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About dmb

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  1. Thanks for the responses. "In this case" is a case of an employee without control of either plan. But how would "control" be defined, especially for a non-profit where there is no ownership? Thanks again.
  2. If a non-profit employer sponsors both a 403b plan and a 401k plan, does the 415 limit apply to each plan separately? That is can a participant actually receive $106,000 between the two plans (2016)?? And taking it one step further, would the participant, if over 50 and the plan allows, be eligible for the catchup contribution in each plan or is the catch up part of 402g limit? Thanks.
  3. Calendar Year Plan. 2016 AFTAP of 79% has been certified Credit Balance of $30,000 not enough to wait to get to 80% At current time, can employer voluntarily waive the credit balance and make a IRC 436 contribution to remove partial benefit restrictions brought on by 79% AFTAP. Thanks for all responses.
  4. We are reviewing a plan for possible take over. There are no HCEs and only three of the about 40 NHCE participants are receiving an employer base allocation where each participant is their own allocation group. If there are no HCEs, is that kosher? Thanks.
  5. This for a for-profit, non-qualified/post-retirement medical plan. Any article or reference would be appreciated. Thanks.
  6. Has anyone dealt with Corporate Owned Life Insurance (COLI) inside a plan as a financing vehicle? And how is treated for accounting purposes? Any guidance, insight or thoughts are appreciated. Thank you.
  7. Thanks again. Agreed on the 436 issue, but there are no restrictions in play here. Thanks again, and yes, maybe that's why no more of the appropriately titled grey book.
  8. Thanks for the response, that was our thought as well. However, I refer to gray book question 2003-28 and ask if this changes your thinking: A participant in a contributory plan terminates and is eligible to withdraw contributions and interest of $3,000 immediately. The present value of the participant's total benefit (including contributions and interest is $7,000 (i.e., over $5,000). The plan does not have a large amount lump sum option. The participant withdraws the contributions and interest, with consent of the participant's spouse. The remaining present value is then $4,000. Can an involuntary cashout of $4,000 be made on the same day the participant withdraws the employee contributions or must the distributions occur in a two-step process in order to meet 1.411(a)-11©(3)? RESPONSE The distributions can occur on the same day. The consent of the spouse is not needed for the “subsequent” lump sum benefit payable that is under the $5,000 threshold.
  9. Does the $5,000 small lump sum cashout threshold apply only to the value of employer provided benefit? How does employee contribution money play into the $5,000 cashout threshold? Thank you.
  10. Employer made election in 2010 to use Market Value of Assets for PPA funding. Can employer now elect to use Average Value of Assets without any strings attached? Thanks.
  11. A DC plan has a dual vesting schedule (result of a merger). Would this trigger availability testing? Thanks.
  12. Would a 401k plan that provides the basic SH match to one group of participants and the enhanced SH match to another group still be considered a SH 401k plan? Thanks.
  13. Employer would like to amend the employer base allocation of profit sharing plan so the current year allocation is based on whether or not a participant worked 1000 hours in the prior year. The allocation is flat 4% of comp. The purpose is so contributions can be made on a pay period basis of the current year. No other requirements for allocation other than meeting initial plan eligibility which is 3 months of service. Would this amendment result in the allocation being considered non-uniform and therefore need general testing under 410(b) and 401(a)(4) or could it be treated as a provision like a last day requirement and therefore only be subject to basic 70% coverage testing under 410(b)? Thanks.
  14. I appreciate the responses, no offense taken. I am an actuary and sometimes I just want to make sure i'm not missing anything, especially regarding the accounting rules and also to try to get a feel for what others are doing. Thanks again.
  15. Thanks. I guess my next question then is whether or not there is a requirement to use other decrements or is it an assumption up to the actuary? And would including the death benefit be a reasonable assumption? Thanks.