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Plan sponsor reportingand audit guideFor defined contribution retirement plans subject to ERISAA comprehensive resource for meeting annual reportingand fee disclosure requirementsPlan year 2021, version 1.0For institutional investor use only. Not for use with or distribution to the general public.
ContentsSection 1—IntroductionChapter 1: TIAA1.1Regulatory and accounting changes. 71.2What’s new for the 2021 reporting cycle. 71.3The plan sponsor reporting and audit guide (the Guide) . 71.4Proprietary annuity and mutual fund investments . 7Section 2—Plan sponsor guideChapter 2: Ongoing plan activities2.1Governance . 132.2Responsibilities of the plan administrator . 2.3.52.3.62.3.72.4Satisfying reporting and disclosure requirements .14Responsibilities as a plan fiduciary .14Managing fee disclosure requirements .14How TIAA helps plan fiduciaries meet their responsibilities .15Timing of annual participant fee disclosure—404a-5.16Overview of 2020 Form 5500 and Form 8955-SSA filing requirements. 16Form 5500 exemptions .17Form 5500 schedules .17Additional Schedule C information .18Additional required disclosure .18When to file Form 5500 and Form 8955-SSA .19How to file Form 5500.19How to file Form 8955-SSA.20Audit requirements. 202.4.1 Small plan audit waiver.202.4.2 Definition of “participant” .202.5Limited scope vs. full scope audit. 212.6Compliance calendar . 212.7Using PlanFocus. 222.8Online reporting . 232.9Online requests for documentation for selectedtransactions—Financial plan audits . 23Chapter 3: Plan year-end report package overview3.1Summary of reports . 243.2Obtaining plan financial reports using PlanFocus . 253.2.1 Comma-separated value (.csv) file format .25For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 2
3.3Timing of report distribution . 253.4Requesting secure access. 253.5Requesting plan reporting aggregation. 25Chapter 4: Report descriptions4.1Reporting changes for 2021 . 264.2Certified financial reports. 264.2.14.2.24.2.34.2.44.3Certification Statement .26Schedule of Assets Held for Investment .26Statement of Changes to Net Assets.27Footnotes to the Statement of Changes to Net Assets .28Supplemental financial reports . 294.3.1 Participant Detail Summary .294.3.2 Transaction History by Fund Report .294.3.3 Contribution Report .294.3.4 Loan Activity Report for Participant Loans .304.3.5 Loan Activity Report for Plan Loans .304.3.6 Outstanding Loan Report for Participant Loans .304.3.7 Outstanding Loan Report for Plan Loans .304.3.8 Distribution Report .304.3.9 Forfeiture Account Report .304.3.10 Transaction History by Date Report .314.3.11 New Loan Issued Report for Participant Loans .314.3.12 New Loan Issued Report for Plan Loans.314.3.13 Participant Contribution Investment Allocation Report.314.3.14 Plan ID Report .314.3.15 Plan to Plan Transfer Report .314.3.16 Revenue Credit Account Report .314.3.17 Plan Servicing Credit Report .324.3.18 Plan Service Fees and Credits by Participant Report .324.3.19 RetirePlus Investment Allocation Report .324.3.20 RetirePlus Usage Report .324.4Supplemental reports to support Form 5500 . 324.4.14.4.24.4.34.4.44.4.54.4.64.4.74.4.85500 Reportable—Schedule of Assets Held for Investment.325500 Reportable—Statement of Changes to Net Assets . 33Filing Summary for Schedule A . 33Filing Summary for Schedule C . 33Filing Summary for Schedule D . 33Filing Summary for Schedule H . 33Filing Summary for Schedule H, Line 4i. 33Filing Summary for Schedule I (may also be referred to as Filing Summaryfor Form 5500 SF) . 334.4.9 Participant Count Report . 344.4.10 5500 Reportable Transactions . 344.4.11 Form 8955-SSA Filing Summary . 34For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 3
