Non-Qualified Savings Plan FAQs
Here are answers to frequently asked questions about the Non-Qualified Savings Plan (NQSP), participation, features, account access and more.
What is an NQSP?
An NQSP is a type of tax-deferred, employer-sponsored retirement plan offered by companies to provide eligible highly compensated employees with additional retirement savings opportunities and tax benefits. Non-qualified plans supplement retirement savings that cannot be contributed to a qualified retirement plan due to IRS limits on pay.
What are the IRS limits on pay?
- IRS pay limit: The IRS caps the amount of annual pay that is considered eligible for the 401(k) Savings Plan. For 2021 the pay limit is $290,000. For 2022, the pay limit is expected to increase to $305,000, but is subject to confirmation by the IRS later this year.
- IRS contribution limits: The IRS caps the annual amount you can personally contribute to an employer- sponsored retirement plan, like BMO’s 401(k) Savings Plan. For 2021, the contribution limit is $19,500; or $26,000 starting in the year you turn 50, if you elect to make additional 401(k) catch-up contributions.
- These limits are subject to change annually as determined by the IRS (typically announced in late October for the following calendar year).
Am I eligible to participate in the NQSP?
You can participate in the NQSP in two ways:
- BMO’s Core Contribution: If your eligible pay exceeds the IRS pay limit in 2021, or in future years, you will automatically receive a 2% Core Contribution from BMO on eligible pay between the IRS pay limit and $500,000.
- Your contributions and BMO’s Match: If eligible, you may have the opportunity to contribute your own pay to the NQSP on a before-tax basis, and receive a BMO Match on your contributions. You will receive an invitation to participate annually if BMO determines you are eligible for the plan.
How do I participate in the NQSP?
To participate in the NQSP for 2022, you must take action during the election period beginning Thursday, October 14 through Friday, October 29, 2021. If you do not make an election during this period, you will not be able to contribute to the NQSP in 2022. The next election opportunity will be in the fall of 2022, for the 2023 calendar year.
Do I need to enroll or re-enroll in the NQSP?
NOTE: Even if you don’t make an election to personally contribute pay into the NQSP, you can still make a distribution and investment election for your 2% Core Contribution during the 2022 election period.
I think my pay might exceed the IRS pay limit. Why didn’t I receive an invitation to participate in the plan?
BMO used a detailed analysis of past and expected future pay in our selection process. It is possible that, due to a number of factors, such as a recent job change that recently increased your pay, you were not selected to participate for the upcoming year. If your pay does exceed the IRS pay limit, you will receive BMO’s 2% Core Contribution on your excess pay, and will likely be invited to participate in the plan with the opportunity to make personal contributions in a future year.
If you feel an error was made, you can email NQAdmin@conduent.com and include an explanation of why you believe you should participate no later than the end of the current election period. Once the election period ends, no exceptions can be made and you will need to wait until the next annual election period.
What types of pay are considered for the NQSP?
Your eligible pay generally includes your base pay, overtime, shift differential and any variable pay that is related to work performance. Variable pay includes:
- Team-based plans (based on company, corporate, department or unit performance, including production and productivity plans)
- Sales, incentive and commission-based plans
- Business referral plans
- Ad hoc cash awards related to performance
However, due to certain IRS provisions that govern NQSPs, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP). This excludes sales incentives and commission pay. While sales incentives and commission pay is excluded for purposes of your personal contributions, it will still be used in determining your overall eligibility for the NQSP.
What is excess pay?
As it relates to the NQSP, excess pay generally refers to your eligible pay that is between the IRS pay limit and $500,000. For 2021 the pay limit is $290,000, but is subject to change each year as determined by the IRS.
How is my excess pay used to calculate benefits under the NQSP?
There are certain differences in how your excess pay is used to calculate contributions both you and BMO make to the NQSP, as follows:
- BMO’s Core Contribution: You will receive a 2% Core Contribution on the total amount of your excess pay.
- Your contributions: You may be eligible to make personal, before-tax contributions to the plan from 1% to 25% of your eligible excess pay. The money you contribute is deducted from your pay each pay period.
IMPORTANT. Due to certain IRS provisions that govern non-qualified savings plans, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP), but exclude sales incentives, commission pay and certain bonuses. You cannot make personal contributions from any pay you earn under a sales, incentive, or commission-based plan, but these types of pay will still be used in determining your overall eligibility for the plan, and the amount of BMO’s Matching and 2% Core Contributions.
- BMO’s Match: You will receive a dollar-for-dollar match on your contributions, limited to 5% of your total excess pay.
