AGENDA A REGULAR MEETING OF THE BOARD OF RETIREMENT LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION 300 N. LAKE AVENUE, SUITE 810, PASADENA, CA 9:00 A.M., THURSDAY, OCTOBER 13, 2016 The Board may take action on any item on the agenda, and agenda items may be taken out of order. I. CALL TO ORDER II. PLEDGE OF ALLEGIANCE III. APPROVAL OF MINUTES A. Approval of the Minutes of the Regular Meeting of September 15, 2016 IV. REPORT ON CLOSED SESSION ITEMS V. OTHER COMMUNICATIONS A. For Information 1. August 2016 All Stars 2. Chief Executive Officer’s Report (Memo dated October 4, 2016) VI. PUBLIC COMMENT
Transcript
AGENDA
A REGULAR MEETING OF THE BOARD OF RETIREMENT
LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION
300 N. LAKE AVENUE, SUITE 810, PASADENA, CA
9:00 A.M., THURSDAY, OCTOBER 13, 2016
The Board may take action on any item on the agenda,
and agenda items may be taken out of order.
I. CALL TO ORDER
II. PLEDGE OF ALLEGIANCE
III. APPROVAL OF MINUTES
A. Approval of the Minutes of the Regular Meeting of September 15, 2016
IV. REPORT ON CLOSED SESSION ITEMS
V. OTHER COMMUNICATIONS
A. For Information
1. August 2016 All Stars
2. Chief Executive Officer’s Report
(Memo dated October 4, 2016)
VI. PUBLIC COMMENT
October 13, 2016
Page 2
VII. NON-CONSENT AGENDA
A. Presentation of Alston & Bird’s Final Report of Privacy Audit
Recommendation as submitted by Richard Bendall, Chief Audit
Executive and Steven P. Rice, Chief Counsel: That the Board:
1. Approve Alston & Bird's Final Report as Presented and Waive
Approval by the Audit Committee.
(Public Memo dated September 29, 2016)
(Privileged and Confidential Version of Memo Dated September 29, 2016
for Board members only)*
B. Recommendation as submitted by Barry W. Lew, Legislative
Affairs Officer: That the Board adopt the Legislative Policy.
(Memo dated October 3, 2016)
C. For Information Only as submitted by Barry W. Lew, Legislative
Affairs Officer, regarding an update on Assembly Bill 1853 – County
Employees Retirement Districts. (Memo dated September 26, 2016)
D. For Information Only as submitted by Beulah S. Auten, Chief
Financial Officer, regarding the Semi-Annual Interest Crediting for Reserves
as of June 30, 2016 (Audited). (Memo dated October 4, 2016)
VIII. REPORT ON STAFF ACTION ITEMS
IX. GOOD OF THE ORDER
(For information purposes only)
X. EXECUTIVE SESSION
A. Conference with Legal Counsel - Anticipated Litigation
Initiation of Litigation (Pursuant to Paragraph (4) of Subdivision (d) of
California Government Code Section 54956.9)
1. Unknown Number
October 13, 2016
Page 3
X. EXECUTIVE SESSION (Continued)
B. Conference with Legal Counsel - Anticipated Litigation
Significant Exposure to Litigation (Pursuant to Paragraph (2) of Subdivision
(d) of California Government Code Section 54956.9)
1. Administrative Appeal of Michele Fiorenza
2. Administrative Appeal of Joseph Ruggiero
XI. ADJOURNMENT
* A public cover memo and PowerPoint presentation are provided in support of this item.
The Board is also provided with the full auditor's report and management's response to
the report. These two documents are privileged attorney-client communications and/or
attorney work product. Under the Brown Act, Government Code Section 54957.5(a), they
are not available for distribution to the public.
Documents subject to public disclosure that relate to an agenda item for an open
session of the Board of Retirement that are distributed to members of the Board of
Retirement less than 72 hours prior to the meeting will be available for public
inspection at the time they are distributed to a majority of the Board of Retirement
Members at LACERA’s offices at 300 N. Lake Avenue, Suite 820, Pasadena, CA
91101, during normal business hours of 9:00 a.m. to 5:00 p.m. Monday through
Friday.
Persons requiring an alternative format of this agenda pursuant to Section 202 of the
Americans with Disabilities Act of 1990 may request one by calling Cynthia Guider at
(626) 564-6000, from 8:30 a.m. to 5:00 p.m. Monday through Friday, but no later than
48 hours prior to the time the meeting is to commence. Assistive Listening Devices are
available upon request. American Sign Language (ASL) Interpreters are available
with at least three (3) business days notice before the meeting date.
MINUTES OF THE REGULAR MEETING OF THE BOARD OF RETIREMENT
LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION
2. LACERA Legislative Report – Other (Dated September 14, 2016)
3. LACERA Legislative Report – Federal (Dated September 14, 2016)
September 15, 2016
Page 9
XI. ADJOURNMENT
There being no further business to come before the Board, the meeting was
adjourned in memory of Edmund D. Edelman, former member of the Board of
Supervisors, at 11:45 a.m.
WILLIAM DE LA GARZA, SECRETARY
SHAWN R. KEHOE, CHAIR
October 4, 2016
TO: Each Member
Board of Retirement
Board of Investments
FROM: Gregg Rademacher
Chief Executive Officer
SUBJECT: CHIEF EXECUTIVE OFFICER’S REPORT
I am pleased to present the Chief Executive Officer’s Report that highlights a few of the
operational activities that have taken place during the past month, key business metrics to
monitor how well we are meeting our performance objectives, and an educational calendar.
LACERA's Annual Wellness and Employee Benefits Program
LACERA continued its long standing tradition for supporting wellness in the workplace by
hosting the 18th Annual Wellness and Employee Benefits Program. This year's two day event
held on September 21st and 22
nd titled "Balancing Work & Life" provided the employee an
opportunity to gather information about their health and financial benefits in advance of their
October benefit open enrollment period and encouraged wellness through a healthy work and life
balance by providing education about lifestyle and well-being changes having a positive impact
on themselves and their family.
The first day included seminars on balancing work and life, eating healthy, home buying
education, retirement options, financial information, identity protection, and preventative health
measures. The second day was the Benefits Fair which included health screenings for blood
pressure, cholesterol, glucose screening and chiropractic chair massages. The vendors in
attendance included: AFLAC, Empowerment Retirement, Colonial Life, Fiscal and LA Financial
Credit Union, and Smile Finders. This allowed employees to speak with a representative and
receive information specific to their situation. To encourage an active lifestyle, all participating
employees were entered into a free raffle for five (5) Fitbit Trackers and other items donated by
the vendors.
A new addition this year included an information fundraising table for the American Cancer
Society's 2016 Making Strides Against Breast Cancer 5K Walk in support of Los Angeles
County's proclamation of October as Breast Cancer Awareness Month. Employees received
information about the walk, how to sign-up to for the walk, and make donations. Pink Ribbon
Pins and Bracelets donation premiums were available with 100% of all donations going toward
Team LACERA's fundraising goal. Employees were encouraged to walk with their family and
friends to show that no one facing breast cancer walks alone.
GR: jp
CEO report Oct 2016.doc
Attachments
LACERA’s KEY BUSINESS METRICS
Metrics YTD from July 1, 2016 through August 31, 2016 Page 1
OUTREACH EVENTS AND ATTENDANCE
Type # of WORKSHOPS # of MEMBERS
Monthly YTD Monthly YTD
Benefit Information 14 31 568 952 Mid Career 6 11 233 367 New Member 19 35 328 686 Pre-Retirement 10 17 179 358 General Information 1 1 25 25 Retiree Events 0 2 0 140 Member Service Center Daily Daily 1,405 2,727
TOTALS 50 97 2,554 5,225
Member Services Contact Center RHC Call Center Top Calls
Overall Key Performance Indicator (KPI) 96.97%
Category Goal Rating Member Services Call Center Monitoring Score 95% 95.42% 98% 1) Workshop Info/Appts. Inquiry Grade of Service (80% in 60 seconds) 80% 67% 34% 2) Benefit Payments: Gen. Inquiry/Payday Call Center Survey Score 90% 95.49% xxxxx 3) Retirement Counseling: Estimate Agent Utilization Rate 65% 67% 86%
Number of Calls 10,398 3,777 Retiree Health Care Calls Answered 9,744 3,266 1) Medical Benefits – General Inquiries Calls Abandoned 654 519 2) Turning Age 65/Part B Premium Calls-Average Speed of Answer 00:01:21 03:44 Reimbursement Number of Emails 314 178 3) Medical-New Enroll/Change/Cancel Emails-Average Response Time 05:58 :8 1 Adjusted for weekends
50%
55%
60%
65%
70%
75%
80%
85%
90%
95%
100%
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16
Quality
Benefits and Member Services
Production and Quality Summary (Rolling 6 Months)
Balance Received Quality
60%
70%
80%
90%
100%
Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16
Pe
rce
nt
Outreach SurveysCall Center
Member Service Center
Workshops
Note: No Member Service Center surveyswere received for June or August 2016.
