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Resources for bankers

Employee Benefits and Retirement Plan Services

The Employee Retirement Income Security Act of 1974 (ERISA, sections 401-409) and the Internal Revenue Code are the primary sources of law governing the structure, administration, and operation of employee benefit plans. Offering retirement plan services exposes national banks to a range of risk factors, including compliance risk, reputation risk, operational risk, and strategic risk. Banks be proactive and adequately manage these risks.

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Retirement Plan Products and Services (Comptroller’s Handbook, February 2014)
Provides an overview of services banks may provide to retirement plans


OCC Bulletin 2004-20, “Risk Management of New, Expanded, or Modified Bank Products and Services: Risk Management Process” (May 10, 2004)

OCC Bulletin 2006-24, “Interagency Agreement on ERISA Referrals” (June 1, 2006)

OCC Bulletin 2007-7, “Soft Dollar Guidance: Use of Commission Payments by Fiduciaries”  (February 5, 2007)

OCC Bulletin 2008-10, “Fiduciary Activities of National Banks: Annual Reviews of Fiduciary Accounts Pursuant to 12 CFR 9.6(c)” (March 27, 2008)

OCC Bulletin 2010-24, “Incentive Compensation: Interagency Guidance on Sound Incentive Compensation Policies” (June 30, 2010)

OCC Bulletin 2013-29, “Third Party Relationships: Risk Management Guidance” (October 30, 2013)

OCC Bulletin 2014-3, “Retirement Plan Products and Services: Comptroller's Handbook Revisions and Rescissions” (February 12, 2014)