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About BillAsay

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    Pittsburgh, PA
  1. A couple of years ago I was attending the annual conference of the IFEBP. I attended a public employer session and the speaker was from the federal government. At that time we were told that they were currently reviewing a question regarding DROP's and "pick-up" arrangements. Plans that included a DROP provision and an IRC 414(h)(2) "pick-up" arrangement, whereby when a DROP provision mandated that those electing to participate in the DROP would no longer contribute to the plan, may be running afoul of the 'pick-up" and/or CODA rules. Since those electing to participate in the DROP would no longer contribute to the pension plan, the question was being reviewed because participating in the DROP was considered optional and may not comply with the "mandatory" requirement of a "pick-up" arrangement. Since then, I have not seen an answer to this question. Does anybody know the outcome of this review?
  2. Pennsylvania, which has about 3,000 of the 9,000 public pension plans in the US, enacted a statute outlining the funding requirements for all municipalities with DB or DC plans. (Act 205 of 1985)
  3. We use ProVal. They have an OPEB key that works very well.
  4. I attended a benefits seminar yesterday and one of the sessions that I attended dealt with section 125 plans. The facilitator said that if a person owns 2% or more in a Sub-S corp they were prohibited from participating in the plan. As a recent owner of more that 2% of our corporation and a current participant in our plan, I was caught off guard. I wasn't able to get to the facilitator and question her before she left. Was the facilitator correct or did I misunderstand her. If she was correct, what can be done at this stage?
  5. With the recent passage of the PPA 2006 and the sweeping changes to corporate plans, has anybody seen an analysis outlining the changes to government pension plans? I have seen a review by NCPERS, but it only outlined 6 areas. Could the changes to government plans be that limited?
  6. The American Law Institute - American Bar Association has an annual conference for public plans in Washington DC. The International Foundation of Employee Benefit Plans has an annual educational conference specifically for public plan plans and within their main annual conference they have a lot of public plan sessions. This year it will be held in Las Vegas in October. The IFEBP also publishes a quarterly newsletter for public plans as does the Government Finance Officers Association. Bill
  7. If the money purchase plan is a 401(k) I believe that you would be able to add the Roth component. However, a vast majority of the money purchase plans in Pa were not grandfathered and there are very few (k)'s in effect. If the tax deductability for the voluntary contribution is important, why wouldn't they just use a 457 plan?
  8. I believe that they could have a profit sharing plan. Most of the new governmental DC plans in Pennsylvania have been Money Purchase plans. However, an IRC 414(h)(2) "pick-up" is for mandatory contributions only. It recharacterizes employee contributions as employer. Also, if this plan qualifies for state aid under Act 205 of 1984, anything other than a flat percentage or flat dollar amount could cause unexpected funding problems.
  9. Our company works in Pennsylvania and we deal exclusively with qualified governmental pension plans. Pennsylvania has about 2900 qualified DB and DC plans. For many of our clients, we have written plan documents that includes only the applicable code sections. (This includes the limited applicability of the GUST amendments.) We first started doing this about 12 years ago. We believe that it is important for a governmental plan not to adopt an ERISA prototype.