LACERA’s KEY BUSINESS METRICS
Metrics YTD from July 1, 2016 through August 31, 2016 Page 2
Closed 6 12 Revised/Reconsidered for Granting 0 1 In Process 512 512 In Process 135 135
Active Members as of 9/26/16
Retired Members/Survivors as of 9/26/16
Retired Members Retirees Survivors Total
General-Plan A 233 General-Plan A 19,179 4,703 23,882 Monthly Payroll 251.89 Million General-Plan B 87 General-Plan B 685 63 748 Payroll YTD 501.47 Million General-Plan C 86 General-Plan C 423 57 480 Monthly Added 242 General-Plan D 46,581 General-Plan D 11,873 1,127 13,000 Seamless % 100.00 General-Plan E 20,652 General-Plan E 11,108 922 12,030 YTD Added 473 General-Plan G 15,657 General-Plan G 4 0 4 Seamless YTD % 100.00 Total General 83,296 Total General 43,272 6,872 50,144 Direct Deposit 95.00% Safety-Plan A 11 Safety-Plan A 5,802 1,579 7,381 Safety-Plan B 11,250 Safety-Plan B 4,335 227 4,562 Safety-Plan C 1,355 Safety-Plan C 1 0 1 Total Safety 12,616 Total Safety 10,138 1,806 11,944 TOTAL ACTIVE 95,912 TOTAL RETIRED 53,410 8,678 62,088
Health Care Program (YTD Totals) Funding Metrics as of 6/30/15 Employer Amount Member Amount Employer Normal Cost 9.28%
Medical 75,188,805 6,527,519 11.90% UAAL 8.49% Dental 6,739,428 713,172 7.50% Assumed Rate 7.50% Med Part B 8,685,999 xxxxxxxxxx Star Reserve $614 million Total Amount $90,614,232 $7,240,691 Total Assets $48.8 billion
Health Care Program Enrollments Member Contributions as of 6/30/15 Medical 47,723 Annual Additions $441.3 million Dental 48,751 % of Payroll 6.18% Med Part B 31,235 Employer Contributions as of 6/30/15 Long Term Care (LTC) 750 Annual Addition $1,495million % of Payroll 17.77%
Current Month Current MonthR o l l i n g 6 - M o . A v e r a ge R o l l i n g 6 - M o . A v e r a ge
97.0%
97.5%
98.0%
98.5%
99.0%
99.5%
100.0%
Member Systems lacera.com
SYSTEMS AVAILABILITY - AUGUST 2016
September 26, 2016 Page 3
Date Conference
November, 2016 3-4 Institutional Limited Partners Association (ILPA) General Partner Summit
New York, NY 8-11 SACRS
Indian Wells, CA 13-16 IFEBP (International Foundation of Employment Benefit Plans)
Annual Employee Benefits Conference Orlando, FL
December, 2016 6-7 International Corporate Governance Network (ICGN) London Conference
London, England January, 2017 29-31 NCPERS (National Conference on Public Employee Retirement Systems)
February, 2017 22-24 Pacific Pension Institute (PPI) North American Winter Roundtable
Seattle, WA 23-24 PREA (Pension Real Estate Association) Spring Conference
New York, NY 27-March 1 Council of Institutional Investors (CII) Spring Conference
Washington D.C. March, 2017 1-2 International Corporate Governance Network (ICGN) Washington D.C. Event
Washington D.C. 13-15 IFEBP (International Foundation of Employment Benefit Plans)
Investments Institute Phoenix, AZ
April, 2017 25-26 IFEBP (International Foundation of Employment Benefit Plans)
Benefits Conference for Public Employees (back fr. Public Employee Benefits Update) Columbus, OH
30-May 3 World Healthcare Congress
Washington D.C.
September 29, 2016
TO: Each Member, Board of Investments
Each Member, Board of Retirement FROM: Richard Bendall Chief Audit Executive
Steven P. Rice Chief Counsel FOR: October 12, 2016 | Board of Investments Meeting
October 13, 2016 | Board of Retirement Meeting SUBJECT: 2016 PRIVACY AUDIT – ALSTON & BIRD
(1) Presentation of Final Audit Report, Findings, and Conclusions (2) Recommendation to Approve Alston & Bird’s Final Report as Presented and
Waive Approval by the Audit Committee RECOMMENDATION That the Boards approve Alston & Bird’s Final Report as presented and waive approval by the Audit Committee.
LACERA’s letter agreement with Alston & Bird requires approval of the Final Report by the Audit Committee and Boards. Acceptance is a prerequisite to final payment on the $325,000 contract price. With delivery of the Final Report, Alston & Bird fully and adequately performed its agreed-upon scope of work, as explained in this memo. Staff therefore recommends that the Report be approved by the Boards. Staff further recommends that separate approval by the Audit Committee be waived as a condition of payment in that, if the Report is approved by the Boards, there is no reason to wait until the next Audit Committee meeting in December to complete the approval process.
OVERVIEW In January 2016, following the results of a competitive bidding process, your Boards directed staff to retain Alston & Bird and their subcontractor Stroz Friedberg to perform a comprehensive audit of LACERA’s privacy practices and compliance and to provide a legal opinion on LACERA’s status and compliance obligations under the Health Insurance Portability and Accountability Act (HIPAA).
This work is now completed. Alston & Bird prepared a privileged executive summary and audit report that includes the firm's legal findings, analysis, conclusions, and recommendations. The full final report is attached for your review at Attachment A. The report includes, as
2016 Privacy Audit – Alston & Bird September 29, 2016
appendices, the data maps completed by Stroz Friedberg along with other supporting documents.
The report is protected by the attorney-client privilege, and therefore it is not subject to public disclosure under the Brown Act, Cal. Gov’t Code § 54957.5(a). Alston & Bird prepared an unprivileged PowerPoint slide presentation to accompany the report, which is a public document and will guide the public discussion of the report and Alston & Bird’s findings and recommendations. The slide presentation is provided in Attachment C. The presentation to the Board of Investments will focus on the portion of the report and slides discussing treatment of business critical information within the Investments Division. The presentation to the Board of Retirement will focus on the portion of the report and slides discussing HIPAA and general privacy and data security issues with LACERA’s operations. Notwithstanding the above, Alston & Bird and staff will be prepared to discuss any and all issues in the report and slides with both Boards.
With respect to HIPAA, Alston & Bird concluded that LACERA’s pension operations, including Disability Retirement, are not subject to HIPAA. Alston & Bird also concluded that Retiree Health Care operations need not be subject to HIPAA, provided certain requirements are met.
With respect to compliance with legal requirements, Alston & Bird concludes that LACERA has a culture of respecting privacy and member information and has a number of practices that are consistent with the spirit of applicable laws. Alston & Bird was also directed to consider best practices as well as legal compliance. Alston & Bird provided recommendations and advice to ensure that LACERA is in compliance with the law and best practices.
Overall, Alston & Bird made sixty-five (65) recommendations. Management has reviewed and accepted fifty-nine (59) of these recommendations. The remaining six (6) recommendations were found by management to not be applicable to LACERA’s operating environment. LACERA’s management responses to all sixty-five (65) recommendations are set forth in Attachment B. The responses are presented in matrix format and include: 1) a summary of each recommendation and its location within the report; 2) a statement as to whether management agrees or disagrees with each recommendation; and 3) management’s detailed response to each recommendation. The management responses matrix is a privileged document and not subject to public disclosure.
BACKGROUND
LACERA’s Internal Audit is responsible for including privacy practices in the annual organization-wide risk assessment as well as monitoring and periodically reporting on LACERA’s compliance with privacy policies. However, the Chief Audit Executive also currently serves as LACERA’s Privacy Officer and is responsible for the administration of the LACERA Privacy Program and Policy as well as education and training for all new and current staff on privacy requirements.
Due to this overlap in responsibilities, Internal Audit periodically contracts for a comprehensive independent audit of LACERA’s privacy policy and practices to ensure our compliance with relevant legislation and alignment with prudent industry practices.
Page 2 of 4
2016 Privacy Audit – Alston & Bird September 29, 2016
In January 2016, following the results of a competitive bidding process, your Boards directed staff to retain Alston & Bird and their subcontractor Stroz Friedberg to perform a comprehensive privacy audit.
The purpose of this audit was to have a qualified third party perform a comprehensive study of LACERA’s business operations with the following objectives:
1) To provide a definitive legal opinion on LACERA’s compliance obligations as they relate to the Health Insurance Portability and Accountability Act (HIPAA) and recommendations for changes in privacy policies and practices as necessary to further comply with relevant privacy legislation and best practices;
2) To determine whether LACERA’s data privacy policies and practices are adequate and conform to the requirements of all applicable data protection laws and regulations as well as best practices; and
3) To evaluate LACERA’s handling of business critical information against legal requirements and best practices.
These tasks required an investigation of and test work to verify how personal data, other private information, and business critical information are handled in practice within the various business units, across divisions, and when dealing with third parties.
RESULTS During their audit, Alston & Bird completed interviews of relevant LACERA staff, shadowed employees as they worked, reviewed relevant documents, and performed extensive legal analysis. Overall, Alston & Bird found that LACERA generally conforms to the applicable laws, regulations, and best practices in the areas identified through the audit. The complete results of the work performed are attached to this memo as Attachment A. Alston & Bird also provided certain recommendations and advice related to prudent privacy practices. LACERA’s management responses to all sixty-five (65) recommendations are provided for you in Attachment B.
Please note that Attachments A and B are privileged and confidential attorney-client communications, because the audit was conducted by counsel to evaluate legal issues and provide legal advice. Attachments A and B are provided only to the Board members, but because they are privileged, should not be provided to others, and should not be the subject of detailed discussion at the Board meetings. The presentation slides provided in Attachment C are public and unprivileged information concerning Alston & Bird’s work.
Staff will monitor disposition of Alston & Bird’s recommendations and advice and will report to the Audit Committee and the Boards as appropriate.
Finally, we would like to recognize the high level of commitment, effort, and support provided by LACERA management and staff in facilitating the completion of this project.
