Oklahoma 2024 Regular Session

Oklahoma House Bill HB2142 Compare Versions

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2828 STATE OF OKLAHOMA
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3030 1st Session of the 59th Legislature (2023)
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3232 HOUSE BILL 2142 By: McDugle
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3838 AS INTRODUCED
3939
4040 An Act relating to the Oklahoma Law Enforcement
4141 Retirement System; amending 47 O.S. 2021, Section 2 -
4242 300, which relates to definitions; modifying
4343 membership definition; providing f or certain election
4444 by common school district with respect to police
4545 officers performing service at school s offering
4646 instruction for specified g rade levels; providing
4747 procedures for police officers to become members of
4848 the Oklahoma Law Enforcement Retirement System;
4949 providing for transfer of service credit; providing
5050 for purchase at actuarial cost; providing for
5151 treatment of service not purchased; providing for
5252 election with respect to certain police officers
5353 based upon prior membership in the Teachers '
5454 Retirement System of Oklahoma; providing for
5555 codification; providing an effective date ; and
5656 declaring an emergency .
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6262 BE IT ENACTED BY THE PEOPLE OF THE STATE OF OKLAHOMA:
6363 SECTION 1. AMENDATORY 47 O.S. 2021, Section 2 -300, is
6464 amended to read as follows:
6565 Section 2-300. As used in Section 2 -300 et seq. of this title:
6666 1. "System" means the Oklahoma Law Enforcement Retirement
6767 System;
6868 2. "Act" means Section 2-300 et seq. of this title; RBH No. 6162
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9595 3. "Board" means the Oklahoma Law Enforcement Retirement Boar d
9696 of the System;
9797 4. "Executive Director" means the managing officer of the
9898 System employed by the Board;
9999 5. "Fund" means the Oklahoma Law Enforcement Retirement Fund;
100100 6. a. "Member" means:
101101 (1) all commissioned law enforcement officers of the
102102 Oklahoma Highway Patrol Division of the
103103 Department of Public Safety who have obtained
104104 certification from the Council on Law Enforcement
105105 Education and Training, and all cadets of a
106106 Patrol Academy of the Department of Public
107107 Safety,
108108 (2) law enforcement officers and crim inalists of the
109109 Oklahoma State Bureau of Investigation,
110110 (3) law enforcement officers of the Oklahoma State
111111 Bureau of Narcotics and Dangerous Drugs Control
112112 designated to perform duties in the investigation
113113 and prevention of crime and the enforcement of
114114 the criminal laws of this state,
115115 (4) law enforcement officers of the Oklahoma
116116 Alcoholic Beverage Laws Enforcement Commission
117117 designated to perform duties in the investigation RBH No. 6162
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144144 and prevention of crime and the enforcement of
145145 the criminal laws of this state,
146146 (5) employees of the Communications Section of the
147147 Oklahoma Highway Patrol Division, radio
148148 technicians and tower technicians of the
149149 Department of Public Safety, who are employed in
150150 any such capacity as of June 30, 2008, and who
151151 remain employed on or after July 1, 2008, until a
152152 termination of service, or until a termination of
153153 service with an election of a vested benefit from
154154 the System, or until re tirement. Effective July
155155 1, 2008, a person employed for the first time as
156156 an employee of the Department of Public S afety in
157157 the Communications Division as an information
158158 systems telecommunication technician of the
159159 Department of Public Safety shall not be a member
160160 of the System,
161161 (6) park rangers of the Oklahoma Tourism and
162162 Recreation Department and any park manager or
163163 park supervisor of the Oklahoma Tourism and
164164 Recreation Department, who was employed in such a
165165 position prior to July 1, 1985, and who elects on
166166 or before September 1, 1996, to participate in
167167 the System, and RBH No. 6162
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194194 (7) inspectors of the Board of Pharmacy ; and
195195 (8) law enforcement officers employed by a common
196196 school district performing services at a school
197197 offering instruction in the ninth grade or higher
198198 that makes an election to participate in the
199199 System pursuant to the provisions of Section 2 of
200200 this act.
201201 b. Effective effective July 1, 1987, a member does not
202202 include a "leased employee" as defined under Section
203203 414(n)(2) of the Internal Revenue Code of 1986, as
204204 amended. Effective July 1, 1999, any i ndividual who
205205 agrees with the participating employer that the
206206 individual's services are to be performed as a leased
207207 employee or an independent contractor shall not be a
208208 member regardless of any classification as a common-
209209 law employee by the Internal Revenu e Service or any
210210 other governmental agency, or any court of competent
211211 jurisdiction.
