FLORIDA INTERNATIONAL UNIVERSITY 403(B) RETIREMENT PLANCOMMITTEE MEETING MINUTESLOCATION:

Via Zoom as described in the mee琀椀ng pos琀椀ng

DATE:April 12th, 2023,

Time:

10:30 pm – 12:30 pm ET

A琀琀endees:

Liz Marston, Senior University Counsel Facilitator)
El pagnier Hudson, Senior Vice-President, Human Resources/DEI
Aime Mar琀椀nez, Interim Chief Financial O昀케cer and Senior Vice President
Carlos A. Flores, Associate Vice President of Opera琀椀ons, Compliance & Systems
Benjamin P. Jarrell, University Treasurer
Carlos Cas琀椀llo, General Counsel

CAPTRUST A琀琀endees:
Shaun Eskamani, Principal, Financial Advisor
Corey Moore, Client Management Specialist
Michael Webb, Senior Manager l Plan Consul琀椀ng
Other FIU A琀琀endees:
Crystal Hsu, Associate Director, Bene昀椀ts
Mariela Varona, Bene昀椀ts ManagerPrior Business
The Commi琀琀ee reviewed the previous mee琀椀ng minutes from December 16, 2021.
They were approved via mo琀椀on by the Commi琀琀ee.
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New Business
The members of the Commi琀琀ee were introduced as were the members of theCAPTRUST team.
Fiduciary Process
The 5 pillars of a successful 403(b) document were brie昀氀y reviewed. These topics
include the 昀椀duciary process, plan design, investment management, vendor
management and par琀椀cipant engagement.
CAPTRUST discussed the discre琀椀onary services overview, which shows the two 昀椀duciaryop琀椀ons available to clients: 3(21) non-discre琀椀onary advisor service and a 3(38)discre琀椀onary investment manager. The di昀昀erences were reviewed and can be discussed
again at a later date should the Commi琀琀ee choose to.
Plan Informa琀椀on Summary Review
CAPTRUST reviewed the Plan Informa琀椀on Summary, no琀椀ng that the plans with themost assets and par琀椀cipants with a balance are at TIAA, Voya, and Fidelity. Manyof the smaller providers have par琀椀cipants in individual annui琀椀es that are not
mappable to mutual funds or to group annui琀椀es. CAPTRUST will check with Voyato see if they are retained as a provider, would any of the assets be able to bemapped to either mutual funds, or into a group annuity.
The Commi琀琀ee asked about vendors with revenue sharing accounts. CAPTRUST
discussed ERISA accounts, returning fees to par琀椀cipants and other op琀椀ons that will
be reviewed in more detail as a part of the RFP process.
CAPTRUST is hoping to help the plan save on fees as a 昀椀duciary best prac琀椀ce withthe vendor consolida琀椀on.
Provider Request for Proposal (RFP) and Selec琀椀on Process
The RFP Process is broken up into 4 phases: Development, Response & Evaluation,Selection, and Implementation.
The first step to get the RFP process going is for CAPTRUST to send the RFP checklist
to the vendors, allowing a few weeks for completion. Once CAPTRUST receives theinitial data back, CAPTRUST’S internal vendor team, will reach out to the providers
for more information and pricing proposals.
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The RFP will ask for three separate pricing op琀椀ons from the providers. 1. as a lead
recordkeeper (one of three), 2. as a lead recordkeeper (one of two), or 3. as one lead,and only ac琀椀ve recordkeeper. The thought is that with the RFP, the Commi琀琀ee would
choose a lead recordkeeper, keeping at least two providers and freeze some of thesmaller remaining providers.
The Commi琀琀ee approved that CAPTRUST will send out the ini琀椀al checklist to theircurrent providers and begin the RFP process.
Fiduciary TrainingCAPTRUST reviewed the Fiduciary training manual for the Commi琀琀ee. This review
includes duty to be prudent, duty of loyalty and impar琀椀ality, duty to diversify, duty tomonitor and supervise, duty to ensure reasonable plan cost, and duty to avoid
prohibited transac琀椀ons. The fee guidelines were reviewed, in that the RFP will include
a ques琀椀on on revenue sharing, the op琀椀on for a portable ERISA account and the op琀椀onto return the fees to the par琀椀cipants who created them. Other items discussed weremaking sure the current plan documents are signed and all providers have the currentversion, the 昀椀delity bond is up to date, that their 昀椀duciary liability coverage issu昀케cient and the need to 昀椀nalize the Commi琀琀ee Charter.
Plan Amendments
The Committee reviewed plan amendments that need to be voted on. The plancurrently has a prototype plan provider, which provided an IRS determination letter.
The plan document is now out of compliance and needs to be amended in thefollowing fashion.
Section 2.1 Termination of deferral suspension. FIU can no longer suspend aparticipant’s deferrals if the participant takes a hardship distribution. This was amandatory change.
Section 2.2 Hardship needs/events. This amendment sets forth when the residential
casualty loss and new disaster loss provisions are effective.
Section 3.1 Modification of hardship necessity provisions. The participant must
provide a certification to the Plan Administrator that the participant has obtained allother currently available distributions under the plan and all other plans (qualified
and non-qualified), except hardship withdrawals and has insufficient cash or otherliquid assets reasonably available to satisfy the need. This is a mandatory change
except this new certification can still require the participant to first obtain a loan or
the loan requirement can be eliminated. The Committee voted to not force
participants to take a loan before a hardship distribution.
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Section 3.2 Residential casualty loss. The Plan already permits a distribution to repair
a participant’s primary residence due to a casualty loss. The amendment merely
clarifies that the casualty loss to the participant’s principal residence must qualify fora loss deduction under Code Section 165, but a Federally Declared Disaster does nothave to be declared for the participant to obtain a hardship withdrawal for this reason.
In other words, the provisions of Code Section 165(h)(5) do not apply. Thisamendment was a clarification requiring no Committee decision.
Section 4.4 Disaster Losses. This is a new safe harbor hardship that can be added tothe Plan. This covers expenses and losses, including loss of income, incurred by aparticipant due to a Federally Declared Disaster (now defined in the amendment) if
the participant’s primary residence or principal place of employment at the time is in
the area of the Federally Declared Disaster. The Committee voted to include this newsafe harbor.
Charter Amendment
The Committee reviewed the Charter and the updates that need to be made to theCommittee Structure. The Committee voted unanimously in favor. Liz will update andforward to the Committee for approval. Once the Charter has been approved, theCommittee will send a copy to CAPTRUST for their records.
The Commi琀琀ee reviewed the current assets in the Revenue Credit Account and notedthat CAPTRUST’s quarterly fees are paid out of that account.
Action Items:
1)

CAPTRUST to draft the meeting minutes for Committee review andapproval, then upload to CAPTRUST Direct (online fiduciary portal)

2)

CAPTRUST find out if the assets at Voya could be mapped if they areretained as a vendor after the RFP

3)

CAPTRUST to send out the initial checklist to vendors and begin the RFP
process

Concluding Remarks and Adjournment
Ms. Mar琀椀nez concluded the mee琀椀ng at 12:30 p.m.

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