Connecticut Comptroller Using a Survey to Solicit Information from Municipalities Regarding Retirement Plans

by Sharon K. Freilich

Our July 14, 2023 Client Alert discussed the information and documents that Connecticut Public Act 23-182 requires municipalities sponsoring retirement plans to provide to the Comptroller’s Office by September 1, 2023. On August 1, 2023, the Comptroller’s Office sent a letter to the 169 local governments in Connecticut to solicit retirement plan information through responses to a survey on the Comptroller’s website.

Information concerning participation in the Connecticut Municipal Employees Retirement System or the State 457(b) Plan is not required to be included in responses to the Survey. The survey clarifies the meaning of the terms “fees” and “retirement plan” used in Public Act 23-182. The survey is soliciting information regarding investment management fees, including investment advisory fees, account maintenance fees, and sales charges, including front-end or back-end loads, commissions, and similar charges.

The Comptroller’s Office is requesting information for “each … retirement plan (DB Defined Benefit, DC Defined Contribution, Hybrid, [457(b)]) offered to all public employees within your municipality (general employees, public works, housing authority, board of education, public safety).” Accordingly, the survey is seeking information regarding Section 403(b) Plans and other retirement plans that are not sponsored directly by the recipients of the Comptroller’s letter in addition to information for the retirement plans directly sponsored.

The survey asks whether the municipality uses a third party advisor or administrator to provide management or oversight of the municipality’s retirement plans. The survey also asks that the advisor or administrator be identified. Municipalities may want to consult with counsel to determine whether any service providers to their plans, in addition to traditional third party administrators, should be identified in response to this question.

For questions, concerns or assistance with this new reporting obligation, please contact any member of our Employee Benefits practice group.

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