Investment Policy Statement
The following document is in two sections. Please click the bookmark at left that refers to your specific retirement plan.
SECTION 1: Trustee 401(k) Plan (Capital Accumulation Plan)
SECTION 2: Trustee Money Purchase Pension Plan (Retirement Savings Fund/RSF)
Investment Policy Statement Trustee 401(k) Plan (Capital Accumulation Plan)
INTRODUCTION CUNA Mutual Insurance Society (“CUNA Mutual”) is the sponsor of a defined contribution retirement plan program for employers that desire to maintain 401(k) plans for their employees. This program, marketed under the name “Trustee 401(k) Program,” offers adopting employers plan administration services, document services and a portfolio of investments selected by named trustees. The trustees, who are appointed by CUNA Mutual, serve as discretionary trustees for each 401(k) plan of an employer that adopts the Trustee 401(k) Plan. The formal name of each plan adopted by an employer is the “Capital Accumulation Plan.” In fulfilling their duties as discretionary trustees, the trustees have adopted this Investment Policy Statement (IPS) relating to the investments they select to be offered under the Trustee 401(k) Plan. This IPS is not intended to be a substitute for the adopting employer’s own investment policy statement, and each adopting employer has a fiduciary duty under ERISA to determine whether the investments offered under the Trustee 401(k) Plan are appropriate for its own employees. Throughout this IPS, references to “Plan” are intended to refer to the Trustee 401(k) Plan, as a CUNA Mutual-sponsored program, and not to each adopting employer’s 401(k) plan. This IPS is set forth to: 1. Define the investment policies, guidelines and objectives of the CUNA Mutual Trustee 401(k) Plan. 2. Create a framework from which the Trustees can evaluate performance and review participant options. 3. Provide guidance for, expectations of, and limitations on all parties bearing responsibilities related to the Plan. The intent of this statement is to design an investment environment with specific parameters that reflects the philosophy of the Trustees, thereby providing all parties with clearly defined policies and objectives. Although these policies and objectives are intended to govern the investment activity, they are designed to be sufficiently flexible in order to be practical. The Plan's investment funds will be selected and monitored with the skill, care and diligence that a prudent individual acting in a like capacity would undertake and in accordance with all other aspects of applicable law, including the requirements of the Employee Retirement Income Security Act of 1974 (ERISA), as amended, and Sections 401(a) and 501(a) of the Internal Revenue Code of 1986 (Code), as amended. The Plan is intended to qualify under the qualified cash or deferred arrangement rules of Code Section 401(k). The Plan is a participant-directed individual account plan. As such, it provides for plan participants to select and direct salary deferrals, any employer matches, and existing account assets in their individual accounts. No fiduciary shall be liable for any loss that results from a participant's exercise of control over the investment of his or her participant accounts.
PURPOSE The purpose of this document is to define the investment policy for the Plan. Individual employers should adopt an IPS for their own plan, and are responsible for determining whether the Trustees’ investment philosophy and oversight processes are appropriate for their individual plans. This document will identify a set of investment objectives and guidelines for the assets of the Plan. It provides guidance for the following: •
The number and type of investment options offered;
•
The choice of investment vehicles to fund the investment options;
•
The ongoing supervision of Plan assets, including responsibility for: o
The review of the investment options and investment characteristics of the investment vehicles offered.
o
Monitoring the actual investment vehicles offered.
o
Decisions regarding the addition, replacement or elimination of the actual investment vehicles offered.
ROLES AND RESPONSIBILITIES Trustees With respect to management of the Plan’s investments, the Trustees’ responsibilities encompass the following: •
Developing an investment program that offers a diversified range of funds;
•
Identifying investment options (i.e., types of funds) which they deem appropriate and prudent (including options that are “qualified default investment alternatives”), and which can be held in a plan without jeopardizing its qualified status or violating ERISA;
•
Selecting qualified investment managers and/or funds which fulfill the criteria of the identified investment options;
•
Monitoring investment results by means of regular reviews and analyses to determine whether those responsible for investment results are meeting the guidelines and criteria identified in this IPS;
•
Deciding whether, and taking appropriate action if, objectives are not being met or if policies and guidelines are not being followed.
Recordkeeper The Recordkeeper will track plan assets and participant accounts in addition to the following responsibilities: •
Investing and divestiture of plan assets among the selected investment funds as directed by the Trustees and/or plan participants to the degree and extent to which plan participants are permitted to direct investments;
2
INVESTMENT POLICY STATEMENT Trustee 401(k) Plan (Capital Accumulation Plan)
•
Providing employers with monthly statements detailing their respective plan assets and transactions;
•
Performing required participant notification, tax withholding and deposit, direct rollover, and other requirements relating to plan distributions;
•
Providing plan participants with prospectuses, confirmations, and other information;
•
Other duties and services as set forth in its Administrative Services Agreement with each respective employer.
