bonuses ❑Yes ® No ("No"is the default provision under the Plan if no selection is made.) 3. Other Pay(specifically describe any other types of pay to be included below) VIII. ROLLOVER PROVISIONS 1. The Employer will permit Rollover Contributions in accordance with Section 4.13 of the Plan: [ZI Yes ❑ No ("Yes"is the default provision under the Plan if no selection is made.) MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 7 May 5, 2022 Regular Board Meeting Agenda Packet- Page 100 of 261 Page 12 of 18 IX. LIMITATION ON ALLOCATIONS If the Employer maintains or ever maintained another qualified plan in which any Participant in this Plan is (or was) a participant or could possibly become a participant, the Employer hereby agrees to limit contributions to all such plans as provided herein, if necessary in order to avoid excess contributions(as described in Section 5.02 of the Plan). 1. If the Participant is covered under another qualified defined contribution plan maintained by the Employer,the provisions of Section 5.02(a)through(e)of the Plan will apply unless another method has been indicated below. ❑ Other Method. (Provide the method under which the plans will limit total Annual Additions to the Maximum Permissible Amount, and will properly reduce any Excess Amounts, in a manner that precludes Employer discretion.) 2. The Limitation Year is the following 12 consecutive month period: X. VESTING PROVISIONS The Employer hereby specifies the following vesting schedule, subject to (1) the Code's vesting requirements in effect on September 1, 1974 and(2)the concurrence of the Plan Administrator.(Forthe blanks below, enter the applicable percentage— from 0 to 100 (with no entry after the year in which 100%is entered), in ascending order.) The following vesting schedule may apply to a Participant's interest in his/her Employer Contribution Account. The vesting schedule does not apply to Mandatory Participant Contributions, Rollover Contributions, Voluntary Participant Contributions, Deductible Employee Contributions, Employee Designated Final Pay Contributions, and Employee Designated Accrued Leave Contributions, and the earnings thereon. Period of Service Completed Percent Vested Zero 100 One 100 % Two 100 Three 100 Four 100 % Five 100 Six 100 Seven 100 oda Eight 100 oda Nine 100 % Ten 100 MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 8 May 5, 2022 Regular Board Meeting Agenda Packet- Page 101 of 261 Page 13 of 18 XI. WITHDRAWALS AND LOANS 1. In-service distributions are permitted under the Plan after a Participant attains (select one of the below options): ❑ Normal Retirement Age VI Age 70'/z("70'/z" is the default provision under the Plan if no selection is made.) ❑ Alternate age(after Normal Retirement Age): ❑ Not permitted at any age 2. A Participant shall be deemed to have a severance from employment solely for purposes of eligibility to receive distributions from the Plan during any period the individual is performing service in the uniformed services for more than 30 days. ❑Yes IVI No ("Yes"is the default provision under the Plan if no selection is made.) 3. Tax-free distributions of up to$3,000 for the direct payment of Qualified Health Insurance Premiums for Eligible Retired Public Safety Officers are available underthe Plan. ❑Yes 0 No ("No"is the default provision under the Plan if no selection is made.) 4. In-service distributions of the Rollover Account are permitted under the Plan,as provided in Section 9.07. ❑Yes lZNo ("No"is the default provision under the Plan if no selection is made.) 5. Loans are permitted under the Plan, as provided in Article XIII of the Plan: ❑Yes [ZNo ("No"is the default provision under the Plan if no selection is made.) XII. SPOUSAL PROTECTION The Plan will provide the following level of spousal protection(select one): ❑ 1. Participant Directed Election. The normal form of payment of benefits under the Plan is a lump sum. The Participant can name any person(s) as the Beneficiary of the Plan, with no spousal consent required. ® 2. Beneficiary Spousal Consent Election(Article XII of the Plan will apply if option 2 is selected).The normal form of payment of benefits under the Plan is a lump sum. Up-on death, the surviving spouse is the Beneficiary, unless he or she consents to the Participant's naming another Beneficiary.