Untitled Texas Attorney General Opinion

lhmotableJames E. (Pete)Laney OpinionNo. JM-691 Chai?lUaU .StateAffairsCommittee Re: Designationof agent,broker Texas Rouse of Representatives or company for Optional Rrtire- P. 0. Box 2910 ment investmentsor annuities Austin, Texas 70769 Dear Representative Laney: You ask if participantsin an Optional RetirementProgram (ORP) authorieedby chapter 36 of Title llOB, V.T.C.S.,may designatethe agent, broker, or company throughwhich investmentsor annuitiesmay be arranged. You suggestthat they may do so and that their choice is limitedonly by the provisionsof sections401(g) and 403(b) of the federal Internal Revenue Code of 1954, as it existed on January 1, 1981. The 1981 date is fixed by section36.002 of Title 1lOB: (a) The optionalretirementprogramestablished as provided by this subtitle shall provide for contributionsto any type of investmentauthorized in Section 403(b) of the federal InternalRevenue Code of 1954, 42 U.S. Code, as it ‘existed on January 1, 1981. and for the purchase of fixed or variable retirement annuities that meet the requirementsof that sectionand Section 401(g) of the federalInternalRevenue Code of 1954, 42 U.S. Code, as amended. (b) Participationin the optional retirement program is an alternativeto active membershipin the retirementsystem. As amended by Acts 1981. 67th Leg., 1st C. S., ch. 18. 135. at 195. 207. It has been argued thet section 36.004 of Title llOB, set out below, allows the governing board of an institution of higher education to provide for contributionsto any federally authorised type of investmentand to arrange the purchase of annuity contracts from “any insurance or annuity,company that is qualified to do business in this state,” without restriction. It is said that the language of section 36.004 “indicatesthat a participantshould be p. 3200 HonorableJames E. (Pete)Laney - Page 2 (JM-691) allowedfreedomof choice in selectingthe vendor from which he or she wishesto purchasean authorizedinvestment[or] annuity." Section 36.004, amended in 1981 by the same act that amended section36.002,reads in its entirety: (a) A governing board may provide for con- tributionsto any type of investmentauthorizedin Section 403(b) of the federal Internal Revenue Code of 1954, 42 U.S. Code, as it existed on January 1, 1981, and may arrange the purchase of annuity contracts from any insurance or annuity company that is qualifiedto do business in this state. (b) If a governing board has more than one component institution,agency, or unit under its jurisdiction,the governingboard may provide a separate optional retirement program for each component or may place two or more components under a singleprogram. V.T.C.S.Title llOB,PublicRetirementSystems,136.004. ye do not read this languageas indicatingthat a participanthas any right to choose OptionalRetirementProgramvendors. The statute conferscertainauthorityou "a governingboard." The most that might be argued from this language, in our opinion, is that it does not preventa governingboard from consideringthe wishes of a participant in selectingOptionalRetirementProgramvendors. It is also suggestedthat 1985 amendmentsto articles6228a-5and 6252-3b,V.T.C.S..demonstratea legislativeintent that participants in an Optional Retirement Program have such a right because the categoriesof employeas affected overlap. Article 6228a-5 reads in pertinentpart: Section 1. Local Boards of Education of the Public Schoolsof this State, the GoverningBoards of the state-supportedinstitutions of higher education,the CoordinatingBoard, Texas College and University System, the Central Education Agency, the Texas Departmentof Hental Reslth and Mental Retardation'and the state schools, state hospitals,and other facilitiesand institutions under its jurisdiction,the Texas Youth Commission and facilitiesand institutionsunder its juris- diction, and the governingboards of Centers for CoPmDunityMental Health and Mental Retardation Services, county hospitals, city hospitals, city-county hospitals, hospital authorities, hospital districts, affiliated state agencies. p. 3201 HonorableJames E. (Pete)Laney - Page 3 (JM-691) and political subdivisionsof each of them, mma enter into agreementswith their employees for the purchase of annuities or for contributions to any type of investment for their employees as authorizedin Section 403(b) of the Internal Revenue Code of 1954, as it existedon January 1. 