To Affirm Concordia Plans and To Amend Bylaws to Require Annual ERISA- Comparable Transparency to Participants

WHEREAS, “The synodwide trust entities of The Lutheran Church—Missouri Synod are collectively known as the Concordia Plans” (Bylaw 3.7.1) and provide essential retirement, health, disability, and related benefits for church workers and retirees; and

WHEREAS, “Concordia Plan Servicesisa controlled entity of The Lutheran Church—Missouri Synod created to manage the Concordia Plans,” and “the Concordia Plans, while operating under the supervision of the Synod Board of Directors, are trust agencies whose assets are not the property of corporate Synod” (Bylaw 1.2.1[d–e]); and

WHEREAS, The Synod’s Bylaws establish an expectation of transparency to member congregations, stating: “The Synod and each of its agencies shall fully disclose their financial books and records to any member congregation of the Synod” (Bylaw 1.5.4); and

WHEREAS, Church plans are generally exempt from many Employee Retirement Income Security Act of 1974 (ERISA) reporting and disclosure requirements, and therefore participants may not automatically receive standardized, year-to-year comparable disclosures that are common in ERISA-governed plans; and

WHEREAS, Church workers, retirees, and congregations benefit from clear, consistent disclosures so they may understand promised benefits and plan changes, plan responsibly, and maintain confidence through transparent communication; and

WHEREAS, As Christ’s church, we should not aim to have less transparency than secular institutions when stewarding promised benefits for those who serve the Gospel, but rather seek standards that meet or exceed widely recognized best practices; therefore be it

Resolved, That Synod in convention thank God for the hard work and dedication of the board members and staff of Concordia Plan Services (CPS) for the proper management of the plans; and be it further

Resolved, That the Synod in convention establish a new bylaw requiring an annual Concordia Plans Transparency Report and participant disclosures using standards equal to or greater than ERISA-style transparency and make the necessary adjustments to enact it; and be it further

Resolved, That a new Bylaw 3.7.1.6 be created as follows: PRESENT/PROPOSED WORDING The Concordia Plans … 3.7.1.6 The Board of Trustees—Concordia Plans and the Board of Directors—Concordia Plan Services shall prepare and publish an annual Concordia Plans Transparency Report for plan participants and the Synod Board of Directors, written for non-specialists and including a one-page plain language participants summary. ERISA- comparable disclosures will be provided yearly to participants for full transparency, not from government obligation. Concordia Plans will provide to participants and make readily accessible the following disclosures, in ERISA-equivalent form, even when not required by federal law, in keeping with the Synod’s commitment to full financial disclosure (Bylaw 1.5.4): 1. Form 5500-equivalent annual financial/actuarial report (standardized content comparable in substance and year-to- year comparability to form 5500 and relevant schedules); 2. Summary Plan Description (SPD); 3. Summary Annual Report (SAR); 4. Summary of Material Modification (SMM) (timely notice of significant changes); 5. Summary of Benefits and Coverage (SBC) for health benefits; and 6. Individual Benefit Statement (periodic statement of accrued and vested benefits, as applicable). The report shall conform to the following requirements: (a) Standard: The level of disclosure provided shall be equal to or greater than ERISA-style disclosure principles in clarity, completeness, and year-to-year comparability. This does not assert that ERISA governs the Concordia Plans. (b) Publication and access: The report and disclosures shall be posted prominently on the Concordia Plan Services website, accessible through the Synod’s website, and participants shall be notified annually of availability. (c) Timeline: The first annual report hall be published within twelve months following the close of the 2026 Synod convention and annually thereafter.

and be it further

Resolved, That the costs associated with such reporting be absorbed within existing administrative functions of CPS; and be it finally

Resolved, That the 2026 Synod convention affirm the ongoing value and necessity of the Concordia Plans as synodwide trust entities serving church workers and retirees.