Can I amend a church's money purchase plan to accomodate a match formula rather than a fixed percentage to all eligible employees? Can the term "eligible employee" be defined as one who makes salary deferrals into the church's 403(b) plan in addition to the usual age and service requirements?

In most cases money purchase plans are not permitted to include salary deferrals. With no deferrals, there is nothing to match.

We have a client with a money purchase plan where the only contribution is a match on deferrals into their 403(b). Before anyone comments on the plan design, the plans were already in place before they became our client.

We had Corbel's service bureau modify their MP volume submitter document to add the match and ACP language we needed and submitted for a letter. We received a favorable determination letter on the plan.


Why don't you want to have the match inside the 403(b)? That would be my choice.

Kevin: Thank you for your reply. I'm very glad to know there is another plan out there like this one, and it received a determination letter besides. I agree with you about the matching contribution going into the 403(b), but in this case, we need to stay with the MP.