1981. Sec. 2. (a). . . . (b) The comptrolleror the governingboard, as the case may be. may reduce the salaryof partici- pants when authorizedin writing and shall apply the amount of the reduction to the purchase of annuity contractsor to contributionsto any type of investmentauthorizedin Section 403(b) of the Internal Revenue Code of 1954, as it existed on January 1, 1981, the exclusive control of which will vest in the participants. (4 The employee is entitled to designate any agent, broker, or company through which the annuity or investment is to be purchased. (Emphasisadded). The pertinentprovisionsof article6252-3bare: Sec. 1. The state or any county,city, town, or other politicalsubdivisionmay, by contract,agree with any employeeto defer, in whole or in part, anT portion of that employee‘s compensationand may subsequently,with the consent of the employee, contractfor, purchase,or otherwiseprocure a life insurance,annuity,mutual fund, or other investment contract for the purpose of funding a deferred compensationprogramfor the employee,from any life underwriterduly licensedby this state who repre- sents an insurance company licensed to contract business in this state, any state or nationalbank domiciledin this state whose deposits are insured by the Federal Deposit Insurance Corporation,any savings and loan associationdoing business in this state whose accounts are insured by the Federal Savings and Loan Insurance Corporation, or any credit union doing business in this state whose accounts are insured by the National Credit Union Administrationor the Texas Share Guaranty Credit Union or a mutual fund licensed to do business in this state. The amounts which participating employeesagree to defer are the only funds a seller of investment products may receive under this program. p. 3202 BonorableJames E. (Pete)Laney - Page 4 (JM-692) . . . . Sec. 3B. (a) For investments in a deferred compensationproduct offered through a vlan created under Section 457 of the InternalRevenue Code. the comptrollermay not require a seller of investment products to solicit business, place contracts,or otherwise procure deferred compensationagreements with or through particular agents, brokers, or companies. Each state amployeeshall have the right to designatethe agent, broker, or company through which the investmentproduct is purchased.Provided, however, that nothing in this section shall prevent the comptrollerfrom restrictingthe participation of any agent, broker, or company in the deferred compensationprogram for good causa. (b) The comptroller,when solicitingbids for the deferred compensation plan authorized under Section 401(k) of the Internal Revenue Code, shall consider bids from companiesrequiring the use of their own agents to sell their products as well as companies selling their products through a third party administratoror otherwise. Sec. 4. For the purposesof this Act, 'employee' means any person whether appointed, elected. or under contract, providing services for the state, county, city, town, or other politicalsubdivision, for which compensationis paid. . . . . Sec. 6. The deferred compensation program establishedby this Act shall exist and serve in additionto retirement,pension, or benefit systems establishedby the state, county, city, towu. or other political subdivision, and no deferral of incomeunder the deferredcompensationprogramshall affect a reductionof any retirement,pension, or other benefit provided by law. However, any sum deferred under the deferred compensationprogram shall not be subject to taxationuntil distribution is actuallymade to the employee. (Emphasisadded). It is true that the categoriesof employeesaffectedby articles 6228a-5 and 6252-3b overlap with those entitled to participate in the Optioual RetirementProgram. Eligibilityto participatein the OptionalRetirementProgram,subject to rules adoptedby the governing board, is open to all faculty members in a component institution. V.T.C.S.Title llOB, 1536.101.~31.001(8).Cf. Carpenterv. StephenF. Austin State University,706 F.2d 608 (Sthir. 