RECOMMENDATION
In January 2016, the Boards approved a total fee for Alston & Bird of $350,000, including $25,000 for an earlier scoping project and $325,000 for the final audit itself. The Boards also
Page 3 of 4
2016 Privacy Audit – Alston & Bird September 29, 2016
approved $150,000 for Alston & Bird’s data mapping subcontractor Stroz Friedberg, resulting in a total approved fee for the entire project of $500,000.
On February 3, 2016, LACERA entered into a letter agreement with Alston & Bird. A copy of the agreement is attached as Attachment D. The agreement requires approval of the Final Report by the Boards and the Audit Committee as a prerequisite to final payment on the firm’s fee. Letter Agreement, pages 3-4.
Staff believes that, with delivery of the Final Report, Alston & Bird fully completed the scope of its work, which, under the letter agreement with LACERA, was to provide a report including the following elements:
1. Legal requirements for privacy and data security;
2. Legal analysis of LACERA’s status under HIPAA and the implications of such status with respect to legal requirements;
3. Best practices applicable to LACERA;
4. Actual practices engaged in by LACERA;
5. Gap analysis; and
6. Recommendations.
Letter Agreement, pages 1-2. All these issues are covered in the Final Report. Accordingly, staff recommends that the Boards approve the Report. If the Boards approve the Final Report, staff recommends that the requirement of Audit Committee approval be waived, given that the next Audit Committee meeting is not until December 2016.
With respect to Alston & Bird’s subcontractor Stroz Friedberg, staff requested at the June 2016 Board meetings that the Boards approve a $25,000 additional payment above the $150,000 price originally approved for that vendor. Stroz has withdrawn its request for additional payment, so payment to Stroz is no longer a matter of concern.
Therefore, IT IS RECOMMENDED that the Boards approve Alston & Bird’s Final Report as presented and waive approval by the Audit Committee. Attachments:
A. Final Privacy & Data Security Legal Compliance Assessment Report by Alston & Bird (Privileged, For Board Members Only)
B. Management Responses (Privileged, For Board Members Only)
C. PowerPoint Presentation by Alston & Bird (Public Document)
D. LACERA Engagement Letter – Privacy & Data Security Audit (Public Document)
SR/DV: rb
Page 4 of 4
Final Privacy & Data Security Legal Compliance Assessment Report
Submitted by:
Dominique Shelton and Paula Stannard
October 2016
Overall:
• LACERA has a culture that values
privacy and accomplishes
substantial compliance
• Legal landscape around privacy
and data security
• Best practice recommendations
Privacy & Data Security Legal Compliance Summary of Report
2
HIPAA: • Status of:
− LACERA’s Retirement Pension Operations − LACERA’s Disability Retirement Functions − Retiree Healthcare Program − LACERA’s Retiree Health Care Division
• HIPAA Recommendations/Best Practices
Privacy & Data Security Legal Compliance Summary of Report
3
Privacy & Data Security Legal Compliance Summary of Report
• Best Practices vs. Laws
• General Privacy − Website
− Mobile
• General Data Security − Risk/Threat Landscape
− Policies
− Training
• Business Critical − Public Records Act
− Policies
− Training
4
Alston & Bird’s Methodology
To Assess LACERA’s Policies, Procedures, and
Practices, Alston & Bird:
• Conducted 54 interviews, encompassing 76 employees, all of LACERA’s
operating areas, and selected Board Members from LACERA’s Board of
Investments and Board of Retirement
• Reviewed 336 documents germane to LACERA’s procedures and processes
• Identified 516 data points drawn from federal and state laws, enforcement
orders, and government advisories, plus additional HIPAA legal metrics and
performed a gap analysis of LACERA’s practices against these points
• Shadowed LACERA employees in all divisions in their activities to trace the
physical movement and storage of documents as well as to validate employee
reports pertaining to the storage of electronic data
5
Stroz Friedberg’s Deliverables
Work Completed: • 19 final maps (including diagrams and accompanying summaries) delivered covering
all of LACERA’s operating areas
Map deliverables based upon Stroz Friedberg’s: • Interviews with approximately 60 employees across LACERA
• Analysis of Alston & Bird interview memos and materials provided by interviewees for additional details to cover as many sources as possible
• Shadowing/physical record validation covering all operating areas dealing with sensitive data, to observe physical security practices and the movement and storage of hard copy documents
• Collaborating with division managers and other LACERA personnel for input in creating detailed diagrams regarding LACERA’s data processes
• Collaborating with Alston & Bird to ensure the requisite details for their legal analysis were included and to advise them of select observations of note throughout the interview and shadowing process
6
HIPAA Status & Compliance
What is HIPAA?
HIPAA regulates Covered Entities and their Business Associates:
• Health Plans, Health Care Clearinghouses, Health Care Providers.
• Entities providing services to Covered Entities involving PHI
HIPAA focuses on the functions that make an entity a Covered Entity or a Business Associate:
• Provide Health Care
• Pay for Health Care
• Provide services to/on behalf of a covered entity that involve PHI.
• Exceptions include:
− Enrollment services/enrollment assistance provided for/on behalf of individuals
− Sponsors of Group Health Plans
7
HIPAA’s Application to:
• LACERA’s Retirement Pension Operations
− HIPAA Does Not Apply
• LACERA’s Disability Retirement Function (Disability Retirement Services, Disability Litigation Division, and Disability Counsel)
− HIPAA Does Not Apply
• County Retiree Healthcare Program
− HIPAA Applies, but Does Not Affect LACERA
• LACERA’s Retiree Health Care Division
− HIPAA Does Not Apply, because LACERA Can Comply with the Plan Sponsor Exception
• Why is LACERA’s Status Under HIPAA Important?
HIPAA Status & Compliance
8
Recommendations/Best Practices: • Plan Sponsor Exception
− Appropriate RHC Plan Documents
− Certification of Amendment and Agreement to Comply
− Review and Update RHC Contracts
HIPAA Status & Compliance
9
HIPAA Status & Compliance
Additional Recommendations/Best Practices:
• Group Health Plan − Notice of Privacy Practices
− Privacy Rule Administrative Provisions
− Security Rule
• HIPAA Rules Policies and Procedures
• Documentation of Information Security Decisions
• Personal Representatives
10
Questions?
HIPAA Status & Compliance
11
General Privacy & Data Security
Best Practices & Reasonable Security:
• Security Risk Assessment (SRA)
• Written Information Security Program (WISP)
• Written Policies
• Monitoring and Training
12
General Privacy – In Depth
Best Practices/Considerations: • Website
• Member Calls
13
SSN Recommendation: Employee ID Numbers or Other Unique Identifier
General Data Security – In Depth
14
Other Best Practices
General Data Security – In Depth
• Chief Privacy Officer
• Chief Information Security Officer
• Update Data Maps
• Incidents and Breaches
− Data Breach Response Plans (Non-Technical vs. Technical)
− Post-Incident Response (Lessons Learned Process and
Documentation)
• Vendor Contracts & Management
• Role of the Legal Division
• Policy Updates and Staff Policy
Committee
• Physical Security (Overall, Specific Divisions, Clean
Desk Policy)
• Monitoring
• Training
• Cyber Security Insurance
15
General Privacy & Data Security
Questions?
16
Business Critical Information - Investments
Best Practices/Considerations:
• Alston & Bird found good practices already in place in
LACERA’s Investment Office
• Additional Considerations
17
Best Practices: • Written Procedures for Complying with Public Records Requests
• Definition of “Business Critical Information” to LACERA
• Written Policies re: Confidentiality and Security
• Confidentiality Agreements with Service Providers and Investment Managers
• Accessibility
− Electronic records
− Physical records
• Training
• Closed Board Sessions
• Monitoring and Updating Policies
Business Critical Information - Investments
18
Questions?
Business Critical Information - Investments
19
Thank you for the opportunity to be of service to LACERA!
1A. Phase 1A: General PrivacyDominique Shelton, PaulaStannard, David Caplan,Kim Chemerinsky
106,560$
a. Close review of meeting notes from scoping exercise to create PIIchecklist; and map collective answers to Privacy InterviewQuestionnaire and Data Security Questionnaire.
Dominique Shelton, PaulaStannard
11 5 5 12,117$
b. Review of policies and procedures documents provided fromscoping exercise.
Dominique Shelton, PaulaStannard 25 10 22,546$
c.
High level review of vendor contracts for privacy & security policiesand practices for vendors handling personal information. [Assumeshigh level review of reasonably representative vendor contracts,including at least the 12 agreements supplied in the scopingexercise].
Dominique Shelton, PaulaStannard, David Caplan,Kim Chemerinsky
5 5 5 10 12,580$
d.
Review of LACERA's July 2015 vendor audit to verify LACERA'sthird-party service provider privacy compliance and monitoring(including selected interview of selected direct vendors andsubcontractors responsible for interacting with physicians andmedical information such as Team Legal).
Dominique Shelton, PaulaStannard
5 5 6,460$
e. Review of staff member training regarding privacy & data security.Dominique Shelton, PaulaStannard 7 7 9,044$
f.
Review of network map and review of any written incidentresponse plan or in lieu of same, oral review with senior ITemployee managers of IT's incident response plan procedures torespond to A+B Data Security Questionnaire nos. 36-51, 53-55, 58,60-89, 97-100.
Dominique Shelton, PaulaStannard, KimChemerinsky
10 5 10 14,684$
g,Website review for (Lacera.com); LACERA.com and HR prowebsite to identify compliance with California's Online PrivacyProtection Act (Cal-OPPA)
Dominique Shelton andDavid Caplan
5 10 6,821$
h.Follow up interviews as necessary concluding review of documentsand data map
Dominique Shelton, PaulaStannard, David Caplan
5 5 10 10,073$
i.Review of data map prepared by recommended third party forensicinvestigator.
