 Summary Plan Description
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| What is the Bank's responsibility for distribution of the summary plan description? |
| ERISA requires the Plan Administrator of every welfare benefit plan to give a Summary Plan Description ("SPD") to each participant. Under the Plan, each Plan Sponsor (usually, the Bank or Bank Holding Company) is the Plan Administrator for its Plan. As such, the Plan Sponsor is responsible for compliance with this requirement. Federal regulations specify the information to be included in the SPD. The SPD replaces the need for a seperate initial COBRA notice for plans with medical, dental, or vision benefits. Thus, special distribution requirements apply.
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| What consitutes the form SPD? |
| A complete Summary Plan Description for a Plan includes both the completed form SPD document with any Appendices and the Plan booklet for any benefits adopted. The Bank's legal counsel should review the form. |
How is the form SPD completed? |
The Plan Sponsor should refer to its Plan Document and do the following:
- The name of the Plan Sponsor should be filled in on the title page.
- Complete Section II.A.
- A plan number must be assigned to each Plan under Section II.A. Plan numbers are assigned consecutively beginning with 501. If numbers have not been assigned, a Plan should be numbered 501 unless that number has been used for a different plan of the Bank.
- Note the part of Section II.A entitled: "STATUS OF EMPLOYER AS "SMALL EMPLOYER" UNDER THE MEDICARE SECONDARY PAYER RULES" (required to be completed
by Plan Sponsors with medical benefits under the Trust.) (Refer to the Plan Document Section 4.2, Appendix M, if completed, and the Medicare Secondary Payer
Section of the manual.) Generally, the Plan Sponsor will check the first blank (No Small Employer Election) if the Plan Sponsor (and related employers, if any) have more
than 20 employees or if the Plan Sponsor executed Appendix M. Otherwise, if the Small Employer has qualified for and elected "small employer" status, check the
second blank (Small Employer Election). Contact the EBC staff with questions.
- Complete the "COBRA DESIGNATIONS" part of Section II.A if the Plan has medical, dental or vision benefits under the Trust. Complete in accordance with your COBRA forms.
Please keep the information current.
- If the SPD is used for a controlled group of employers, the Attachment to the SPD listing all of the participating employers should be completed. Refer to Appendix A
of the Plan Document when completing this Attachment.
- Add Appendix E and R or D if adopted as part of the Plan Document. Add Appendix C if the Bank provides medical, dental, or vision benefits under the Trust.
- Copy each completed SPD form with the appropriate Appendix (E,R, or D) for distribution with benefit booklets to each participant and other individuals as described below. Add
Appendix C if medical, dental, or vision benefits are offered.
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| Who should receive the SPD? |
| Upon completion fo the Summary Plan Description form for a Plan, a copy of it, the applicable Attachments and Appendices, and the Plan blooklet must be given to each eligible employee
or participant, COBRA qualified beneficiary, QMCSO alternate recipient, spouse/dependent of deceased participant (if they continue to receive benefits), and representatives or guardians of
incapacitated person in that Plan. If the Plan has medical, dental, or vision benefits, the spouse of the employee or participant also must receive the SPD. See Special Distribution Requirments for SPDs.
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