212212 c. All all persons who shall be offered a position of a
213213 commissioned law enforcement officer as an employee of
214214 one of the agencies des cribed in subparagraph a of
215215 this paragraph shall participate in the System upon
216216 the person meeting the requisite post -offer-pre- RBH No. 6162
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243243 employment physical examination standards which shall
244244 be subject to the following requirements:
245245 (1) all such persons shall be of good moral
246246 character, free from deformi ties, mental or
247247 physical conditions, or disease and alcohol or
248248 drug addiction which would prohibit the person
249249 from performing the duties of a law enforcement
250250 officer,
251251 (2) the physical-medical examination shall pertai n to
252252 age, sight, hearing, agility and ot her conditions
253253 the requirements of which shall be established by
254254 the Board,
255255 (3) the person shall be required to meet the
256256 conditions of this subsection prior to the
257257 beginning of actual employment but after an offer
258258 of employment has been tendered by a
259259 participating employer,
260260 (4) the Board shall have authority to deny or revoke
261261 membership of any person submitting false
262262 information in such person 's membership
263263 application, and
264264 (5) the Board shall have final authority in
265265 determining eligibility for membership in the RBH No. 6162
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292292 System, pursuant to the provisions of this
293293 subsection;
294294 7. "Normal retirement date" means the date at which the member
295295 is eligible to receive the unreduced payments of the member 's
296296 accrued retirement benefit. S uch date shall be the first day of the
297297 month coinciding with or following the date the member:
298298 a. completes twenty (20) years of vesting service, or
299299 b. attains sixty-two (62) years of age with ten (10)
300300 years of vesting service, or
301301 c. attains sixty-two (62) years of age, if:
302302 (1) the member has been transferred to this System
303303 from the Oklahoma Public Employees Retirement
304304 System on or after July 1, 1981, and
305305 (2) the member would have been vested had the member
306306 continued to be a member of the Oklahoma Public
307307 Employees Retirement System.
308308 With respect to distributions under the System made for calendar
309309 years beginning on or after January 1, 2005, the System shall apply
310310 the minimum distribution incidental benefit requirements, incidental
311311 benefit requirements, and m inimum distribution requirements of
312312 Section 401(a)(9) of the Internal Revenue Code of 1986, as amended,
313313 in accordance with the final regulations under Section 401(a)(9) of
314314 the Internal Revenue Code of 1986, as amended, including Treasury
315315 Regulations Sections 1.401(a)(9)-1 through 1.401(a)(9)-9; provided RBH No. 6162
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342342 that for individuals who attain seventy and one -half (70 1/2) years
343343 of age after December 31, 2019, distributions shall be made when the
344344 individual attains seventy -two (72) years of age, pursuant to the
345345 provisions of the SECURE Act of 2019, Pub. L. 116-94, Sections
346346 401(a)(9)(B)(iv)(I), 401(a)(9)(C)(i)(I) and 401(a)(9)(C)(ii) (I) of
347347 the Internal Revenue Code of 1986, as amended, notwithstanding any
348348 provision of the System to the contrary. With respect to
349349 distributions under the System made for calen dar years beginning on
350350 or after January 1, 2001, through December 31, 2004, the System
351351 shall apply the minimum distribution requirements and incidental
352352 benefit requirements of Section 401(a)(9) of the Internal Revenu e
353353 Code of 1986, as amended, in accordanc e with the regulations under
354354 Section 401(a)(9) of the Internal Revenue Code of 1986, as amended,
355355 which were proposed in January 2001, notwithstanding any provision
356356 of the System to the contrary.
357357 Effective July 1, 198 9, notwithstanding any other provision
358358 contained herein to the contrary, in no event shall commencement of
359359 distribution of the accrued retirement benefit of a member be
360360 delayed beyond April 1 of the calendar year following the later of:
361361 (1) the calendar year in which the member reaches seventy and one-
362362 half (70 1/2) years of age for a member who attains this age before
363363 January 1, 2020, or, for a member who attains this age after January
364364 1, 2020, the calendar year in which the member reaches seventy -two
365365 (72) years of age; or (2) the actual retirem ent date of the member. RBH No. 6162
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392392 A member electing to defer the commencement of retirem ent benefits
393393 pursuant to Section 2 -308.1 of this title may not defer the benefit
394394 commencement beyond the age of sixty -five (65).