Dominique Shelton, PaulaStannard
14 5 12,236$
Work Breakdown (Hours)Totals Includes 15% Discount off of 2015 Rates
Alston & Bird Work Plan and Budget Model for LACERA*Total Fees
Shelton MacKay Gorsen Stannard Singleton Chemerinsky Caplan Alston Gage Includes 15% Discount off of 2015 Rates
Phase No. Matter Name/Number Description Team Members
Work Breakdown (Hours)Totals Includes 15% Discount off of 2015 Rates
1B. Phase 1B: HIPAA FactualAssessment Phase
Paula Stannard,Dominique Shelton 31,212$
a.
With respect to the relationship between LACERA and (1) LACounty/LA County Pension Trust Fund, (2) Local 1014, and/or (3)any other governmental entity/governmental employees union forwhich LACERA provides retiree health insurance related services:Review documents relating to the relationship between LACERAand the governmental entity/union and to the services to be providedby LACERA to/for/on behalf of the entity/union, including, e.g., the1937 Act, documents regarding the formation of the LA CountyPension Fund, documents regarding the creation of LACERA, LACounty Board resolutions regarding retiree health insurance, andcontracts between LA County/Pension Fund and LACERAregarding services to be provided by LACERA concerning retireehealth insurance, and any contracts with Local 1014 and any othergovernmental entity/union on the retiree health insurance relatedservices provided by LACERA. (In addition to/to the extent thatsuch review is not encompassed in Phase 1A.)
c.Follow up interviews as necessary concerning services provided to(or on behalf of) LA County/Pension Fund (or such other entities)with respect to retiree health insurance coverage.
Paula Stannard
5 3,251$
d.
Review LACERA’s privacy, information security, and breachnotification policies for compliance with the HIPAA Privacy,Security, and Breach Notification Rules. (In addition to/to theextent that such review is not encompassed in Phase 1A.)
Paula Stannard
10 6,503$
e. Review of existing LACERA notices and forms(authorization/consent) for compliance with HIPAA and theCalifornia Confidentiality of Medical Information Act (CMIA).
Paula Stannard8 5,202$
f.
Review of LACERA training materials with respect to privacy,information security, and security incident/breach issues forcompliance with HIPAA. (In addition to/to the extent that suchreview is not encompassed in Phase 1A.)
*Budget subject to confirmation of actual number of policies to be reviewed and scope of retention.
TOTAL Budget for All Matters
Documents not attached are exempt from
disclosure under the California Public Records Act and other legal authority.
For further information, contact: LACERA
Attention: Public Records Act Requests 300 N. Lake Ave., Suite 620
Pasadena, CA 91101
October 3, 2016 TO: Each Member Board of Investments Board of Retirement
FROM: Barry W. Lew Legislative Affairs Officer FOR: October 12, 2016 Board of Investments Meeting October 13, 2016 Board of Retirement Meeting SUBJECT: LACERA Legislative Policy
RECOMMENDATION That the Board of Investments and Board of Retirement adopt the Legislative Policy.
DISCUSSION
At the Board of Investments meeting on July 13, 2016 and the Board of Retirement meeting on July 14, 2016, your Boards approved the work plan outlined by staff to redevelop the currently separate legislative policies into a single-source joint policy document. The work plan included a review of the draft policy by your Boards in order to propose revisions. The Board of Retirement reviewed and commented on the draft policy at its meeting on August 11, 2016, and the Board of Investments reviewed and commented on the draft policy at its meeting on September 14, 2016. On September 21, 2016, staff also sent a copy of the draft policy to the Intergovernmental and External Relations (IGER) Branch of the Los Angeles County Chief Executive Office for comments. IGER staff reviewed the draft policy and noted that there were no conflicts with the legislative policies approved by the Board of Supervisors. The following is a summary of the changes suggested by each Board. Board of Retirement
Page 13: Indicate when the Board may take a position on a ballot measure. Page 15: Include an overview of the legislative process by which a bill becomes law.
LACERA Legislative Policy Board of Investments Board of Retirement October 3, 2016 Page 2
Board of Investments Page 6: Revise bullet point regarding supporting proposals that promote transparent financial reporting by deleting the reference to generally accepted accounting principles. Page 14: Monthly status report should cover all bills on which the Boards have taken a position, not just bills that are being supported or opposed. Page 14: Provide for a year-end report by staff at the end of each legislative session regarding bills on which the Boards had taken a position and their final disposition.
These changes to the draft policy are highlighted in the redlined copy under Attachment B along with other minor edits. The final copy incorporating the changes is in Attachment A. IT IS THEREFORE RECOMMENDED THAT YOUR BOARDS adopt the Legislative Policy.
Reviewed and Approved:
______________________________ Steven P. Rice, Chief Counsel
Status Reports ..................................................................................................................... 14
Legislative Process ............................................................................................................... 15
Page 3
Statement of Mission and Purpose The Los Angeles County Employees Retirement Association (LACERA) was established under the County Employees Retirement Law of 1937 (CERL) and administers retirement benefits provided by CERL and the California Public Employees’ Pension Reform Act of 2013 (PEPRA). LACERA is governed by the Board of Retirement and the Board of Investments. The Boards have plenary authority and fiduciary responsibility for the system as provided by Section 17 of Article XVI of the California Constitution and in CERL. The Boards have the sole and exclusive fiduciary responsibility to administer the system in a manner that will assure prompt delivery of benefits and related services to its members and beneficiaries. The existence of LACERA and the fiduciary responsibility of its governing Boards are embodied in the organizational mission to produce, protect, and provide the promised benefits. Each element of our mission informs the foundation of this Legislative Policy:
Produce the highest quality of service for our members and sponsors.
Protect the promised benefits through prudent investment and conservation of plan assets.
Provide the promised benefits.
LACERA’s retirement plan benefits are provided by CERL, PEPRA, and other provisions under the California Government Code. As a tax-qualified defined benefit plan, LACERA is also subject to federal law under the Internal Revenue Code. The value to our members of the benefits administered by LACERA may also be affected by other provisions of state and federal law. Changes to provisions that affect LACERA are achieved through the state and federal legislative process and through forms of direct democracy by California voters, which include ballot initiatives and referenda. It is also intended that this policy cover state and federal rulemaking, although such action takes place within the Executive branch of government rather than the Legislative. These various proposals, whether submitted through the state or federal legislative process or through rulemaking, may enhance or detract from LACERA’s administrative capability and mission; they may also further or infringe upon the Boards’ fiduciary responsibilities, member rights and benefits, or LACERA’s mission. As such, the Boards will proactively monitor such proposals and voice its position regarding proposals as described in this policy. LACERA may identify issues that it determines to pursue through sponsorship of legislative proposals. The scope of such issues may vary in applicability to LACERA only or also to other public retirement systems. The diversity of public retirement plans within California implies a diversity of issues that may overlap with or have impact upon other public retirement systems. Consequently, the Boards may directly sponsor
Page 4
legislation or they may co-sponsor legislation with other public retirement systems, through the State Association of County Retirement Systems, or with other parties that may have an alignment of interest with LACERA with respect to an issue or proposal. The purpose of this Legislative Policy is to:
Establish legislative policy standards to guide staff in making recommendations regarding legislative proposals to the Boards.
Define the range of positions that the Boards may take with respect to legislative proposals.
Establish a standard memorandum format to provide legislative analysis and recommendations to the Boards.
Define circumstances in which the Board may need to communicate a position regarding a legislative proposal before the proposal is considered at a regularly scheduled Board meeting.
Establish guidelines for staff and Board actions related to ballot measures.
Provide for status reports of LACERA’s legislative advocacy efforts.
The overall goal of this policy is to provide the Boards with flexibility to pursue legislative action on any and all issues that the Boards may view as affecting LACERA’s mission. This policy shall be reviewed by the Board of Retirement and Board of Investments biannually at the end of each two-year legislative session and may be amended by action of both Boards at any time.
Page 5
Legislative Policy Standards
The legislative policy standards are categorized for the Board of Retirement, the Board of Investments, and both Boards. Legislative action items of interest to the Board of Retirement are first brought before the Board of Retirement’s Insurance, Benefits and Legislative Committee for consideration before being recommended to the Board of Retirement. However, items may go directly to the Board of Retirement for consideration with the agreement of both the Chair of the Board of Retirement and the Chair of the Insurance, Benefits and Legislative Committee. Legislative action items of interest to the Board of Investments are brought directly to the Board of Investments. Legislative action items of interest to both the Board of Retirement and Board of Investments are brought separately to both Boards. However, such items to be considered by the Board of Retirement will first be considered by the Board of Retirement’s Insurance, Benefits, and Legislative Committee before being recommended to the Board of Retirement. The legislative policy standards conceptually relate to LACERA’s mission to produce, protect, and provide the promised benefits; the legislative policy standards also embody the themes of quality of service, prudent investment, conservation of plan assets, and prompt delivery of benefits and services within each element of LACERA’s mission. Legislative proposals or rulemaking that are enacted into law ultimately require implementation by LACERA. The approach staff will take in formulating positions and recommendations is to foster collaboration with divisions within LACERA and resources outside of LACERA, including other public pension systems, LACERA’s legislative advocate, and others whose interests align with LACERA’s or who may have relevant information, to fully assess the impact of proposals. Although the legislative policy standards are intended to guide staff in formulating positions and recommendations to the Boards on legislative proposals or rulemaking, the Boards may in their discretion adopt any position on specific proposals. This policy is not intended to limit the flexibility of the Boards to take a position or other action on any legislative matter or rulemaking that may impact LACERA or its stakeholders, whether or not the specific subject matter is listed in this policy. Board of Retirement
Support proposals that provide the Board of Retirement with increased flexibility in its administration of retirement plans and operations or enable more efficient and effective service to members and stakeholders.
