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STEP, Inc., also served as the STEP plan sponsor from the
plan’s inception until April 1, 1992. U.S. Trust served as the
successor plan sponsor from April 1, 1992, until February 14,
1997, when first STEP, Inc., and subsequently Teplitzky & Co.
took over as successor plan sponsor. On February 7, 2002,
Teplitzky & Co. resigned as plan sponsor and appointed SPSI as
the successor plan sponsor.
During the subject years, Teplitzky & Co., acting as the
STEP plan administrator, ran the daily operation of the STEP
plan. U.S. Trust, as plan sponsor, interacted with the insurance
companies whose policies were owned by the STEP plan and
conducted the plan’s marketing activities.
D. Marketing Documents
The STEP plan marketing documents set forth detailed
examples of when severance benefits would and would not be paid
under the plan.7 These examples allowed individuals covered by
the plan to time their departures from their businesses and to
phrase their requests for severance benefits so that benefits
would be paid to them under the STEP plan as they anticipated.
The STEP plan marketing documents warned participants that
“Benefits accrued for an employee are forfeited if the employee
does not qualify for benefits under a bona fide severance as
7 Upon adopting the plan, each participating employer also
was provided examples of qualifying severance events.
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Last modified: March 27, 2008