4.5 Plan sponsor reports . 4.6.34.6.4Payroll Summary Report . 34Missing Dates Report (Birth, Hire, Rehire, Termination) . 34Nearing Retirement Age Report .35Distribution Tax Information Report .35Minimum Distribution Monitoring Report .35Small Cash Out Monitoring Report .35Fund Usage and Diversification Report .36Fee disclosure reports . 36Summary of Fees and Compensation for Your Plan .36Investment Fee & Expense Disclosure .36Direct Fees Paid from Plan Assets.36Service Provider Summary .36Section 3—Auditor guideChapter 5: Audit support services5.1Safe Harbor Attestation Letter . 385.2Access to PlanFocus . 385.2.1 Audit Support Resources in PlanFocus . 385.3Requests for additional information . 395.4Documentation for selected transactions . 395.4.1 Submitting “In Good Order” (IGO) requests . 405.4.2 Regulatory examination support services . 405.4.3 Documentation for regulatory plan examinations .415.5SECURE Act, CARES Act . 415.6Statement on Auditing Standards 136 . 41Chapter 6: Statement on Standards for Attestation Engagements6.1SSAE 18 reports, in general. 426.2TIAA’s SSAE 18 reports . 426.3TIAA, FSB financial controls . 436.4SOC 2 Reporting Relevant to Cybersecurity and Production AvailabilityControls for TIAA . 43Chapter 7: Disclosure information related to TIAA and CREF annuities and loans7.1TIAA Traditional Annuity . 437.1.1 TIAA Traditional Annuity . 447.1.2 TIAA Stable Value. 447.1.3 Reporting investments in the TIAA TraditionalAnnuity and TIAA Stable Value on Form 5500 . 44For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 4
7.2TIAA Real Estate Account. 457.2.1 Reporting investments in the REA on Form 5500 . 457.3CREF Accounts and TIAA Access Annuity . 457.3.1 Reporting investments in the CREF Accounts andTIAA Access on Form 5500. 457.4Plan asset valuation . 457.4.1 Frequency with which TIAA values plan assets . 457.4.2 Fair value measurements and disclosures . 467.5Participant loans vs. plan loans . 467.6Plan confirmation information. 46Frequently asked questionsFinancial statements . 49Form 5500 and Form 8955-SSA . 49Plan loans . 50Fee disclosures . 50General . 50Governance and internal controls. 50Plan terminations and plan mergers . 50AppendicesIndex to plan financials . 67Appendix A—Sample plan sponsor reporting package . 69Appendix B—Fee reports and disclosures .156Appendix C—Form 5500 Mapping .161Appendix D—Acronyms and abbreviations .166Appendix E—Illustrative formats for financial statements .167Appendix F—Model footnote disclosure for investments in TIAA Traditional Annuity .169Appendix G—Participant Count Report: Explanation of source data logic . 170Appendix H—TIAA proprietary investments . 173Appendix I—Fair value measurements and disclosures. 178Appendix J—TIAA Traditional benefit responsive/nonbenefit responsive chart .184TIAA has compiled this Guide to help answer some questions the plan sponsor, financial and legal advisors, orplan auditor may have during the ERISA reporting process for a qualified plan or a 403(b) plan subject to ERISA.For answers to questions not addressed in this Guide, call TIAA at 888-842-7782.For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 5
Section 1IntroductionFor institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 6
WSample annual plan financial report package(see Appendix A)WSample fee disclosure reports and disclosures(see Appendix B)Providing retirement plan solutions for the academic,medical, cultural and research communitiesWMapping logic for all Form 5500 filing summaries(see Appendix C)Significant regulatory and accounting changes that mayimpact plan sponsors and their auditors have beenenacted in recent years.WSample plan-level financial statements(see Appendix E)WAssistance on completing the participant countsection of Form 5500 and Form 5500-SF(see Appendix G)WTicker symbols for TIAA proprietary investments(see Appendix H)WAccounting Standards Codification Topic 820,Fair value measurements and disclosures(see Appendix I)WTIAA Traditional benefit responsive/nonbenefitresponsive chart (see Appendix J)Chapter 1TIAA1.1 Regulatory and accounting changesSAS 136 is a new auditing standard that is effective foraudits of ERISA plan financial statements for periodsending on or after December 15, 2021. This means mostplan sponsors will see the impact of the new standard fortheir 2021 year end audits completed in 2022. Pleasereview Section 5.6 “Statement on Auditing Standards 136”for details.1.2 What’s new for the 2021 reporting cycleThere are several material