Investment Consultant The Trustees may retain the services of a third-party Investment Consultant (“Consultant”) to provide expert advice and recommendations to help the Trustees discharge their fiduciary responsibilities in furtherance of the Plan’s goals and objectives. Such services provided by the Consultant will include the following: •
Monitoring of long-term capital market trends.
•
Periodic review of investment policies and objectives, and suggestion of appropriate changes.
•
Research and recommendation of investment management firms, which are appropriate for implementation of the Plan’s investment policies and objectives.
•
Measurement, evaluation and reporting of the Investment Managers’ performance results.
GOALS AND OBJECTIVES The investment objective of the Plan is to offer a set of investment options such that: •
Plan participants are able to invest in, or build, portfolios consistent with their investment risk/return preferences;
3
•
A “Qualified Default Investment Alternative” is offered as an option;
•
Each option is adequately diversified;
•
Each option has a risk profile consistent with its position in the overall structure;
•
Each option is provided at a reasonable cost;
•
No option has major governance or operational deficiencies.
INVESTMENT POLICY STATEMENT Trustee 401(k) Plan (Capital Accumulation Plan)
REVIEW OF INVESTMENT OBJECTIVES AND POLICY The Trustees will review the achievement of investment objectives periodically. The review will focus on the continuing feasibility of achieving the objectives and the continued appropriateness of the IPS. It is not expected that the IPS will change frequently; in particular, short-term changes in the financial markets generally should not require an adjustment in the investment policy.
As a general rule, the IPS should be reviewed annually. Some occurrences which might suggest to the Trustees an earlier review are: •
Changes in the overall marketplace;
•
The availability of acceptable new asset classes;
•
The passage of relevant new legislation or regulations;
•
Policy issues identified by the Trustees.
CONFLICT OF INTEREST All persons responsible for investment decisions or who are involved in the management of the Plan or who are consulting to, or providing any advice whatsoever, to the Trustees shall disclose in writing at the beginning of any discussion or consideration by the Trustees, any relationships providing material benefit, which the person has or may reasonably be expected to have, with respect to any investment issue under consideration. The Trustees may require such persons to remove themselves from the decision-making process.
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INVESTMENT POLICY STATEMENT Trustee 401(k) Plan (Capital Accumulation Plan)
10001334-0610 TRUSTEE PROGRAM INVESTMENT POLICY STATEMENT © CUNA Mutual Group
Investment Policy Statement Trustee Money Purchase Pension Plan (Retirement Savings Fund)
INTRODUCTION CUNA Mutual Insurance Society (“CUNA Mutual”) is the sponsor of a defined contribution retirement plan program for employers that desire to maintain money purchase pension plans for their employees. This program, marketed under the name “Trustee Money Purchase Pension Plan,” offers adopting employers plan administration services, document services and a portfolio of investments selected by named trustees. The trustees, who are appointed by CUNA Mutual, serve as discretionary trustees for each money purchase pension plan of an employer that adopts the Trustee Money Purchase Pension Plan. The formal name of each plan adopted by an employer is the “Retirement Savings Fund.” In fulfilling their duties as discretionary trustees, the trustees have adopted this Investment Policy Statement (IPS) relating to the investments they select to be offered under the Trustee Money Purchase Pension Plan. This IPS is not intended to be a substitute for the adopting employer’s own investment policy statement, and each adopting employer has a fiduciary duty under ERISA to determine whether the investments offered under the Trustee Money Purchase Pension Plan are appropriate for its own employees. Throughout this IPS, references to “Plan” are intended to refer to the Trustee Money Purchase Pension Plan, as a CUNA Mutual-sponsored program, and not to each adopting employer’s money purchase pension plan. This IPS is set forth to: 1. Define the investment policies, guidelines and objectives of the CUNA Mutual Trustee Money Purchase Pension Plan. 2. Create a framework from which the Trustees can evaluate performance and review participant options. 3. Provide guidance for, expectations of, and limitations on all parties bearing responsibilities related to the Plan. The intent of this statement is to design an investment environment with specific parameters that reflects the philosophy of the Trustees, thereby providing all parties with clearly defined policies and objectives. Although these policies and objectives are intended to govern the investment activity, they are designed to be sufficiently flexible in order to be practical. The Plan's investment funds will be selected and monitored with the skill, care and diligence that a prudent individual acting in a like capacity would undertake and in accordance with all other aspects of applicable law, including the requirements of the Employee Retirement Income Security Act of 1974 (ERISA), as amended, and Sections 401(a) and 501(a) of the Internal Revenue Code of 1986 (Code), as amended. The Plan is a participant-directed individual account plan. As such, it provides for plan participants to select and direct the investment of employer and employee contributions, and existing account assets in their individual accounts. No fiduciary shall be liable for any loss that results from a participant's exercise of control over the investment of his or her participant accounts.