Support proposals that correct structural deficiencies in plan design.
Page 6
Support proposals that provide clarification, technical updates, or conforming changes to the County Employees Retirement Law of 1937, the California Public Employees’ Pension Reform Act of 2013, or other applicable provisions under California law related to public retirement systems.
Support proposals that protect vested benefits or have a positive impact upon LACERA’s members.
Support proposals that seek to prevent fraud in connection with retirement benefits and applications.
Oppose proposals that infringe on the Board of Retirement’s plenary authority or fiduciary responsibility.
Oppose proposals that deprive members of vested benefits.
Oppose proposals that mandate the release of confidential information of members and beneficiaries.
Oppose proposals that jeopardize the tax-exempt status of LACERA’s qualified retirement plan under the Internal Revenue Code and the California Revenue and Taxation Code or the deferred treatment of income tax on employer and employee contributions and related earnings.
Oppose proposals that create unreasonable costs or complexity in the administration of retirement benefits.
Oppose proposals that are contrary to or interfere with the Board of Retirement’s adopted policies or decisions.
Board of Investments
Support proposals that give increased flexibility to the Board of Investments in its investment policy and administration.
Support proposals that preserve the assets and minimize the liabilities of trust funds administered by LACERA.
Support proposals that are consistent with the Board of Investments’ Corporate Governance Principles.
Support proposals that are consistent with the Board of Investments’ Statement of Investment Beliefs.
Support proposals that promote transparent financial reporting.
Page 7
Oppose proposals that infringe on the Board of Investments’ authority over the actuarial valuation process.
Oppose proposals that infringe on the Board of Investments’ plenary authority or fiduciary responsibility, including but not limited to investment mandates or restrictions.
Oppose proposals that create unreasonable costs or complexity in the administration of investments.
Oppose proposals that are contrary to or interfere with the Board of Investment’s adopted policies or decisions.
Board of Retirement & Board of Investments
Support proposals that harmonize the powers and functions of the Board of Retirement and Board of Investments but do not encroach on each Board’s respective separate jurisdiction.
Support proposals that enhance board member education and ethics.
Address proposals related to the administrative budget.
Address proposals related to the appointment of personnel.
Page 8
Definitions of Board Positions SPONSOR OR CO-SPONSOR
Indicates that the proposal was initiated by the Board or that the proposal was
initiated by one or more organizations with which LACERA shares sponsorship.
Authorizes staff to engage with LACERA’s legislative advocate to achieve
passage of the proposal.
SUPPORT
Indicates that the Board believes the proposal should become law.
Authorizes staff to engage with LACERA’s legislative advocate to achieve
passage of the proposal.
SUPPORT IF AMENDED
Indicates that the Board conditionally supports the proposal in becoming law and
that amendments are necessary to facilitate implementation and administration.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and incorporate amendments into the proposal.
NEUTRAL
Indicates that the proposal affects LACERA and its stakeholders, but the Board
neither supports nor opposes it.
Does not require engagement with LACERA’s legislative advocate to achieve
passage or defeat of the proposal.
OPPOSE
Indicates that the Board does not believe the proposal should become law.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and to defeat the proposal.
OPPOSE UNLESS AMENDED
Indicates that the Board conditionally opposes the proposal in becoming law and
that amendments are necessary to remove the Board’s opposition.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and to incorporate amendments into the proposal.
Page 9
WATCH
Indicates that the proposal does not affect LACERA and its stakeholders but
would be enacted under a law that covers LACERA such as CERL or PEPRA.
Indicates that proposal will be resubmitted to the Board for consideration if
amendments cause the proposal to affect LACERA and its stakeholders.
Once the Board has acted, these positions will typically be communicated by means of a letter from the Chief Executive Officer to the appropriate legislative officers. Staff coordinates with LACERA’s legislative advocate in preparing this letter and developing a communication and distribution strategy for the letter, which may include verbal communications by the legislative advocate with relevant legislators and/or legislative staff. In the rulemaking context, LACERA’s positions will typically be communicated to the enacting state or federal agency by means of a comment letter where the agency has provided an opportunity for public comment on a proposed rule before it is finalized and becomes effective.
Page 10
Legislative Analysis Memorandum Format The following is an outline of the format of the legislative analysis memorandum provided by staff. In general, the memorandum will follow this format but may be modified for specific cases.
Page 11
Date TO: FROM: FOR: SUBJECT: Bill Number Author: Sponsor: Introduced: Amended: Status: Board Position: Committee Recommendation: Staff Recommendation: [If the memo addresses rulemaking, the Subject section will provide similar relevant information.]
RECOMMENDATION [This section states staff’s or the Committee’s recommendation to the Board.]
LEGISLATIVE POLICY STANDARD [This section discusses the application of LACERA’s legislative policy standards to the proposal and the justification for the recommendation to the Board.]
SUMMARY [This section describes the provisions of the proposal and the key additions or updates the proposal makes to existing law.]
ANALYSIS [This section provides an analysis of the effects and implications of the proposal on LACERA.]
IT IS THEREFORE RECOMMENDED THAT YOUR BOARD [This section restates staff’s or the Committee’s recommendation and summary or concluding comments.]
Attachments Attachment 1—Board Positions Adopted On Related Legislation [This attachment states the positions the Board has previously taken on the subject matter of the bill.]
Attachment 2—Support And Opposition [This attachment identifies those entities that have already taken a position on the bill.]
Bill Text
Page 12
Action between Board Meetings The Board of Retirement generally meets twice a month, including a disability meeting on the first Wednesday and an administrative meeting on the Thursday following the second Wednesday; the Board of Investments meets once a month on the second Wednesday. The meeting schedules of the Boards do not necessarily accord with the hearing schedules and deadlines of the Legislature. The policy will provide direction for staff to engage with LACERA’s legislative advocate to communicate a position on amendments to a bill before formal consideration by the Board of Retirement or Board of Investments if all the following conditions are met:
1. The Board had adopted a Support, Support If Amended, Oppose, or Oppose Unless Amended position on the bill before it was amended.
2. Substantive amendments that may justify a change in the Board’s position to other than Neutral or Watch have occurred in the bill after the Board adopted a position and before the next regularly scheduled board meeting.
3. Consideration of the amended bill by a legislative committee or by the Assembly or Senate floor will occur before the amended bill can be considered at the next regularly scheduled board meeting.
Staff will take the following actions:
1. Prepare a legislative analysis of the amended bill for use in consultation.
2. Consult with the Chief Counsel, Chief Executive Officer, and legislative advocate for input regarding the amended bill to determine if the new position should be communicated to the Legislature.
3. If the new position should be communicated to the Legislature, consult with the Chair (or if not available, the Vice Chair) of the Board that has jurisdiction over the subject matter of the amended bill and obtain approval that the new position be communicated.
4. At the next regularly scheduled Board meeting, present a report to the Board regarding the position communicated in Step 3 and a summary of actions taken.
Page 13
Ballot Measures California law provides for citizens to use ballot measures to initiate a state statute or a constitutional amendment or to repeal legislation through a veto referendum. The California State Legislature may also use ballot measures to offer legislatively referred state statutes or constitutional amendments. In general, a government agency may not spend public funds for a partisan campaign advocating the passage or defeat of a ballot measure. It is, however, permissible for a government agency to engage in informational activities. What distinguishes informational activities from campaign activities depends on the style, tenor, and timing of the activity. From time to time, ballot measures may be offered that are related to public retirement plans. The following guidelines are intended to provide guidance on actions that may be taken with respect to ballot measures on public retirement plans:
Providing informational staff reports and analysis on the ballot measure’s effect in a meeting open to the public.
Providing a recommendation for the Board to take a position on the ballot measure in a meeting open to the public where all perspectives can be shared. (The Board may or may not take a position on any ballot measure. The Board may take a position when it determines it is necessary to publicly express its opinion for or against a matter on which it feels strongly with respect to its impact on LACERA.)
Providing the Board’s position and views on the ballot measure’s merits and effects to interested stakeholders and organizations.
Responding to inquiries from stakeholders and the public regarding the Board’s position and views on the ballot measure.
The Fair Political Practices Commission (FPPC) was created by the Political Reform Act and requires government agencies to report expenses used to advocate or unambiguously urge the passage or defeat of a measure in an election. The FPPC also prohibits government agencies from paying for communication materials that advocate or unambiguously urge the passage or defeat of a measure in an election. LACERA must be cautious in not engaging in activities that can be characterized as campaign activities, which are prohibited and would be subject to campaign expenditure reporting requirements. Therefore, all activities related to ballot measures are subject to review by Chief Counsel.
Page 14
Status Reports For bills on which the Boards have taken a position, staff will provide a monthly status report listing each bill, its current status in the legislative process, and copies of communications used for lobbying the Legislature. The status report will be included in the green folders provided to the Board of Retirement and Board of Investments before regularly scheduled board meetings. At the end of each legislative session, staff will provide a year-end report of all the bills on which the Boards had taken a position and their final disposition.
Page 15
Legislative Process The following pages include an outline1 and a flowchart2 of the California legislative process through which a bill becomes law. In general, bills in the federal legislative process move through similar stages.