changes to the Certified PlanFinancial Reporting package. Enhancements were madeto the Statement of Changes to Net Assets report, theContribution report, the Participant Count report and theTransaction History reports.Please review Section 4.1 “Reporting changes for 2021” onpage 26 for details regarding these changes.1.3 The plan sponsor reporting and audit guide(the Guide)This Guide provides the information needed to supportstandard plan financial reporting and auditing for an ERISAdefined contribution retirement plan funded, in whole orin part, by investment products provided by TIAA, CollegeRetirement Equities Fund (CREF), Nuveen Investmentsor any other investment product recordkept by TIAA. It isseparated into two separate and distinct sections—Plansponsor guide (Section 2) and Audit guide (Section 3).The Guide includes:WYear-end and regulatory reporting requirements, anoverview of the reporting data that TIAA provides, anddescriptions and samples of the TIAA reportsWRequirements and resources for meeting annualDepartment of Labor (DOL) fee disclosure requirementsWAn overview of audit guidelines, information on theSSAE 18 Service Organizations Control (SOC) 1 report,and reporting information relating to TIAA, CREF and TIAAinvestment productsWFrequently asked questionsTIAA is available to work directly with plan sponsors—aloneor with any plan intermediaries that may be engaged—toreview the Guide and offer assistance when needed.Contact your TIAA representative or, if served by theAdministrator Telephone Center, contact a TIAA InstitutionalConsultant at 888-842-7782.TIAA will supplement this Guide through a variety ofcommunications designed to brief the plan sponsor on anyfurther clarifications concerning changes in the regulatoryenvironment and provide continuing practical guidance.These will include educational materials, webinars,workshops, along with regular communications andupdates—such as articles posted on the TIAA PlanFocuswebsite, the online 403(b) Resource Center, and in thee-newsletter for plan administrators, Plan sponsor pathways.TIAA is unable to provide accounting, legal or tax advice, sowe strongly encourage you to discuss matters pertainingto regulations governing an ERISA covered retirement planwith the plan’s tax or legal advisor or auditor.1.4 Proprietary annuity and mutualfund investmentsUnlike many trusteed plans, a retirement plan using TIAAand CREF annuities may be funded, in whole or in part,by individually or plan-sponsor-controlled TIAA and CREFfixed- and variable-annuity contracts. The RetirementChoice, Retirement Choice Plus, and Stable Valuecontracts are owned and controlled by the plan sponsor.Contributions made by the employer and the participantscan be allocated by the participants to investmentoptions selected by the plan sponsor and maintained onthe TIAA recordkeeping platform. Defined contributionFor institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 7
retirement plans may also offer a brokerage windowinvestment option within which a participant may investin an expanded menu of investment choices.–Plan investments in mutual funds are generally heldin trust for qualified plans and in custodial accountsfor 403(b) plans.Annuity contracts are exempt from being held in a trustor custodial accounts under Section 401(f) of the InternalRevenue Code (IRC) and Section 403(b) of ERISA.Other considerations related to TIAA and CREF contractsinclude, but are not limited to:WThe TIAA Traditional Annuity is an unallocatedfixed-rate guaranteed annuity contract offered byTIAA, an insurance company. Contributions to theTIAA Traditional Annuity purchase a contractualor guaranteed amount of future benefits for theparticipant. The guarantees and returns of the TIAATraditional Annuity are backed by TIAA’s claims-payingability. For purposes of ERISA, TIAA Traditional Annuityis considered an unallocated contract. See Departmentof Labor’s Advisory Opinion 2010-01A.For amounts not converted to begin a stream ofguaranteed lifetime income, liquidity restrictions applyto the TIAA Traditional Annuity under the followingtypes of annuity