Fred Payne Posted December 29, 2001 Share Posted December 29, 2001 The Relius recordkeeping software included a participant's full-year comp in the calculation of the Average Benefits Test even though the participant didn't enter the Plan until 7/1. Relius' calculation of this participant's EBAR differs from mine since I had only used comp while a participant (as the Plan docs stipulate) for calculating both the dollar allocation and the EBAR. Did I err in my calculation of the allocation and EBAR, or do I possibly have a setting incorrect in Relius? Link to comment Share on other sites More sharing options...
Tom Poje Posted December 31, 2001 Share Posted December 31, 2001 The regs require you to use on of the definitions that satisfy 414(s) - and the typical document will define 414(s) comp as being from date of participation, so that is what you have to use. If you are processing the plan only once a year on Relius, then the system has to be 'told' what comp to use. there are a couple of ways to do this, otherwise the system will use whatever comp (e.g. ytd comp) that you plug in census. Link to comment Share on other sites More sharing options...
Mike Preston Posted January 2, 2002 Share Posted January 2, 2002 Just a small clarification. The document definition of compensation (whether it is a 414(s) definition of compensation or not) is not the only compensation that can be used when doing non-discrimination testing. Unless the document specifies all of the non-discrimination methodology (like we used to do back when the IRS was insisting on such language, but we no longer typically do because they aren't), one can test for non-discrimination against any definition of compensation that satisfies 414(s). I don't use the system in question, but I would be shocked if there wasn't a mechanism for pointing the non-discrimination testing at a definition of compensation that is independent of the other definitions of compensation under the plan. Link to comment Share on other sites More sharing options...
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