1 Overview of Legislative Process – Official California Legislative Information (http://www.leginfo.ca.gov/bil2lawx.html). 2 The Life Cycle of Legislation: From Idea into Law. California Legislature: Assembly Rules Committee.
OVERVIEW OF LEGISLATIVE PROCESS
The process of government by which bills are considered and laws enacted is commonly referred to as theLegislative Process. The California State Legislature is made up of two houses: the Senate and the Assembly.There are 40 Senators and 80 Assembly Members representing the people of the State of California. TheLegislature has a legislative calendar containing important dates of activities during its two-year session.
Idea
All legislation begins as an idea or concept. Ideas and concepts can come from a variety of sources. Theprocess begins when a Senator or Assembly Member decides to author a bill.
The Author
A Legislator sends the idea for the bill to the Legislative Counsel where it is drafted into the actual bill. Thedraft of the bill is returned to the Legislator for introduction. If the author is a Senator, the bill is introduced inthe Senate. If the author is an Assembly Member, the bill is introduced in the Assembly.
First Reading/Introduction
A bill is introduced or read the first time when the bill number, the name of the author, and the descriptivetitle of the bill is read on the floor of the house. The bill is then sent to the Office of State Printing. No billmay be acted upon until 30 days has passed from the date of its introduction.
Committee Hearings
The bill then goes to the Rules Committee of the house of origin where it is assigned to the appropriate policycommittee for its first hearing. Bills are assigned to policy committees according to subject area of the bill.For example, a Senate bill dealing with health care facilities would first be assigned to the Senate Health andHuman Services Committee for policy review. Bills that require the expenditure of funds must also be heardin the fiscal committees: Senate Appropriations or Assembly Appropriations. Each house has a number ofpolicy committees and a fiscal committee. Each committee is made up of a specified number of Senators orAssembly Members.
During the committee hearing the author presents the bill to the committee and testimony can be heard insupport of or opposition to the bill. The committee then votes by passing the bill, passing the bill as amended,or defeating the bill. Bills can be amended several times. Letters of support or opposition are important andshould be mailed to the author and committee members before the bill is scheduled to be heard in committee.It takes a majority vote of the full committee membership for a bill to be passed by the committee.
Each house maintains a schedule of legislative committee hearings. Prior to a bill's hearing, a bill analysis isprepared that explains current law, what the bill is intended to do, and some background information.Typically the analysis also lists organizations that support or oppose the bill.
Second and Third Reading
Bills passed by committees are read a second time on the floor in the house of origin and then assigned tothird reading. Bill analyses are also prepared prior to third reading. When a bill is read the third time it isexplained by the author, discussed by the Members and voted on by a roll call vote. Bills that require anappropriation or that take effect immediately, generally require 27 votes in the Senate and 54 votes in theAssembly to be passed. Other bills generally require 21 votes in the Senate and 41 votes in the Assembly. If a
bill is defeated, the Member may seek reconsideration and another vote.
Repeat Process in other House
Once the bill has been approved by the house of origin it proceeds to the other house where the procedure isrepeated.
Resolution of Differences
If a bill is amended in the second house, it must go back to the house of origin for concurrence, which isagreement on the amendments. If agreement cannot be reached, the bill is referred to a two house conferencecommittee to resolve differences. Three members of the committee are from the Senate and three are from theAssembly. If a compromise is reached, the bill is returned to both houses for a vote.
Governor
If both houses approve a bill, it then goes to the Governor. The Governor has three choices. The Governorcan sign the bill into law, allow it to become law without his or her signature, or veto it. A governor's veto canbe overridden by a two thirds vote in both houses. Most bills go into effect on the first day of January of thenext year. Urgency measures take effect immediately after they are signed or allowed to become law withoutsignature.
California Law
Bills that are passed by the Legislature and approved by the Governor are assigned a chapter number by theSecretary of State. These Chaptered Bills (also referred to as Statutes of the year they were enacted) thenbecome part of the California Codes. The California Codes are a comprehensive collection of laws groupedby subject matter.
The California Constitution sets forth the fundamental laws by which the State of California is governed. Allamendments to the Constitution come about as a result of constitutional amendments presented to the peoplefor their approval.
HELD IN
COMMITTEE
PASSAGE REFUSED
PASSAGE REFUSED
HELD IN
COMMITTEE
COMMITTEERECOMENDATIONSPASS
ProposedAmendments
RevisedThird
ReadingAnalysis
TO ASSEMBLYCOMMITTEERECOMENDATIONSPASS
HELD IN
COMMITTEE
COMMITTEERECOMENDATIONSPASS
ASSEMBLYBILL
PREPAREDBY
LEGISLATIVE COUNSEL
SENATEBILL
PREPAREDBY
LEGISLATIVE COUNSEL
RULESCOMMITTEE
ASSIGNSBILL TO
COMMITTEE
Bill may not be heard by committee until 31st day after
introduction
COMMITTEE HEARING:Policy or Appropriations
CHAIRPERSONAND MEMBERS
TESTIFY:BILL AUTHOR
CITIZENSEXPERTS
LOBBYISTS
RULESCOMMITTEE
ASSIGNSBILLS TO
COMMITTEE
SECONDSENATEREADING
THIRDSENATEREADINGDEBATE
VOTE
FIRSTASSEMBLYREADING
COMMITTEE HEARING:Policy or Appropriations
CHAIRPERSONAND MEMBERS
TESTIMONY BY:BILL AUTHOR
CITIZENSEXPERTS
LOBBYISTS
THIRDASSEMBLYREADINGDEBATE
VOTE
THE LIFE CYCLE OF LEGISLATIONFrom Idea into Law
INTRODUCEDBY
MEMBER,NUMBERED,
FIRSTREADING,PRINTED
RULESCOMMITTEE
ASSIGNSBILL TO
COMMITTEE
Bill may not be heard by committee until 31st day after
introduction
COMMITTEE HEARING:Policy or Appropriations
CHAIRPERSONAND MEMBERS
TESTIFY:BILL AUTHOR
CITIZENSEXPERTS
LOBBYISTS
RULESASSIGNSBILLS TO
COMMITTEE
THE CALIFORNIA LEGISLATURE
A S S E M B LY R U L E S C O M M I T T E E
Although the procedure can become complicated, this chart shows the essential steps for passage of a bill.
Typical committee actions are used to simplify charting the course of legislation.
Some bills require hearings by more than one committee, in which case a committee may re–refer the bill to another committee. For example, bills with monetary implications must be re–referred to the proper fiscal committee in each House before they are sent to the second reading file and final action.
A bill may be amended at various times as it moves through the Houses. The bill must be reprinted each time an amendment is adopted by either house. All bill actions are printed in the DAILY FILES, JOURNALS and HISTORIES.
If a bill is amended in the opposite House, it is returned to the House of Origin for concurrence in amendments. If House of Origin does not concur, a Conference Committee Report must then be adopted by each House before the bill can be sent to the Governor.
SU
GG
ES
TIO
NS
FO
R N
EE
DE
D L
EG
ISL
AT
ION
FR
OM
Ag
enci
es, C
itiz
ens,
Gov
ern
or,
Lo
bby
ists
ASSEMBLYMEMBER
SENATOR
SECONDASSEMBLYREADING
THIRDASSEMBLY READINGDEBATE
VOTE
FIRSTSENATEREADING
COMMITTEE HEARING:Policy or Appropriations
CHAIRPERSONAND MEMBERS
TESTIMONY BY:BILL AUTHOR
CITIZENSEXPERTS
LOBBYISTS
THIRDSENATEREADINGDEBATE
VOTE
RevisedThirdReadingAnalysis
GOVERNOR
RETURN TO ASSEMBLY FLOORConcurrence in Senate Amendments
YES NO
CONFERENCE COMMITTEE3 AssemblyMembers
3 SenateMembers
CONFERENCE REPORT
ASSEMBLYand
SENATEAdopt
ConferenceReport
YES NO
*Follow sameprocedures
as in theAssembly
RETURN TO SENATE FLOORConcurrence in Assembly Amendments
Bill becomes law January 1st of the following year unless it contains an urgency clause (takes effect immediately) or specifies its own effective date.
ProposedAmendments
PASSED WITH SENATE AMENDMENTS
WIT
HO
UT
SENATE AM
END
MEN
TS
SIGN
PASSED WITH ASSEMBLY AMENDMENTS
WIT
HO
UT
ASSEMBLY AM
END
MEN
TS
BECOMES LAW WITHOUT SIGNATURE
VETO
ProposedAmendments
RevisedThird
ReadingAnalysis
SECONDSENATEREADING
SECONDASSEMBLYREADING
** Assembly policy committeewill do Governor's Veto analysis
PASSAGE REFUSED
INTRODUCEDBY
MEMBER,NUMBERED,
FIRSTREADING,PRINTED
TO SENATE
PASSAGE REFUSED
HELD IN
COMMITTEE
COMMITTEERECOMENDATIONSPASS
RevisedThirdReadingAnalysis
ProposedAmendments
ATTACHMENT B
Draft.08-01-16
LACERA LEGISLATIVE POLICY
Restated Board of Retirement: and Approved: Board of Investments:
Draft.08-01-16
Page 2
Table of Contents
Statement of Mission and Purpose ........................................................................................ 3
Status Reports ..................................................................................................................... 14
Draft.08-01-16
Page 3
Statement of Mission and Purpose The Los Angeles County Employees Retirement Association (LACERA) was established under the County Employees Retirement Law of 1937 (CERL) and administers retirement benefits provided by CERL and the California Public Employees’ Pension Reform Act of 2013 (PEPRA). LACERA is governed by the Board of Retirement and the Board of Investments. The Boards have plenary authority and fiduciary responsibility for the system as provided by Section 17 of Article XVI of the California Constitution and in CERL. The Boards have the sole and exclusive fiduciary responsibility to administer the system in a manner that will assure prompt delivery of benefits and related services to its members and beneficiaries. The existence of LACERA and the fiduciary responsibility of its governing Boards are embodied in the organizational mission to produce, protect, and provide the promised benefits. Each element of our mission informs the foundation of this Legislative Policy:
Produce the highest quality of service for our members and sponsors.