('Beneficiary Spousal Consent Election"is the default provision under the Plan if no selection is made.) ❑ 3. QJSA Election (Article XVII). The normal form of payment of benefits under the Plan is a 50% qualified joint and survivor annuity with the spouse(or life annuity, if single). In the event of the Participant's death prior to commencing payments,the spouse will receive an annuity for his or her lifetime. (If option 3 is selected, the spousal consent requirements in Article XII of the Plan also will apply.) MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 9 May 5, 2022 Regular Board Meeting Agenda Packet- Page 102 of 261 Page 14 of 18 XIII. FINAL PAY CONTRIBUTIONS (Under the Plan's definitions, Earnings automatically include leave cashouts paid by the later of 2'/z months after severance from employment or the end of the calendar year. If the Plan will provide additional contributions based on the Participant's final paycheck attributable to Accrued Leave, please provide instructions in this section. Otherwise, leave this section blank.) The Plan will provide for Final Pay Contributions if either 1 or 2 below is selected.The following group of Employees shall be eligible for Final Pay Contributions: 1. Employees within the Covered Employment Classification identified in section V of the Adoption Agreement. ❑ 2. Other. (This must be a subset of the Covered Employment Classification identified in section V of the Adoption Agreement.) Final Pay shall be defined as(select one): ❑ A.Accrued unpaid vacation ❑ B.Accrued unpaid sick leave ❑ C.Accrued unpaid vacation and sick leave [ZI D. Other(insert definition of Final Pay— must be leave that Employee would have been able to use if employment had continued and must be bona fide vacation and/or sick leave): See appendix A Z 1. Employer Final Pay Contribution. The Employer shall contribute on behalf of each Participant See App. A%of their Final Pay to the Plan(subject to the limitations of Article V of the Plan). ❑ 2. Employee Designated Final Pay Contribution. Each Employee eligible to participate in the Plan shall be given the opportunity at enrollment to irrevocably elect to contribute % (insert fixed percentage of Final Pay to be contributed)or up to % (insert maximum percentage of Final Pay to be contributed)of Final Pay to the Plan(subjectto the limitations of Article V of the Plan). Once elected, an Employee's election shall remain in force and may not be revised or revoked. XIV. ACCRUED LEAVE CONTRIBUTIONS The Plan will provide for unpaid Accrued Leave Contributions annually if either 1 or 2 is selected below. The following group of Employees shall be eligible for Accrued Leave Contributions: ❑ 1. Employees within the Covered Employment Classification identified in section V of the Adoption Agreement. ❑ 2. Other. (This must be a subset of the Covered Employment Classification identified in section V of the Adoption Agreement.) MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 10 May 5, 2022 Regular Board Meeting Agenda Packet- Page 103 of 261 Page 15 of 18 Accrued Leave shall be defined as(select one): ❑ A. Accrued unpaid vacation ❑ B. Accrued unpaid sick leave ❑ C. Accrued unpaid vacation and sick leave ❑ D. Other(insert definition of Accrued Leave that is bona fide vacation and/or sick leave): ❑ 1. Employer Accrued Leave Contribution.The Employer shall contribute as follows(choose one of the following options): ❑ For each Plan Year,the Employer shall contribute on behalf of each eligible Participant the unused Accrued Leave in excess of (insert number of ❑ hours ❑ days ❑ weeks (check one))to the Plan(subject to the limitations of Article V of the Plan). ❑ For each Plan Year, the Employer shall contribute on behalf of each eligible Participant %of unused Accrued Leave to the Plan(subject to the limitations of Article V of the Plan). ❑ 2. Employee Designated Accrued Leave Contribution. Each eligible Participant shall be given the opportunity at enrollment to irrevocably elect to annually contribute_% (insert fixed percentage of unpaid Accrued Leave to be contributed)or up to %(insert maximum percentage of unpaid Accrued Leave to be contributed)of Accrued Leave to the Plan(subject to the limitations of Article V of the Plan).Once elected, an Employee's election shall remain in force and may not be revised or revoked. XV. The Employer hereby attests that it is a unit of state or local government or an agency or instrumentality of one or more units of state or local government. XVI. The Employer understands that this Adoption Agreement is to be used with only the MissionSquare Retirement Governmental Money Purchase Plan. This MissionSquare Retirement Governmental Money Purchase Plan is a restatement of a previous plan, which was submitted to the Internal Revenue Service for approval on December 31,2018 and received approval on June 30, 2020. The Plan Administrator will inform the Employer of any amendments to the Plan made pursuant to Section 14.05 of the Plan or of the discontinuance or abandonment of the Plan. The Employer understands that an amendment(s) made pursuant to Section 14.05 of the Plan will become effective within 30 days of notice of the amendment(s) unless the Employer notifies the Plan Administrator, in writing,that it disapproves of the amendment(s). If the Employer so disapproves,the Plan Administrator will be under no obligation to act as Administrator under the Plan. XVII. The Employer hereby appoints the ICMA Retirement