PURPOSE The purpose of this document is to define the investment policy for the Plan. Individual employers should adopt an IPS for their own plan, and are responsible for determining whether the Trustees’ investment philosophy and oversight processes are appropriate for their individual plans. This document will identify a set of investment objectives and guidelines for the assets of the Plan. It provides guidance for the following: •
The number and type of investment options offered;
•
The choice of investment vehicles to fund the investment options;
•
The ongoing supervision of Plan assets, including responsibility for: o
The review of the investment options and investment characteristics of the investment vehicles offered.
o
Monitoring the actual investment vehicles offered.
o
Decisions regarding the addition, replacement, or elimination of the actual investment vehicles offered.
ROLES AND RESPONSIBILITIES Trustees With respect to management of the Plan’s investments, the Trustees’ responsibilities encompass the following: •
Developing an investment program that offers a diversified range of funds;
•
Identifying investment options (i.e. types of funds) which they deem appropriate and prudent (including options that are “qualified default investment alternatives”), and which can be held in a plan without jeopardizing its qualified status or violating ERISA;
•
Selecting qualified investment managers and/or funds which fulfill the criteria of the identified investment options;
•
Monitoring investment results by means of regular reviews and analyses to determine whether those responsible for investment results are meeting the guidelines and criteria identified in this IPS;
•
Deciding whether, and taking appropriate action if, objectives are not being met or if policies and guidelines are not being followed.
Recordkeeper The Recordkeeper will track plan assets and participant accounts in addition to the following responsibilities: •
Investing and divestiture of plan assets among the selected investment funds as directed by the Trustees and/or plan participants to the degree and extent to which plan participants are permitted to direct investments;
2
INVESTMENT POLICY STATEMENT Trustee Money Purchase Pension Plan
•
Providing employers with monthly statements detailing their respective plan assets and transactions;
•
Performing required participant notification, tax withholding and deposit, direct rollover, and other requirements relating to plan distributions;
•
Providing plan participants with prospectuses, confirmations, and other information;
•
Other duties and services as set forth in its Administrative Services Agreement with each respective employer.
Investment Consultant The Trustees may retain the services of a third-party Investment Consultant (“Consultant”) to provide expert advice and recommendations to help the Trustees discharge their fiduciary responsibilities in furtherance of the Plan’s goals and objectives. Such services provided by the Consultant will include the following: •
Monitoring of long-term capital market trends.
•
Periodic review of investment policies and objectives, and suggestion of appropriate changes.
•
Research and recommendation of investment management firms, which are appropriate for implementation of the Plan’s investment policies and objectives.
•
Measurement, evaluation and reporting of the Investment Managers’ performance results.
GOALS AND OBJECTIVES The investment objective of the Plan is to offer a set of investment options such that: •
Plan participants are able to invest in, or build, portfolios consistent with their investment risk/return preferences;
3
•
A “Qualified Default Investment Alternative” is offered as an option;
•
Each option is adequately diversified;
•
Each option has a risk profile consistent with its position in the overall structure;
•
Each option is provided at a reasonable cost;
•
No option has major governance or operational deficiencies.
INVESTMENT POLICY STATEMENT Trustee Money Purchase Pension Plan
REVIEW OF INVESTMENT OBJECTIVES AND POLICY The Trustees will review the achievement of investment objectives periodically. The review will focus on the continuing feasibility of achieving the objectives and the continued appropriateness of the IPS. It is not expected that the IPS will change frequently; in particular, short-term changes in the financial markets generally should not require an adjustment in the investment policy.
As a general rule, the IPS should be reviewed annually. Some occurrences which might suggest to the Trustees an earlier review are: •
Changes in the overall marketplace;
•
The availability of acceptable new asset classes;
•
The passage of relevant new legislation or regulations;
•
Policy issues identified by the Trustees.
CONFLICT OF INTEREST All persons responsible for investment decisions or who are involved in the management of the Plan or who are consulting to, or providing any advice whatsoever, to the Trustees shall disclose in writing at the beginning of any discussion or consideration by the Trustees, any relationships providing material benefit, which the person has or may reasonably be expected to have, with respect to any investment issue under consideration. The Trustees may require such persons to remove themselves from the decision-making process.
4
INVESTMENT POLICY STATEMENT Trustee Money Purchase Pension Plan
10001340-0610 © CUNA Mutual Group