395395 Effective September 8, 2009, notwithstanding anything to the
396396 contrary of the System, the System, which as a governmental plan
397397 (within the meaning of Section 414(d) of the Internal Revenue Code
398398 of 1986, as amended), is treated as having complied with Section
399399 401(a)(9) of the Internal Revenue Code of 1986 , as amended, for all
400400 years to which Section 401(a)(9) of the Internal Revenue Code of
401401 1986, as amended, applies to the System if the System complies with
402402 a reasonable and good faith interpretation of Section 401(a)( 9) of
403403 the Internal Revenue Code of 1986, as amended.
404404 A member who was required to join the System effective July 1,
405405 1980, because of the transfer of the employing agency from the
406406 Oklahoma Public Employees Retirement System to the System, and was
407407 not a member of the Oklahoma Public Employees Reti rement System on
408408 the date of such transfer shall be allowed to receive credit f or
409409 prior law enforcement service rendered to this state, if the member
410410 is not receiving or eligible to receive retirement credit or
411411 benefits for such service in any other public retirement system,
412412 upon payment to the System of the employee contribution the member
413413 would have been subject to had the member been a member of the
414414 System at the time, plus five percent (5%) interest. Service cred it
415415 received pursuant to this paragraph shall be used in determining the RBH No. 6162
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442442 member's retirement benefit, and shall be used in determining years
443443 of service for retirement or vesting purposes;
444444 8. "Actual paid base salary " means the salary received by a
445445 member, excluding payment for any accumulated le ave or uniform
446446 allowance. Salary shall include any amount of nonelective salar y
447447 reduction under Section 414(h) of the Internal Revenue Code of 1986;
448448 9. "Final average salary " means the average of the highest
449449 thirty (30) consecutive complete months of act ual paid gross salary.
450450 Gross salary shall include any amount of elective salar y reduction
451451 under Section 457 of the Internal Revenue Code of 1986, as amended,
452452 and any amount of nonelective salary reduction under Sect ion 414(h)
453453 of the Internal Revenue Code of 1986, as amended. Effective July 1,
454454 1992, gross salary shall include any am ount of elective salary
455455 reduction under Section 125 of the Internal Revenue Code of 1986, as
456456 amended. Effective July 1, 1998, gross sala ry shall include any
457457 amount of elective salary reduction not includable in the gross
458458 income of the member under Section 132(f)(4) of the Internal Revenue
459459 Code of 1986, as amended. Effective July 1, 1998, for purposes of
460460 determining a member 's compensation, any contribution by the member
461461 to reduce his or her regular cash remuneration under Section
462462 132(f)(4) of the Internal Revenue Code of 1986, as amended, shall be
463463 treated as if the member did not make such an election. Only salary
464464 on which required contri butions have been made may be used in RBH No. 6162
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491491 computing the final average salary. Gross salary shall not include
492492 severance pay.
493493 In addition to other applicable limitations, and notwithstanding
494494 any other provision to the contrary, for plan years beginning on or
495495 after July 1, 2002, the annual gross salar y of each "Noneligible
496496 Member" taken into account under the System shall not ex ceed the
497497 Economic Growth and Tax Relief Reconciliation Act of 2001 ( "EGTRRA")
498498 annual salary limit. The EGTRRA annual salary limit is Two Hundred
499499 Thousand Dollars ($200,000.00), as adjusted by the Commissioner for
500500 increases in the cost of living in accorda nce with Section
501501 401(a)(17)(B) of the Internal Revenue Code of 1986, as amended. The
502502 annual salary limit in effect for a calendar year a pplies to any
503503 period, not exceeding twel ve (12) months, over which salary is
504504 determined ("determination period ") beginning in such calendar year.
505505 If a determination period consists of fewer than twelve (12) months,
506506 the EGTRRA salary limit will be multipli ed by a fraction, the
507507 numerator of which is the number of months in the determination
508508 period, and the denominator of wh ich is twelve (12). For purposes
509509 of this section, a "Noneligible Member" is any member who first
510510 became a member during a plan year comm encing on or after July 1,
511511 1996.
