In response to these new data exchange requirements, a number of friends and colleagues from a large number of 403 (b) providers joined forces and worked diligently and effectively to establish information standards for the exchange of this data for several years after the release of the regulations. They are referred to as SPARK 403 (b) Best Practices for Sharing Data Elements. Don`t be misled; Nothing could be further from the truth. SPARK standards are intended for the essential contractual information necessary to comply with ISA requirements. There is no royalty data; There is no data on investments; there is no description of the services. The reference to the standard “SPARK” as a solution for the DOL rules is certainly a very eye-catching sales and marketing hook, but it is also very wrong. The IRS also imposed new rules for the exchange of contracts between lenders in the same plan. Among these new rules is the famous “Information Sharing Agreement” (or “ISA”) which requires that the terms of exchange through the employer, which is an agreement with the issuer of the contract in which the funds are exchanged. According to the ISA, the employer and the new issuer agree to make available to each other “from time to time in the future” the information necessary to complete Section 403 (b) of the new contract or any other contract to which the employer has contributed. These include information on the participant`s employment status, eligibility for an emergency position and the ability to take out a loan (and how much), as well as information needed to meet other tax requirements. In the end, as I have suggested in the past, the answer may lie in the formation of a consortium funded largely by user fees; supported by a well-established centre such as a public university; and led by a large number of stakeholders – not just suppliers. It`s not just a dream, so a number of standard configuration organizations and consortia are managed with some consistency. I accept here a bias, because some of us had proposed and developed such a structure during the early days of the new Regs, and a number of critical parties were interested.
In addition, ISA standards have been well developed by dedicated professionals, many of whom are passionate about this business. They were indeed a huge success “Skunk Works”. Much of the current value of standards comes from volunteers who have moved to other positions within and the other of the original organizations involved in the process. Sustainability is now on the agenda. The standards were also developed under the aegis of a small organization with very limited specialized and administrative staff who, in addition to trying to establish retirement data standards in addition to 403 (b) standards, are very geared towards the establishment of a new “brand” of its own. Sustainability, structure and support are necessary elements to maintain and develop these standards for older adults.