Protect the promised benefits through prudent investment and conservation of plan assets.
Provide the promised benefits.
LACERA’s retirement plan benefits are provided by CERL, PEPRA, and other provisions under the California Government Code. As a tax-qualified defined benefit plan, LACERA is also subject to federal law under the Internal Revenue Code. The value to our members of the benefits administered by LACERA may also be affected by other provisions of state and federal law. Changes to provisions that affect LACERA are achieved through the state and federal legislative process and through forms of direct democracy by California voters, which include ballot initiatives and referenda. It is also intended that this policy cover state and federal rulemaking, although such action takes place within the Executive branch of government rather than the Legislative. These various proposals, whether submitted through the state or federal legislative process or through rulemaking, may enhance or detract from LACERA’s administrative capability and mission; they may also further or infringe upon the Boards’ fiduciary responsibilities, member rights and benefits, or LACERA’s mission. As such, the Boards will proactively monitor such proposals and voice its position regarding proposals as described in this policy. LACERA may identify issues that it determines to pursue through sponsorship of legislative proposals. The scope of such issues may vary in applicability to LACERA only or also to other public retirement systems. The diversity of public retirement plans within California implies a diversity of issues that may overlap with or have impact upon
Draft.08-01-16
Page 4
other public retirement systems. Consequently, the Boards may directly sponsor legislation or they may co-sponsor legislation with other public retirement systems, through the State Association of County Retirement Systems, or with other parties that may have an alignment of interest with LACERA with respect to an issue or proposal. The purpose of this Legislative Policy is to:
Establish legislative policy standards to guide staff in making recommendations regarding legislative proposals to the Boards.
Define the range of positions that the Boards may take with respect to legislative proposals.
Establish a standard memorandum format to provide legislative analysis and recommendations to the Boards.
Define circumstances in which the Board may need to communicate a position regarding a legislative proposal before the proposal is considered at a regularly scheduled Board meeting.
Establish guidelines for staff and Board actions related to ballot measures.
Provide for status reports of LACERA’s legislative advocacy efforts.
The overall goal of this policy is to provide the Boards with flexibility to pursue legislative action on any and all issues that the Boards may view as affecting LACERA’s mission. This policy shall be reviewed by the Board of Retirement and Board of Investments biannually at the end of each two-year legislative session and may be amended by action of both Boards at any time.
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Legislative Policy Standards
The legislative policy standards are categorized for the Board of Retirement, the Board of Investments, and both Boards. Legislative action items of interest to the Board of Retirement are first brought before the Board of Retirement’s Insurance, Benefits and Legislative Committee for consideration before being recommended to the Board of Retirement. However, items may go directly to the Board of Retirement for consideration with the agreement of both the Chair of the Board of Retirement and the Chair of the Insurance, Benefits and Legislative Committee. Legislative action items of interest to the Board of Investments are brought directly to the Board of Investments. Legislative action items of interest to both the Board of Retirement and Board of Investments are brought separately to both Boards. However, such items to be considered by the Board of Retirement will first be considered by the Board of Retirement’s Insurance, Benefits, and Legislative Committee before being recommended to the Board of Retirement. The legislative policy standards conceptually relate to LACERA’s mission to produce, protect, and provide the promised benefits; the legislative policy standards also embody the themes of quality of service, prudent investment, conservation of plan assets, and prompt delivery of benefits and services within each element of LACERA’s mission. Legislative proposals or rulemaking that are enacted into law ultimately require implementation by LACERA. The approach staff will take in formulating positions and recommendations is to foster collaboration with divisions within LACERA and resources outside of LACERA, including other public pension systems, LACERA’s legislative advocate, and others whose interests align with LACERA’s or who may have relevant information, to fully assess the impact of proposals. Although the legislative policy standards are intended to guide staff in formulating positions and recommendations to the Boards on legislative proposals or rulemaking, the Boards may in their discretion adopt any position on specific proposals. This policy is not intended to limit the flexibility of the Boards to take a position or other action on any legislative matter or rulemaking that may impact LACERA or its stakeholders, whether or not the specific subject matter is listed in this policy. Board of Retirement
Support proposals that provide the Board of Retirement with increased flexibility in its administration of retirement plans and operations or enable more efficient and effective service to members and stakeholders.
Support proposals that correct structural deficiencies in plan design.
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Support proposals that provide clarification, technical updates, or conforming changes to the County Employees Retirement Law of 1937, the California Public Employees’ Pension Reform Act of 2013, or other applicable provisions under California law related to public retirement systems.
Support proposals that protect vested benefits or have a positive impact upon LACERA’s members.
Support proposals that seek to prevent fraud in connection with retirement benefits and applications.
Oppose proposals that infringe on the Board of Retirement’s plenary authority or fiduciary responsibility.
Oppose proposals that deprive members of vested benefits.
Oppose proposals that mandate the release of confidential information of members and beneficiaries.
Oppose proposals that jeopardize the tax-exempt status of LACERA’s qualified retirement plan under the Internal Revenue Code and the California Revenue and Taxation Code or the deferred treatment of income tax on employer and employee contributions and related earnings.
Oppose proposals that create unreasonable costs or complexity in the administration of retirement benefits.
Oppose proposals that are contrary to or interfere with the Board of Retirement’s adopted policies or decisions.
Board of Investments
Support proposals that give increased flexibility to the Board of Investments in its investment policy and administration.
Support proposals that preserve the assets and minimize the liabilities of trust funds administered by LACERA.
Support proposals that are consistent with the Board of Investments’ Corporate Governance Principles.
Support proposals that are consistent with the Board of Investments’ Statement of Investment Beliefs.
Support proposals that promote transparent financial reporting in accordance with generally accepted accounting principles.
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Oppose proposals that infringe on the Board of Investments’ authority over the actuarial valuation process.
Oppose proposals that infringe on the Board of Investments’ plenary authority or fiduciary responsibility, including but not limited to investment mandates or restrictions.
Oppose proposals that create unreasonable costs or complexity in the administration of investments.
Oppose proposals that are contrary to or interfere with the Board of Investment’s adopted policies or decisions.
Board of Retirement & Board of Investments
Support proposals that harmonize the powers and functions of the Board of Retirement and Board of Investments but do not encroach on each Board’s respective separate jurisdiction.
Support proposals that enhance board member education and ethics.
Address proposals related to the administrative budget.
Address proposals related to the appointment of personnel.
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Definitions of Board Positions SPONSOR OR CO-SPONSOR
Indicates that the proposal was initiated by the Board or that the proposal was
initiated by one or more organizations with which LACERA shares sponsorship.
Authorizes staff to engage with LACERA’s legislative advocate to achieve
passage of the proposal.
SUPPORT
Indicates that the Board believes the proposal should become law.
Authorizes staff to engage with LACERA’s legislative advocate to achieve
passage of the proposal.
SUPPORT IF AMENDED
Indicates that the Board conditionally supports the proposal in becoming law and
that amendments are necessary to facilitate implementation and administration.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and incorporate amendments into the proposal.
NEUTRAL
Indicates that the proposal affects LACERA and its stakeholders, but the Board
neither supports nor opposes it.
Does not require engagement with LACERA’s legislative advocate to achieve
passage or defeat of the proposal.
OPPOSE
Indicates that the Board does not believe the proposal should become law.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and to defeat the proposal.
OPPOSE UNLESS AMENDED
Indicates that the Board conditionally opposes the proposal in becoming law and
that amendments are necessary to remove the Board’s opposition.
Authorizes staff to engage with LACERA’s legislative advocate to communicate
the Board’s position and to incorporate amendments into the proposal.
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WATCH
Indicates that the proposal does not affect LACERA and its stakeholders but
would be enacted under a law that covers LACERA such as CERL or PEPRA.
Indicates that proposal will be resubmitted to the Board for consideration if
amendments cause the proposal to affect LACERA and its stakeholders.
Once the Board has acted, these positions will typically be communicated by means of a letter from the Chief Executive Officer to the appropriate legislative officers. Staff coordinates with LACERA’s legislative advocate in preparing this letter and developing a communication and distribution strategy for the letter, which may include verbal communications by the legislative advocate with relevant legislators and/or legislative staff. In the rulemaking context, LACERA’s positions will typically be communicated to the enacting state or federal agency by means of a comment letter where the agency has provided an opportunity for public comment on a proposed rule before it is finalized and becomes effective.
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Legislative Analysis Memorandum Format The following is an outline of the format of the legislative analysis memorandum provided by staff. In general, the memorandum will follow this format but may be modified for specific cases.
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Date TO: FROM: FOR: SUBJECT: Bill Number Author: Sponsor: Introduced: Amended: Status: Board Position: Committee Recommendation: Staff Recommendation: [If the memo addresses rulemaking, the Subject section will provide similar relevant information.]
RECOMMENDATION [This section states staff’s or the Committee’s recommendation to the Board.]
LEGISLATIVE POLICY STANDARD [This section discusses the application of LACERA’s legislative policy standards to the proposal and the justification for the recommendation to the Board.]