512512 For plan years beginning on or after July 1, 2002, any reference
513513 in the System to the annual salary limit under Section 401(a)(17) of RBH No. 6162
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540540 the Internal Revenue Code of 1986, as amended, shall mean the EGTRRA
541541 salary limit set for th in this provision.
542542 Effective January 1, 2008, gross salary for a plan year shall
543543 also include gross salary, as descr ibed above, for services, but
544544 paid by the later of two and one -half (2 1/2) months after a
545545 member's severance from employment or the end of the calendar year
546546 that includes the date the member terminated employment, if it is a
547547 payment that, absent a severan ce from employment, would have been
548548 paid to the member while the member continued in employment with the
549549 employer.
550550 Effective January 1, 2 008, any payments not described above
551551 shall not be considered gross salary if paid after severance from
552552 employment, even if they are paid by the later of two and one -half
553553 (2 1/2) months after the date of severance from employment or the
554554 end of the calendar year that includes the date of severanc e from
555555 employment, except payments to an individual who does not currently
556556 perform services for the employer by reason of qualified military
557557 service within the meaning of Section 414(u)(5) of the Internal
558558 Revenue Code of 1986, as amended, to the extent the se payments do
559559 not exceed the amounts the individual would have received if the
560560 individual had continued to perform services for the employer rather
561561 than entering qualified military service.
562562 Effective January 1, 2008 , back pay, within the meaning of
563563 Section 1.415(c)-2(g)(8) of the Income Tax Regulations, shall be RBH No. 6162
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590590 treated as gross sal ary for the limitation year to which the back
591591 pay relates to the extent the back pay represents wages and
592592 compensation that would otherwi se be included in this definition.
593593 Effective for years beginning after December 31, 2008, gross
594594 salary shall also inclu de differential wage payments under Section
595595 414(u)(12) of the Internal Revenue Code of 1986, as amended;
596596 10. "Credited service" means the period of service used to
597597 determine the amount of benefits payable to a member. Credited
598598 service shall consist of th e period during which the member
599599 participated in the System or the predecessor Plan as an active
600600 employee in an eligible membership class ification, plus any service
601601 prior to the establishment of the predecessor Plan which was
602602 credited under the predecessor Plan and for law enforcement officers
603603 and criminalists of the Oklahoma State Bureau of Investigation and
604604 the Oklahoma State Bureau of Na rcotics and Dangerous Drugs Control
605605 who became members of the System on July 1, 1980, any service
606606 credited under the Ok lahoma Public Employees Retirement System as of
607607 June 30, 1980, and for members of the Communications and Lake Patrol
608608 Divisions of the Okl ahoma Department of Public Safety, who b ecame
609609 members of the System on July 1, 1981, any service credited under
610610 the predecessor Plan or the Oklahoma Public Employees Retirement
611611 System as of June 30, 1981, and for law enforcement officers of the
612612 Alcoholic Beverage Laws Enforcement Commission who became members of
613613 the System on July 1, 1982, any service credited under the Ok lahoma RBH No. 6162
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640640 Public Employees Retirement System as of June 30, 1982, and for park
641641 rangers of the Oklahoma Tourism and Recreation Department who became
642642 members of the System on July 1, 1985, any service credited under
643643 the Oklahoma Public Employees Retirement Syst em as of June 30, 1985,
644644 and for inspectors of the Oklahoma State Board of Pharmacy who
645645 became members of the System on July 1, 1986, any service credited
646646 under the Oklahoma Publ ic Employees Retirement System as of June 30,
647647 1986, for law enforcement officer s of the Oklahoma Capitol Patrol
648648 Division of the Department of Public Safety who became members of
649649 the System effective July 1, 1993, any service credited under the
650650 Oklahoma Public Employees Retirement System as of June 30, 1993, and
651651 for all commissioned o fficers in the Gunsmith/Ammunition Reloader
652652 Division of the Department of Public Safety who became members of
653653 the System effective July 1 , 1994, any service credited under the
654654 Oklahoma Public Employees Retirement System as of June 30, 1994, and
655655 for the park managers or park supervisors of the Oklahoma Tourism
656656 and Recreation Department who were employed in such a position prior
657657 to July 1, 1985, and who elect to become members of the System
658658 effective September 1, 1996, any service transferred pursuant to
659659 subsection C of Section 2 -309.6 of this title and any service
660660 purchased pursuant to subsection B of Section 2 -307.2 of this title.
