Nancy D

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About Nancy D

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  1. Hi, I can prepare accurate 5500s back to 2009, but would be creative with earnings prior to 2008. If I read your answer correctly, that shouldn't be a problem? Thank you so much for your help.
  2. I like the way you think! Contributions were made into participant accounts in name of 403(b) plan. Not sure how vendor set up accounts without a document. A Participant is terminating and wants to roll to IRA. Employees have been told there was a 403(b) plan in place.
  3. Hi, I have a 403(b) plan that started making employer contributions in 2001. Never had a plan document, never filed 5500s. One participant for fifteen years, then two participants for a couple of years. I can deal with document issue. My question is, do I have to start filing 5500s back to 2001? I believe the answer is yes. Neither vendor nor participant can provide statements for the account prior to 2008. Would you file knowing what you know, i.e. the amount of contributions, pro rate earnings? I'll be filing under the DFVC program. Any help/ suggestions would be greatly appreciated. Thanks,
  4. Thanks buckaroo...
  5. Thanks duckthing. That's what every fiber of my being was saying too. I appreciate your taking the time to answer.
  6. Thanks Buckaroo, I guess it's hard for me to believe that under 414 (s) an alternate definition of compensation that would allow compensation excluded over a dollar limit passes muster. I am thinking it is too easy a solution to my problem.
  7. Hi, I have a plan that looks like it will fail 414(s), it excludes bonuses and one NHCE gets a bonus of about 43% of her compensation. ( comp is $20,000 and bonus is $15,000). HCEs are all owners and earn about $20,000. I am thinking that if I have a definition of compensation that excludes compensation in excess of $20,000 that will solve my problem. I read in 1.414(s)1(d)(2)(iii) that ... " a definition of Compensation is not unreasonable merely because it excludes all compensation in excess of a specified dollar amount" Am I missing something? Thanks for any guidance you can offer....
  8. Thanks for your responses, sorry for delay have been out of office. Mbozek, you are right that's what we have found is that the insurance companies do not let us assess a fee. The plan does allow for distribution of de minimus amounts, but we are finding insurance companies will not honor that provision as it is not part of the individual contracts. We have tried telling the participants they must take a distribution, but when they contact the insurance companies they are told they don't have to. Flyboyjohn, thanks to you too. My kneejerk was no you can't do that, but then I thought if it is outside of the plan??? Spin off is a good idea, I'll pursue that option. I really do appreciate your help. NancyD
  9. Hi group, I'm a TPA of a 403(b) plan with multiple vendors and many terminated participants with account balances. Some of the participants are in individual contracts and it is a challenge to work with the vendors to pay those terminated participants with balances under $5K. Sponsor is wondering if they offer some type of incentive to terminated participants who take a distribution ( $100 gift card or the like). Wondering what your thoughts are?? Thank you for any help/guidance you can give...
  10. Thank you FlyboyJohn, That is what it looked like to me, but it seemed too easy! Thanks for your help!
  11. Hi, I am working on late 5500s for a client ( 100 plus covered) with a self insured health plan and insured LTD plan. My question has to do with what schedules are required for the health plan. We received Schedule A information from the claims Administrator for the Health Plan, but since there is no insurance carrier, I am thinking no Schedule A is necessary. The broker received commissions in excess of $5K do those get reported on Schedule C? In my reading of the instructions many times, it looks as if no schedule H or G is required. I appreciate any help as I keep rereading the instructions and end up more and more confused.... Thanks,
  12. Hi all, We are a TPA getting into COBRA administration. Does anyone have any information on software programs to help with administration? Any tips or feedback, pro and con on software would be greatly appreciated. Thanks for any help!
  13. Thank you Flyboyjohn. That is what I was thinking but couldn't find anything definitive. I really appreciate your help.
  14. Hi all, I am wondering if "Key Person" Insurance policies are generally subject to ERISA? This is not part of a group policy, only life insurance company offers is 100% paid by company for the owners of the company? Thanks for any guidance you can give.