Am I vested in my NQSP?
You’re vested in BMO’s 2% Core Contributions after three years of BMO service (including prior service). Your personal contributions and BMO’s Matching Contributions are vested immediately.
Why am I being asked to make my fiscal year 2022 STIP Award deferral election during the October 2021 election period, rather than April 2022?
IRS regulations require NQSP participants to make contribution elections prior to the start of the performance period for which that pay is earned. Because of the timing of BMO’s fiscal year, this means we are now required to collect your STIP Award deferral election at the same time as your election to participate in the NQSP.
IMPORTANT. When you submit your NQSP election online, you will also choose when you want to receive payment of your FY2022 STIP award, either in December 2022 or January 2023, if eligible.
How do contributions to the NQSP change my taxes?
Payment of Federal income tax and most state/local income tax is not applicable until you receive your account distribution on NQSP contributions made by you or BMO. You will pay current FICA taxes (Social Security and Medicare), as applicable, on amounts you contribute to the plan at the time they are deducted from your pay.
In addition, the value of BMO’s Matching and vested Core Contributions will be included in your pay for FICA tax purposes at the time they are contributed to the plan. If you are not yet vested in the 2% Core Contribution, the value will not be included in your pay until you become vested.
At the time you begin to receive your distribution from the NQSP you may be asked to complete a tax Form W-9 (if you are a U.S. citizen or resident alien residing outside the U.S.) or W-8BEN (if you are a non-U.S. citizen and the beneficial owner of an amount subject to U.S. withholding) before we will issue your payment.
I previously enrolled in the NQSP. Why have I not had any contributions deducted from my pay?
If your annual Short-Term Incentive Pay (STIP) makes up most, or all, of your compensation that exceeds the $290,000 limit on eligible pay, then you likely will not see your first NQSP contributions until your STIP is paid, either in December 2021, or January 2022.
What investment options are offered in the NQSP?
|BMO Government Money Market
|Target Date Retirement Funds||Ticker||Default Investment (based on your year of birth):|
|BlackRock Index Retirement Fund
|LIRKX||1952 or earlier|
|BlackRock Index Retirement 2025 Fund
|LIBKX||1958 to 1962|
|BlackRock Index Retirement 2030 Fund
|LINKX||1963 to 1967|
|BlackRock Index Retirement 2035 Fund
|LIJKX||1968 to 1972|
|BlackRock Index Retirement 2040 Fund
|LIKKX||1973 to 1977|
|BlackRock Index Retirement 2045 Fund
|LIHKX||1978 to 1982|
|BlackRock Index Retirement 2050 Fund
|LIPKX||1983 to 1987|
|BlackRock Index Retirement 2055 Fund
|LIVKX||1988 to 1992|
|BlackRock Index Retirement 2060 Fund
|LIZKX||1993 or 1997|
|BlackRock Index Retirement 2065 Fund
|LIWKX||1998 or later|
|Target Risk Funds (available until Nov. 30, 2021)||Ticker|
|BMO Conservative Allocation Fund (R6)||BDVSX||Automatically map to the BlackRock 20/80 Target Allocation Fund after Nov. 30, 2021.|
|BMO Moderate Allocation Fund (R6)||BMBTX||Automatically map to the BlackRock 40/60 Target Allocation Fund after Nov. 30, 2021.|
|BMO Balanced Allocation Fund (R6)||BGRQX||Automatically map to the BlackRock 60/40 Target Allocation Fund after Nov. 30, 2021.|
|BMO Growth Allocation Fund (R6)||BABQX||Automatically map to the BlackRock 80/20 Target Allocation Fund after Nov. 30, 2021.|
|BMO Aggressive Allocation Fund (R6)||BDSQX||Automatically map to the BlackRock 80/20 Target Allocation Fund after Nov. 30, 2021.|
|Target Risk Funds (available after Nov. 30, 2021)||Ticker|
|Conservative: BlackRock 20/80 Target Allocation Fund
|Moderate: BlackRock 40/60 Target Allocation Fund
|Balanced: BlackRock 60/40 Target Allocation Fund
|Growth: BlackRock 80/20 Target Allocation Fund
What are my account distribution options?
Unlike other retirement plans, when you participate in a NQSP, you must also choose in advance how your account balance will be paid to you during the election period. You can choose:
- Lump Sum: You will receive your full account balance in one payment made approximately 60 days following your retirement or date you otherwise leave BMO for any reason.