contracts:––Retirement Annuity (RA)–Individually owned–Lump-sum withdrawals are not permittedunless small sum conditions are met–Participant-initiated transfers or withdrawalsmay only be made in ten annual installmentsover a period of approximately nine yearsGroup Retirement Annuity (GRA)–Small sum conditions–Individually owned via certificate–Lump-sum withdrawals are permitted within120 days following termination of employmentand are subject to a 2.5% surrender charge–Other participant-initiated transfers or withdrawalsmay only be made in ten annual installments overa period of approximately nine years–Following termination of employment,participant-initiated withdrawals (other than alump-sum withdrawal permitted in the 120-dayperiod following termination of employmentdescribed above) are limited to fiveannual installmentsRetirement Choice ated lump-sum withdrawalsare permitted within 120 days followingtermination of employment and are subject toa 2.5% surrender charge–Other participant-initiated transfers may only bemade in 84 monthly installmentsThe following TIAA Traditional Annuity contracts have noliquidity restrictions (applicable to participant withdrawalsand transfers):WSupplemental Retirement Annuity (SRA),individually ownedWGroup Supplemental Retirement Annuity (GSRA),individually owned via certificateWRetirement Choice Plus (RCP)**For certain RCP contracts, 90-day equity wash applies if competingfunds exist (e.g., money market, short-term bond, self-directedbrokerage accounts or the TIAA Real Estate Account). Transfersfrom TIAA Traditional can only be made to noncompeting funds.The amount must remain in noncompeting funds for 90 daysbefore transferring to competing funds, including transferring backto TIAA Traditional.ValuationA plan’s balance in the TIAA Traditional Annuity isreported at contract value for plan financial and Form5500 reporting. See the TIAA Traditional Annuitywhite paper and Fair value measurements anddisclosures document.Benefit responsivenessTIAA Traditional Annuity holdings within liquidcontracts (SRA, GSRA and RCP) are benefitresponsive. TIAA Traditional Annuity holdings withinilliquid contracts (RA, GRA and RC) are nonbenefitresponsive. For plan years ended on or beforeSeptember 30, 2014, the two categories of TIAATraditional Annuities are reported separately tofacilitate reporting and disclosure in the financialstatements. For plan years ended on and afterOctober 31, 2014, the RC and RCP contracts willappear separately in many reports. Certain reporttiming exceptions may apply. Benefit responsivenessdoes not impact Form 5500. See Appendix J for TIAATraditional benefit/nonbenefit responsive chart.For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 8
As with the TIAA Traditional Annuity, and because ofthe complexity of the “vintage” system, one approachto recordkeeping fixed-rate annuities that provides foran additional discretionary interest rate is to unitizethe annuities to more efficiently apply the interestcrediting rates (representing the combined guaranteedand discretionary rates). As a result, realizedand unrealized appreciation/depreciation will appearin plan-level reporting. All realized and unrealizedappreciation/depreciation should be consideredinterest. TIAA follows this approach for the TIAATraditional Annuity and TIAA Stable Value.EarningsEarnings on the TIAA Traditional Annuity are based onthe “vintage” approach, with each “vintage” being agrouping of contributions into contiguous time periodsand used for the purposes of applying discretionaryearnings (otherwise called “additional amounts”) toparticipants on an equitable basis. Note that withrespect to the TIAA Traditional Annuity, additionalamounts, when declared by the TIAA, remain in effectfor the “declaration year” which begins March 1 foraccumulating annuities. Such additional amountsare not guaranteed for future years. Because of thecomplexity of the “vintage” system, one approach torecordkeeping fixed-rate annuities that provides foran additional discretionary interest rate is to unitizethe annuities to more efficiently apply the interestcrediting rates (representing the combined guaranteedand discretionary rates). As a result, realizedand unrealized appreciation/depreciation will appearin plan-level reporting. All realized and unrealizedappreciation/depreciation should be consideredinterest. TIAA follows this approach for the TIAATraditional Annuity and TIAA Stable Value.Footnote disclosureAccounting Standards Codification (ASC) 962-325-50-3requires certain disclosures for benefit-responsivecontracts. One of the disclosure elements relatesto the average yield earned by the reporting plan.A simple average yield can be calculated by dividing theannualized earnings of all benefit-responsive contractsby the fair value of all benefit-responsive contracts(see FAQ 5—page 51). Historical interest rates for eachcontract type are available and are inclusive of both theguaranteed rate and the discretionary rate (collectively,the “vintages”).WThe TIAA Stable Return Annuity is a fixed-rate groupannuity contract offered by TIAA, an insurance company.The TIAA Stable Return Annuity product is no longeroffered by TIAA. The fund was discontinued in 2010.EarningsThe contract provides a guaranteed minimum rateof interest of between 1% and 3% with the potentialfor crediting additional interest above the guaranteedminimum. Additional earnings, otherwise called“additional amounts,” when declared by the TIAA Boardof Trustees, remain in effect for the “declaration year”that begins each March 1 and are not guaranteed forfuture years.Footnote disclosureASC 962-325-50-3 requires certain disclosures forbenefit-responsive contracts. One of the disclosureelements relates to the average yield earned bythe reporting plan. A simple average yield can becalculated by dividing the annualized earnings of allbenefit-responsive contracts by the fair value of allbenefit-responsive contracts (see FAQ 5—page 51).Historical interest rates for each contract type areavailable, and are inclusive of both the guaranteed rateand the discretionary rate (collectively, the “vintages”).WTIAA Stable Value is a fixed-rate group annuity contractoffered by TIAA, an insurance company. Contributionsare maintained in a nonunitized separate account ofTIAA and buy a contractual or guaranteed amount offuture benefits for the participant. Allocations to theTIAA Stable Value annuity are backed by the value ofthe assets in the separate account and, if insufficient,by TIAA’s claims-paying ability.Plan sponsors choosing to terminate a plan’sinvestment in the TIAA Stable Value will receivecontract value in, at most, two years. If the two-yearpayout applies, a discontinuance fee will be assessed,reducing the interest credited during the two-yearperiod by up to 75 basis points (0.75%).ValuationA plan’s investment in TIAA Stable Value is reportedat contract value in all plan and participant financialreporting. TIAA believes that the TIAA Stable Valueis sufficiently similar to the TIAA Traditional Annuitythat the same valuation approach is appropriate. Seethe TIAA Traditional Annuity white paper and Fair valuemeasurements and disclosures document.For institutional investor use only. Not for use with or distribution to the general public.Plan sponsor reporting and audit guide 9
Benefit responsivenessTIAA Stable Value is immediately liquid to participantsand does not have participant-level withdrawalrestrictions. There are, however, “equity wash” provisionsthat prevent the immediate transfer of amounts to anycompeting funds available in the plan. As such, TIAAStable Value is a benefit-responsive contract.participant’s investment rises and falls with the returnon the underlying assets. TIAA Access has four tiers,each of which has an individual unit value. Auditedfinancial statements are available at TIAA.org.WEarningsThe contract provides a guaranteed minimum rateof interest of between 1% and 3% before dedu
Plan year 2021, version 1.0 For institutional investor use only. Not for use with or distribution to the general public. Contents Section 1—Introduction . (SOC) 1 report, and reporting information relating to TIAA, CREF and TIAA investment products W Frequently asked questions