Corporation, doing business as MissionSquare Retirement, as the Plan Administrator pursuant to the terms and conditions of the MISSIONSQUARE RETIREMENT GOVERNMENTAL MONEY PURCHASE PLAN. The Employer hereby agrees to the provisions of the Plan. MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 11 May 5, 2022 Regular Board Meeting Agenda Packet- Page 104 of 261 Page 16 of 18 XVIII. The Employer understands that it must complete a new Adoption Agreement upon first adoption of the Plan.Additionally, upon any modifications to a prior election, making of new elections, or restatements of the Plan, a new Adoption Agreement must be completed. The Employer hereby acknowledges it understands that failure to properly fill outthis Adoption Agreement may result in disqualification of the Plan. XIX. An adopting Employer may rely on an Opinion Letter issued by the Internal Revenue Service as evidence that the Plan is qualified under section 401 of the Internal Revenue Code only to the extent provided in Rev. Proc. 2017-41.The Employer may not rely on the Opinion Letter in certain other circumstances or with respect to certain qualification requirements, which are specified in the Opinion Letter issued with respect to the Plan and in Rev. Proc.2017-41. In Witness Whereof, the Employer hereby causes this Money Purchase Plan Adoption Agreement to be executed. EMPLOYER SIGNATURE&DATE Signature of Authorized Plan Representative: Print Name: T. Kevin Mizuno Title: Finance Manager/Plan Administrator Attest: Date: 05 / 05 2022 Month Day Year For inquiries regarding adoption of the plan,the meaning of plan provisions,orthe effect of the Opinion Letter, contact: MissionSquare Retirement 777 N.Capitol St. NE Suite 600 Washington, DC 20002 800-326-7272 52582-0621-W1303 MissionSquare Retirement Governmental Money Purchase Plan Adoption Agreement 12 May 5, 2022 Regular Board Meeting Agenda Packet- Page 105 of 261 Page 17 of 18 Attachment 2 APPENDIX A CENTRAL CONTRA COSTA SANITARY DISTRICT 401(A) MONEY PURCHASE PLAN & TRUST COVERED EMPLOYMENT CLASSIFICATIONS Section V—Covered Employment Classifications: Employees in the following classifications are eligible to participate in the Plan: Employees who are represented by the Employees' Association, Public Employees Union, Local 1 (Local 1), the Management Support/Confidential Group (MS/CG), and the Management Group (Management), Unrepresented At-Will Employees (Unrepresented At-Will), and the General Manager. CONTRIBUTIONS Section VIA.A—Fixed Employer Contributions: The Employer shall contribute to the Plan each payroll period on behalf of each Participant hired by the Employer before April 1, 1986, the equivalent of the Social Security maximum (Employer portion), including the Medicare percentage, and for each Participant hired on or after April 1, 1986,the Social Security maximum (employer portion) excluding Medicare percentage. For the General Manager only,the Employer shall also contribute to the Plan for the 2021 Plan Year a one-time contribution of$33,423.50. The Employer shall contribute $400 each month to the Plan on behalf of each Participant who is not enrolled in Employer-provided group health plan coverage because the Participant is enrolled in other group health plan coverage. Section V1.1.6—Required Mandatory Contributions: Effective April 18, 2022, Participants who are Unrepresented At-Will Employees shall be required to contribute Required Mandatory Contributions by pre-tax salary reduction picked up by the Employer equal to the percentage of base pay specified in the table below: Employee Attributes as of 2022 Unrepresented Salary Contribution Resolution Adoption Date: Annual compensation exceeding$200,000, but not exceeding 8%of base pay each pay period $250,000 Annual compensation exceeding$250,000 12.5%of base pay each pay period Annual compensation of less than $200,000 2%of base pay each pay period May 5, 2022 Regular Board Meeting Agenda Packet- Page 106 of 261 Page 18 of 18 Appendix A—Page 2 of 2 TERMINAL COMPENSATION Section XIII—Final Pay Contributions: A portion of each Participant's Terminal Compensation shall be contributed by the Employer upon termination of the Participant's employment with the Employer based on the Participant's Bargaining Group as follows: Bargaining Group Terminal Compensation Portion of the Participant's Terminal Compensation to be Contributed by the Employer Local 1 More than $10,000 50% Between $5,000 and $10,000 25% Less than $5,000 0% MS/CG, Management, and Not specified 100% Unrepresented At-Will For purposes of this Appendix A,the term Terminal Compensation shall mean a Participant's accrued unused vacation, sick leave, earned overtime, and holiday comp pay (to the extent of the amount any of the preceding are payable to employees upon termination per the relevant MOU or resolution). May 5, 2022 Regular Board Meeting Agenda Packet- Page 107 of 261