SUMMARY [This section describes the provisions of the proposal and the key additions or updates the proposal makes to existing law.]
ANALYSIS [This section provides an analysis of the effects and implications of the proposal on LACERA.]
IT IS THEREFORE RECOMMENDED THAT YOUR BOARD [This section restates staff’s or the Committee’s recommendation and summary or concluding comments.]
Attachments Attachment 1—Board Positions Adopted On Related Legislation [This attachment states the positions the Board has previously taken on the subject matter of the bill.]
Attachment 2—Support And Opposition [This attachment identifies those entities that have already taken a position on the bill.]
Bill Text
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Action between Board Meetings The Board of Retirement generally meets twice a month, including a disability meeting on the first Wednesday and an administrative meeting on the Thursday following the second Wednesday; the Board of Investments meets once a month on the second Wednesday. The meeting schedules of the Boards do not necessarily accord with the hearing schedules and deadlines of the Legislature. The policy will provide direction for staff to engage with LACERA’s legislative advocate to communicate a position on amendments to a bill before formal consideration by the Board of Retirement or Board of Investments if all the following conditions are met:
1. The Board had adopted a Support, Support If Amended, Oppose, or Oppose Unless Amended position on the bill before it was amended.
2. Substantive amendments that may justify a change in the Board’s position to other than Neutral or Watch have occurred in the bill after the Board adopted a position and before the next regularly scheduled board meeting.
3. Consideration of the amended bill by a legislative committee or by the Assembly or Senate floor will occur before the amended bill can be considered at the next regularly scheduled board meeting.
Staff will take the following actions:
1. Prepare a legislative analysis of the amended bill for use in consultation.
2. Consult with the Chief Counsel, Chief Executive Officer, and legislative advocate for input regarding the amended bill to determine if the new position should be communicated to the Legislature.
3. If the new position should be communicated to the Legislature, consult with the Chair (or if not available, the Vice Chair) of the Board that has jurisdiction over the subject matter of the amended bill and obtain approval that the new position be communicated.
4. At the next regularly scheduled Board meeting, present a report to the Board regarding the position communicated in Step 3 and a summary of actions taken.
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Ballot Measures California law provides for citizens to use ballot measures to initiate a state statute or a constitutional amendment or to repeal legislation through a veto referendum. The California State Legislature may also use ballot measures to offer legislatively referred state statutes or constitutional amendments. In general, a government agency may not spend public funds for a partisan campaign advocating the passage or defeat of a ballot measure. It is, however, permissible for a government agency to engage in informational activities. What distinguishes informational activities from campaign activities depends on the style, tenor, and timing of the activity. From time to time, ballot measures may be offered that are related to public retirement plans. The following guidelines are intended to provide guidance on actions that may be taken with respect to ballot measures on public retirement plans:
Providing informational staff reports and analysis on the ballot measure’s effect in a meeting open to the public.
Providing a recommendation for the Board to take a position on the ballot measure in a meeting open to the public where all perspectives can be shared. (The Board may or may not take a position on any ballot measure. The Board may take a position when it determines it is necessary to publicly express its opinion for or against a matter on which it feels strongly with respect to its impact on LACERA.)
Providing the Board’s position and views on the ballot measure’s merits and effects to interested stakeholders and organizations.
Responding to inquiries from stakeholders and the public regarding the Board’s position and views on the ballot measure.
The Fair Political Practices Commission (FPPC) was created by the Political Reform Act and requires government agencies to report expenses used to advocate or unambiguously urge the passage or defeat of a measure in an election. The FPPC also prohibits government agencies from paying for communication materials that advocate or unambiguously urge the passage or defeat of a measure in an election. LACERA must be cautious in not engaging in activities that can be characterized as campaign activities, which are prohibited and would be subject to campaign expenditure reporting requirements. Therefore, all activities related to ballot measures are subject to review by Chief Counsel.
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Status Reports For bills that the Boards are actively supporting or opposingon which the Boards have taken a position, staff will provide a monthly status report listing each bill, its current status in the legislative process, and copies of communications used for lobbying the Legislature. The status report will be included in the green folders provided to the Board of Retirement and Board of Investments before regularly scheduled board meetings. Staff will provide the current status of all monitored legislation on a monthly basis in legislative charts that are included in the green folders provided to the Board of Retirement and Board of Investments before each regularly scheduled board meeting.At the end of each legislative session, staff will provide a year-end report of all the bills on which the Boards had taken a position and their final disposition.
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Legislative Process The following pages include an outline1 and a flowchart2 of the California legislative process through which a bill becomes law. In general, bills in the federal legislative process move through similar stages.
1 Overview of Legislative Process – Official California Legislative Information (http://www.leginfo.ca.gov/bil2lawx.html). 2 The Life Cycle of Legislation: From Idea into Law. California Legislature: Assembly Rules Committee.
September 26, 2016
FOR INFORMATION ONLY TO: Each Member Board of Investments Board of Retirement
FROM: Barry W. Lew Legislative Affairs Officer
FOR: October 12, 2016 Board of Investments Meeting
October 13, 2016 Board of Retirement Meeting SUBJECT: Update on Assembly Bill 1853 – County Employees Retirement
Districts AB 1853 would provide the retirement board of any retirement system operating under the County Employees Retirement Law of 1937 with the ability, subject to certain procedures, to adopt a resolution to become a district, which would enable the employees of the retirement system, who are currently employed by the county, to be directly employed by the retirement system. The Board of Investments adopted a “Watch” position on AB 1853 on July 13, 2016, and the Board of Retirement adopted an “Oppose” position on AB 1853 on July 14, 2016. On September 23, 2016, Governor Jerry Brown vetoed AB 1853. Attached is his veto message, which states that the bill was too far-reaching and that a collaborative approach between a county and its retirement system better serves the public interest.
Reviewed and Approved:
______________________________ Steven P. Rice, Chief Counsel
Board of Investments FROM: Beulah S. Auten, CPA, CGFM, CGMA
Chief Financial Officer FOR: October 12, 2016 – Board of Investments Meeting SUBJECT: Semi-Annual Interest Crediting for Reserves as of June 30, 2016 (Audited) Pursuant to the County Employees Retirement Law Section 31591, regular interest shall be credited semi-annually on June 30 and December 31 to all contributions in the retirement fund, which have been on deposit six months immediately prior to such date at an interest rate of 2.5% per annum, until otherwise determined by your Board. The semi-annual interest crediting rate applicable for June 30, 2016 was 3.75% (i.e., 7.50% annual rate). You may recall that in October 2011, your Board approved to reduce the assumed actuarial earnings rate over a three-year period from 7.75% to 7.50%. The existing rate of 7.50% was implemented with your Board’s adoption of the June 30, 2013 actuarial valuation. To provide ample time for both the plan sponsor and LACERA to prepare for the rate change implementation, the existing 7.50% rate became effective July 1, 2014, which was also when the corresponding employee contribution rates as recommended in the June 30, 2013 valuation report, took effect. Going forward, this annual rate of 7.50% remains in effect unless your Board adopts a different rate. The Retirement Benefit Funding Policy stipulates that interest credits for Reserve accounts are allocated in the same priority order as the allocation of actuarial assets. Such interest credits are granted based on Realized Earnings for the period. The allocation of Realized Earnings is performed twice each year on June 30 and December 31. As of June 30, 2016, all available Realized Earnings, which were less than the required interest credit rate of 3.75%, were applied to the Member Reserves. Thus, there were no additional earnings available to apply to other priorities. Also, there was no Advanced Employer Contributions Reserve balance for the fiscal year 2015-2016. The table below depicts the actual interest credit allocations for the six-month period ended June 30, 2016.
Priority Order Reserve Account Interest Rate Applied
1 Member 3.58%
2 Advanced Employer Contributions N/A
3 Employer 0.00%
At their respective meetings last month, LACERA’s Chief Executive Officer provided both Boards a preview of unanticipated changes to the unaudited versus the audited interest crediting rates applied to the Reserve accounts. Specifically, the reduction of the interest crediting rate allocated to the Member Reserves from the initial estimate of 3.75% (unaudited) to 3.58% based on audited financial results. There was a similar change in the interest crediting rate allocated to the Employer Reserves from the initial estimate of 0.24% (unaudited) to a 0.00% audited rate. LACERA’s external auditor has been
Semi-Annual Interest Crediting for Reserves as of June 30, 2016 (Audited) October 4, 2016 Page 2 apprised of this situation and determined there is no material impact to the June 30, 2016 financial statements. Staff will be briefing the Board of Retirement’s Operations Oversight Committee at its next meeting regarding the impact to members’ accounts. Additionally, staff will be performing a root cause analysis of this event and determine the best way to mitigate risks in the future. REVIEWED AND APPROVED: ______________________________ GREGG RADEMACHER Chief Executive Officer Interest Credit Rate Jun 2016 (audited)_final.doc GR:BSA:tg
c: Board of Retirement, LACERA Sachi A. Hamai, CEO, Los Angeles County
Documents not attached are exempt from
disclosure under the California Public Records Act and other legal authority.
For further information, contact: LACERA
Attention: Public Records Act Requests 300 N. Lake Ave., Suite 620
Pasadena, CA 91101
Documents not attached are exempt from
disclosure under the California Public Records Act and other legal authority.
For further information, contact: LACERA
Attention: Public Records Act Requests 300 N. Lake Ave., Suite 620
Pasadena, CA 91101
Documents not attached are exempt from
disclosure under the California Public Records Act and other legal authority.
For further information, contact: LACERA
Attention: Public Records Act Requests 300 N. Lake Ave., Suite 620