661661 Effective August 5, 1993, an authorized leave of absence shall
662662 include a period of absence pursuant to the Family and Medical Le ave
663663 Act of 1993; RBH No. 6162
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690690 11. "Disability" means a physical or mental condition which, in
691691 the judgment of the Board, totally and presumably perma nently
692692 prevents the member from engaging in the usual and customary duties
693693 of the occupation of the member and thereaft er prevents the member
694694 from performing the duties of any occupation or service for which
695695 the member is qualified by reason of training, e ducation or
696696 experience. A person is not under a disability when capable of
697697 performing a service to the employer, regar dless of occupation,
698698 providing the salary of the employee is not diminished thereby;
699699 12. "Limitation year" means the year used in applyi ng the
700700 limitations of Section 415 of the Internal Revenue Code of 1986,
701701 which year shall be the calendar year;
702702 13. "Line of duty" means any action which a member whose
703703 primary function is crime control or reduction or enforcement of the
704704 criminal law is obligated or authorized by rule, regulatio ns,
705705 condition of employment or service, or law to perform including
706706 those social, ceremonial or athletic functions to which the member
707707 is assigned, or for which the member is compensated, by the agency
708708 the member serves;
709709 14. "Personal injury" or "injury" means any traumatic injury as
710710 well as diseases which are caused by or result fr om such an injury,
711711 but not occupational diseases;
712712 15. "Catastrophic nature" means consequences of an injury that
713713 permanently prevent an individual from performing any gainful w ork; RBH No. 6162
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740740 16. "Traumatic injury" means a wound or a condition of the body
741741 caused by external force including injuries inflicted by bullets,
742742 explosives, sharp instruments, blunt objects or other physical
743743 blows, chemicals, electricity, climatic conditions, infec tious
744744 diseases, radiation and bacteria, but excluding stress and strain;
745745 and
746746 17. "Beneficiary" means the individual designated by the member
747747 on a beneficiary designation form supplied by the Oklahoma Law
748748 Enforcement Retirement System, or, if there is no d esignated
749749 beneficiary or if the designated beneficiary predeceases the member,
750750 the estate of the member. If the member 's spouse is not designated
751751 as the sole primary beneficiary, the member 's spouse must sign a
752752 consent.
753753 SECTION 2. NEW LAW A new section of law t o be codified
754754 in the Oklahoma Statutes as Section 2-309.6a of Title 47, unless
755755 there is created a duplication in numbering, reads as follows:
756756 A. The governing board of any common school dis trict may make
757757 an irrevocable writte n election for the district to become a
758758 participating employer in the Oklahoma Law Enforcement Retirement
759759 System for police officers who are CLEET certified and employed by
760760 the school district at any school offering inst ruction in the ninth
761761 grade or higher. The school district shall send written notice of
762762 the election to the Oklahoma Law Enforcement Retirement System. RBH No. 6162