- Installments: You will receive your full account balance in annual payments made over five or ten years. Payments will be made at the beginning of the calendar year following the year you retire or otherwise leave BMO for any reason, and every January thereafter.
The choice applies to both your contributions and BMO’s contributions made to your account during the next plan year, and any investment earnings. During each subsequent election period, you have the ability to make a new distribution choice for the following year only.
If you do not make a distribution election, or if your vested account balance is less than $50,000 when you retire or otherwise leave BMO for any reason, you will receive your account balance in a lump sum. Your distribution is not eligible for a roll-over to an IRA or other qualified retirement plan (like a 401(k) plan).
How do I access my NQSP account online?
- ACCESSBenefits from Workday – (no password required)
- Go to Workday, click Pay application
- Under External Links, click 401(k) to connect to your ACCESSBenefits account
- Click Savings from the menu and then use the drop-down box to switch the view from your 401(k) to your Non-Qualified Savings Plan account
- For those employees who have relocated from the U.S. to another country: ACCESSBenefits Online from Workday – (no password required)
- Go to Workday, click More Tools application, then click HR Intranet
- Under Benefits, click Retirement, then click U.S. Retirement Savings Program (make sure you are viewing the BMO U.S. tab)
- Click on Login to 401(k) from the menu on the right-hand side to connect to your ACCESSBenefits account
- Click on Savings from the menu and then use the drop-down box to switch the view from your 401(k) to your Non-Qualified Savings Plan account
- ACCESSBenefits Online – from any internet enabled device (User Name/Password required)
You can access your account online from any internet enabled device (computer, phone or tablet). You need your ACCESSBenefits User Name and Password to access your account (NOTE: this is the user name and password you created to access your 401(k) Savings Plan account). Go to ACCESSBenefits Online.
- Life@Work App – from any mobile device
Download the Life@Work app from the App Store or Google Play. You’ll need your ACCESSBenefits username/password. To register, follow the prompts and enter either your current BMO email address or use a company code:
- HRB01 (current employees)
- HRB03 (former employees)
How will I get my account information?
You will have access to your NQSP account statements through ACCESSBenefits. The site allows you to view real-time data about your account, or print PDF statements.
Who can I contact if I have more questions?
If you have more questions about the NQSP or the upcoming election period, you may send an email to NQAdmin@conduent.com.
To speak with a representative you may contact the Human Resources Centre at 1-888-927-7700 and when prompted select “Retirement & Savings,” then “401(k).”
- You will be connected to ACCESSBenefits, where you will be prompted to enter your SSN and PIN (use the same 6-digit PIN you use to access the 401(k) Savings Plan).
- Follow the menu prompts and select “Non-Qualified Savings Plan” to be directly connected with an NQSP Client Service Team member, Monday to Friday, 9 a.m. – 5 p.m. ET.
NOTE: If you wish to speak with an NQSP Client Service Team member, you will need your PIN. If you have forgotten your phone PIN, but have access to your account online, you can quickly reset your Interactive Voice Response (IVR) PIN in your ACCESSBenefits profile online, or you can follow the prompts in the phone menu to request a PIN reset, which will be mailed to your home. Additionally, you can press “0” to be transferred to a customer service representative. Please ask to be directly transferred to the NQSP Client Service Team for assistance with the BMO Non-Qualified Savings Plan.
Example: How to maximize your benefit under the Non-Qualified Savings Plan if your pay includes sales, incentive, or commission-based pay
In this example, David earns a $120,000 base salary and has earned commission pay of $250,000. David understands his BMO 2% Core Contribution and dollar-for-dollar Matching Contribution up to 5% are based on his total excess pay (base plus commission pay). Therefore, in order to maximize his savings potential under the NQSP, David elects a higher contribution percent of 20%, which only applies to base-pay, but not his commission pay.
Please rotate your device to see the table.
|Eligible Pay||Excess Pay||NQSP Contributions|
In comparison, David’s co-worker Stacey earns exactly the same amount during the year, but she has a $120,000 base salary and received a $250,000 STIP in December with no sales, incentive or commission-based pay.
Stacey personally contributes 5% of her pay to the plan in order to maximize her BMO Match. Although David and Stacey elected different contribution percentages, they end the year with the same benefit amount. This is because David understood what his commission-based pay meant for him and intentionally elected a higher contribution amount in an effort to maximize his savings potential.
Please rotate your device to see the table.
|Eligible Pay||Excess Pay||NQSP Contributions|
NOTE: This example assumes a $290,000 IRS pay limit. The limit is subject to change annually as determined by the IRS.