1983) (exclusions). p. 3203 HonorableJames E. (Pete)Laney - Page 5 (JM-692) Each of those persons is also now an "employee of a governmental budy covered" vithin the meaning of article 622Sa-5. and a person II appointed,elected, or under contract,providingservices. . . for which compensationis paid" within section4 of article 6252-3b. Cfi Attorney General OpinionM-313 (1968) (coordinatingboard employees). But we do not think the overlapaffectsthe constructionof chapter36 of Title 1lOB. Cf. Attorney GeneralOpinionMU-570 (1982) (overlapof coveragebetweenyticles 6252-3band 622Sa-5). Chapter 36 of Title 1lOB establishesthe Optional Retirement Program as a retirementsystem for certain state employeesin which such employees can choose to participateinstead of, participating in the Teachers Retirement System of Texas. V.T.C.S. Title llOB, 5811.001(2).31.001, 36.001. 36.002(b). On the other hand, articles 6228a-5 and 6252-3b do not establish retirement systems; they merely accord employeesan opportunityto take advantageof certain federaltax reductionmeasures, if available. See Attorney General OpinionC-83 (1963) (article 6228a-5 intent). The differencesare not cosmetic. V.T.C.S.Title 1lOB. §11.001(2). See AttorneyGeneral OpinionMU-548 (1982). All such employeesmust make contributionsof a certain level to a retirementsystem -- either the Teacher RetirementSystem or the OptionalRetirementProgram. V.T.C.S. Title llOB, 1136I201.35.4C3. 32.002, 31.001(14). Such contributionsare mandatory. -- See In re Ropar. 49 B.R. 4 (Bank=.N.D. Tex. 1984). The state is statutorily required to make even greater contributionsfor the employer's benefit.Id. 1136.201.35.404.But benefitsin the OptionalRetirement ProgramvZ in a participantonly after a full year of participation. Id. 136.204. Aud benefitsare availableto the participantonly upon death. retirement,or terminationof the participant'semploymentin all 'institutionsof higher education. ,Id.$36.105(c). See Attorney GeneralOpinion MB-548 (1982) (availabilfty of investment%nefits as well as annuitybenefitsrestricted). By contrast, participationin a tax sheltered annuity or in- vestment plan under article 622Sa-5, or in either of the deferred compensationplans under article 6252-3b. is purely voluntary and the state contributes no funds toward the realization of any of them. They are not establishedfor the same reasons that retirement systemsare established,&. to provide security for the employees as well as to encouragequalifiedpersons to become and remain public 1. By electing to reduce their salaries,participantsmay. in effect,also voluntarilycontribute(unmatched)additionalamounts to See V.T.C.S.Title 11OB. 536.203. the OptionalRetirementProgram. - p. 3204 HonorableJames E. (Pete)Laney - Page 6 (3-f-692) employess. Tex. Const. art. XVI, 567. See Woods v. Reilly, 218 S.W.Zd 437 (Tex. 1949); Attorney General Opxon Nos. B-1060 (1977); B-532 (1975). There is no delayed vesting or statutorily-mandated delayed realizationof benefitsunder the tax shelteror deferredcompensation plans because the public interestis not the same. No public money, in the ordinary sense, is invested or contributed;the security, safety,and stabilityof those investmentprogramsare private - not public - concerns. We advise that the law does not accord participants in an OptionalRetirementProgram any right to designatethe agent, broker, or company through which investmentsor annuitiesmay be arranged pursuantto chapter36 of Title llOB, V.T.C.S.,althoughthe governing board of an institutionestablishingsuch a program may take into account the wishes of participantsabout such matters if it may be done in a manner consistentwith law and the protectionof the public interest. SUMMARY Participantsin the OptionalRetirementProgram have no statutory right to designate the agent, broker, or company through which investments or annuitiesmay be arrangedpursuantto chapter 36 of Title 1lOB. V.T.C.S. f-l-h Very truly yours . JIM MATTOX AttorneyGeneral of Texas JACRBIGBTOWER First AssistantAttorneyGeneral MARY KELLER ExecutiveAssistantAttorneyGeneral JUDGE ZOLLIE STEARLBY SpecialAssistantAttorneyGeneral RICK GILPIN Chairman,OpinionCommittee Preparedby Bruce Youngblood AssistantAttorneyGeneral p. 3205