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788788
789789 B. Beginning the fol lowing month after the System receives the
790790 written notice, the school district and all active police officers
791791 who are CLEET certified and hired on or after the date of the
792792 election and who perform services as described in subsection A of
793793 this section shall participate in and make contr ibutions to the
794794 System as other participating employers and members of the System.
795795 C. Upon election by the school district board, pursuant to
796796 subsection A of this section, active CLEET certified police officers
797797 employed prior to the date of the election and who were
798798 participating in the Teachers' Retirement System of Oklahoma, may,
799799 within three (3) months of the date of the election, make an
800800 irrevocable written election to participate in the Oklahoma Law
801801 Enforcement Retirement System and file the written election with the
802802 Teachers' Retirement System of Oklahoma and the Oklahoma Law
803803 Enforcement Retirement System. Such police officers w ho make the
804804 election to transfer shall be transferred to the Oklahoma Law
805805 Enforcement Retirement System subject to the following:
806806 1. Upon the date of election of the police officer, t he police
807807 officer shall cease accruing benefits in the Teachers ' Retirement
808808 System of Oklahoma and shall commence accruing benefits in the
809809 Oklahoma Law Enforcement Retirement System;
810810 2. Prior to the beginning of the mont h following receipt of the
811811 police officers' election by Teachers ' Retirement System of
812812 Oklahoma, the Teache rs' Retirement System of Oklahoma shall transfer RBH No. 6162
813813
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839839 to the Oklahoma Law Enforcement Retirement System all employee
840840 contributions and employer contributi ons plus accrued interest. The
841841 Teachers' Retirement System of O klahoma shall also send to the
842842 Oklahoma Law Enforcement Retirement System the retirement records of
843843 the transferring police officer;
844844 3. To receive service credit accrued by such police office r
845845 prior to the election, or prior t o the date as of which the pe rson
846846 making the election ceases to be a mem ber of the Teachers'
847847 Retirement System of Oklahoma, whichever date occurs last, the
848848 member shall pay the difference between the amount transferred by
849849 the Teachers' Retirement System of Oklahoma to the Oklahoma Law
850850 Enforcement Retirement System in paragraph 2 of this subsection and
851851 the amount determined by the Board of Trustees pursuant to Section
852852 2-307.5 of Title 47 of the Oklahoma Statutes. The polic e officer
853853 shall elect to either pay any difference to receive fu ll credit for
854854 the years sought to be transf erred or receive prorated service
855855 credit for only the amount received from the Teachers ' Retirement
856856 System of Oklahoma pursuant to this subsection. Payments made by
857857 electing police officers pursuant to this parag raph shall be made
858858 pursuant to subsection B of Section 2-307.5 of Title 47 of the
859859 Oklahoma Statutes;
860860 4. Service credit accrued by a police officer while a member of
861861 the Teachers' Retirement System of Oklahoma shall be treated as
862862 credited service for such transferring police officer in the RBH No. 6162
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889889 Teachers' Retirement System of Oklahoma if the police officer is not
890890 receiving or eligible to receive service credit or benefits from
891891 said service in any oth er public retirement system and the member
892892 has not received serv ice credit for the same years of service
893893 pursuant to Sections 2-307.1, 2-307.3 and 2-307.4 of Title 47 of the
894894 Oklahoma Statutes. Provided further, that only transferred credited
895895 service related to police service with the school district shall be
896896 included in the determination of a police officer 's normal
897897 retirement date or vesting date; and
898898 5. All service credit with the Teachers ' Retirement System of
899899 Oklahoma which is ineligible for transfer to the Oklahoma Law
900900 Enforcement Retirement System shall be cance led.
901901 D. Upon election by the school district board, pursuant to
902902 subsection A of this section, active CLEET certified police officers
903903 employed prior to the date of the elec tion and who were not
904904 participating in the Teachers ' Retirement System of Oklahoma, may,
905905 within three (3) months of the date of the election, make an
906906 irrevocable written election to participate in the Oklahoma Law
907907 Enforcement Retirement System and file the written election with the
908908 Oklahoma Law Enforcement Ret irement System. Beginning th e following
909909 month after the System for such police officer s receives the police
910910 officer's written election, the school district and the electing
911911 police officer shall participate and make contributions to the
912912 System as other participating employers and memb ers of the System. RBH No. 6162
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939939 SECTION 3. This act shall become effective July 1, 2023.
940940 SECTION 4. It being immediately necessary for the preservation
941941 of the public peace, health or safety, an emergency is hereby
942942 declared to exist, by reason whereof this act shall take effect and
943943 be in full force from and after its passage and approval.
944944
945945 59-1-6162 MAH 01/12/23
946946
947947 THOMAS E. CUMMINS CONSULTING ACTUARY, INC.
948948 2512 E. 71
949949 st
950950 Street , Suite D ∙ Tulsa, Oklahoma 741 36
951951 (918) 492-9658 ∙ (918) 492- 9659
952952
953953
954954
955955
956956
957957 January 16, 2023
958958
959959
960960
961961 Representative Kevin McDugle
962962 Room 242
963963
964964
965965
966966 Re: RHB No. 6162
967967
968968
969969 RBH No. 6162 would allow the law enforcement officers who are
970970 employed by a common school district at an institution in grade 9 or
971971 greater to become participants in Oklahoma Law Enforcement
972972 Retirement System. The school district must elect to become a
973973 Participating Employer for the officers may become participants.
974974
975975
976976 RBH No. 6162 is a fiscal bill as defined by OPLAAA since it adds
977977 additional eligible participants to OLERS.
978978
979979 I am a member of the American Academy of Actuaries and meet the
980980 Qualification Standards of the American Academy of Actuaries to
981981 render the actuarial opinion herein.
982982
983983
984984 Thomas E. Cummins
985985
986986 Thomas E. Cummins, MAAA
987987
988988