The FCMM Retirement Plan is an employer plan, meaning that an employing church or ministry organization decides whether – and how – to participate in the Plan. As with other 401(k) or 403(b) plans, only the employer can remit contributions to the Plan.

Those contributions may consist of employer contributions, employee salary deferral contributions (deducted from paycheck), and/or matching contributions where the employer matches up to a certain level of employee deferrals.

The Employer Adoption Agreement

The IRS requires these details to be spelled out in a document whereby the employer “adopts” the Plan as the organization’s official retirement program. Since FCMM operates as a multiple-employer Plan, the employer needs only to participate according to the Plan’s design, which is maintained by FCMM as a 403(b)(9) denominational Church Plan.

By completing the FCMM Employer Adoption Agreement (EAA) – Form 20, the organization agrees to operate under FCMM’s Plan Document (Form 30), with the EAA customizing certain employer choices.  Together, these documents comprise the compliant Plan under which the church provides the retirement benefit. The participating organization must submit the EAA to FCMM and also keep a current copy on file with local records. 

The EAA form guides the employer through decisions regarding classes of employees, if desired. These classes may specify eligibility requirements for each class as well as levels of employer contribution. FCMM staff are available to advise for completion of the EAA.

Upon completion of the EAA and approval by FCMM, the employer can commence contributions according to those features. FCMM provides an Employer Guide (Form 21) to assist the organization in initiating and maintaining the Plan.

Making Changes

When an organization chooses to modify its retirement plan benefits, it is important to submit a new EAA that reflects the updated features. Please note that when an employer specifies a contribution by dollar amount, any change in that amount going forward must be listed in a new EAA form submitted to FCMM. When specified as ongoing percentage(s), the EAA does not need to be updated until new percentage(s) are offered.

Meeting Employer Requirements

Employers should take note of the agreements that are part of the EAA, including:

• Monitoring calendar year contribution limits for contributions as required by the IRS. 
• Notifying employees of their eligibility to participate in the Plan, as they meet qualifications. 
• Ensuring that once an employee gains eligibility to make salary deferral contributions, they must be included even if they subsequently work fewer hours than required for a salary deferral threshold, or even if an employer raises the eligibility threshold for new hires. 
• Utilizing the FCMM Plan as the sole active retirement plan of the employer, which is necessary for proper IRS compliance by the Plan.
   

Eligible Organizations

As the church retirement plan of the Evangelical Free Church, FCMM serves electing EFCA congregations as well as ReachGlobal missionaries and EFCA national office staff.

Non-EFCA churches, such as independent congregations, may participate if not served by a denominational plan and after affirming common bonds of evangelical faith with the EFCA.

Ministry organizations meeting the IRS definition of Qualified Church Controlled Organizations may participate after certifying their status and affirming common bonds of evangelical faith with the EFCA.