Jump to content

Taking ASPA C-2(DC), need help....


stevena
 Share

Recommended Posts

Lisa, back to your original question, the answer is yes. But, in your extreme example you have a full ADP failure so you need to follow the document in terms of what the ramifications of that are. If the full deferral must be refunded, do you have a deferral that has a match to test? You need to look to the document for corrective action.

Link to comment
Share on other sites

stevena,

you said

"what if they do not meet the last day test AND they have more than 500 hours?? Then they are not excluded from coverage, and my understanding is they MUST be on the ACP test"

teach me to go on vacation for a week, I don't see anyone quoting the regs to support the discussion one way or another.!

look at 1.401(m)-1(f)(4) [this section is for ACP testing, etc and not coverage. lets not confuse the two!]

...By contrast, if an employee must perform addition service...in order...to receive an allocation of matching contributions for the plan year, the employee is not an eligible employee for the plan year unless the service is actually performed....

Thus, if a plan has a last day requirement, an an employee quits, he has not met the plan's service requirement and is therefore 'not eligible'

1.401(m)-1(b)(1)(A) The ACP for the group of eligible HCE....of all other eligible employees...

Therefore, if you are not eligible, you are not included in the ACP test. It is not an option. You are simply not included in the ACP test.

Coverage is of course a different test, and an ee who terms with more than 500 hours is includable and not benefiting.

.....................

Now, I believe the example was 1 HCE and 1 NHCE. the NHCE quit so did not receive a match. NHCE also did not defer.

For 401(m)coverage, the NHCE is includable and not benefiting, unless they termed with less than 500 hours. How can they be considered benefiting when they didn't receive anything? see 1.410(b)(3)(a)(2)

"An employee is treated as benefiting if and only if an employee is an eligible employee as defined in 1.401(m)-1(f)(4)"

This is, by the way, the whole concept behind a Standardized document. all active employees and all terminees with greater than 500 hours receive a contribution, thus you can't fail testing.

Link to comment
Share on other sites

I appreciate mkimball response and wanted to respond also in general. As a member of the E&E committee, my role is specifically to assist the committees in their review of exams and study guide materials. His comment that feedback from candidates is invaluable is right on the mark. We do make mistakes and we do need people to point them out so we can avoid those types of mistakes in the future.

Also, while not an excuse, remember these books have publishing deadlines, and especially in the case of new legislation, the things we know in June 2003 may not have been as crystal clear in September 2002 when the exam materials are sent to be published. The study guide is not the only resource you are using to learn this information and pass these exams. There is required reading that should help you to understand something that was "summarized" in the study guide.

As a reminder to candidates, you are encouraged to email your comments to educaspa@aspa.org We try to address each concern and believe me, the committees do review your comments/suggestions.

As a reminder to those of you that have earned your designations, I urge you to volunteer your resources to the ASPA E&E committee if you care about making these exams better. From what I've seen on the board you have some very strong opinions about the quality of these exams. It doesn't necessarily need to be a big time commitment. We are always looking for volunteers to review a study guide chapter or group of questions. And you can get CE credit as well. See the ASPA website for volunteer information.

Specifically to the candidate asking these questions on the board, I hope you did well on your exam today, and I'd be happy to address your concerns further (email me at kocak@msn.com) if they were not addressed satisfactorily by the other participants in this thread.

Michele Kocak

Link to comment
Share on other sites

Michele,

what would really be helpful (if possible) on the exam is to be able to check question(s) that one has a possible problem - either in the wording used or terminolgy or whatever. In the old days when you received a copy of the test in the mail you could go over it and then contact ASPA. Currently, that is not possible.

At least if you can mark a question you have possible problems with ASPA can review them. I have done enough reviewing with people in the office over old (old) exams, or some questions from the ASPA review sessions to know it would be a nice feature - especially since the exam questions are recycled now.

Link to comment
Share on other sites

Well, Michele, based on how you described the opportunities, now I will volunteer. I actually tried to before but I had problems with the volunteer form on the website. Not a good excuse, just a good one that day. Thanks for your comments as well as the others. Good discussion.

Link to comment
Share on other sites

Well everyone, I did pass! I am so excited.

The test was really hard, but I have to say, I didnt have any problems with wording of questions at all on the test...

i almost didnt finish the test because i was reading each question so carefully.,

but anyway, i am psyched so thanks everyone for your help!!!! (even though, truthfully, i still dont get the answer to the question.....)

Link to comment
Share on other sites

**sigh**

I just cannot let this go, for some reason...because I really want to understand it!! Sorry for those who are tiring of my confusion...

am i understanding correct, tom...

that an employee can actually be includable on the coverage test but excluded from the ACP test?

You said "the employee would be includable and not benefitting" from coverage...

but then you said "the employee is not included on the ACP test"

????

Link to comment
Share on other sites

yes! a person can be 'on' the coverage (included and not benefiting) and therefore not on the ACP test.

strange isn't it.

for coverage 401(m) a person is considering benefiting even if they are at 0.

that helps your coverage test, but the zero hurts your ACP test.

Think of it this. pretend the person deferred. (In reality, they did, but at 0)

But if the person had actually deferred something, would they have gotten a match?

if your answer is yes, then for 401(m) coverage ee is includable benefiting

if your answer is no, then includable not benefiting.

the only exception would be if the ee terminated with less than 500 hours.

for acp test you only include those who could have gotten a match. Again, a deferral of 0 = a match of zero, the person actually got something.

The big exception would be if the plan allowed post tax contributions. since anyone could make one, it doesn't matter whether you get a match or not, whether you quit or not. everyone is includable and benefiting, everyone is on the ACP test.

Link to comment
Share on other sites

Wow I have to say, I am blown away by that.

I have been doing that wrong all these years. I have always counted the employee who does not get a match due to a last day requirement who works over 500 hours as not benefitting, which i think is ok.

But, I also have always put that person in my ACP test and counted that person as a "0"

thanks so much for helping me understand that.

Lisa

Link to comment
Share on other sites

Lisa,

It is not the gators (or the Gators if you are talking sports) that are bad. It is the heat and humidity!

This thread shows the importance of:

1. ASPA, and studying for the exams because it raised some questions

2. this website, because it gives a chance to share knowledge.

I think I can speak for most when I say that we all do things differently than when we first started, and sometimes 'unlearning' something is very hard!

I have been assigned the task of giving a talk at the fall ASPA

401(k) Testing Hierarchy for Beginners.

This discussion has certainly given me some ideas to include. Thanks!

Link to comment
Share on other sites

I plan on taking the C-2 DC test this fall. It has been very interesting to read this link about the C-2 exam.

I want to obtain past actual C-2 tests so that I can practice those questions. Where can I get old C-2 test questions?

This test has got me worried now so I want to be prepared as much as possible by solving some old tests.

Thanks. :unsure:

Link to comment
Share on other sites

In response to Tom, I see where it may be helpful for a candidate to be able to comment on a question while taking the exam. I'll bring it up to the committee and get their feedback. It seems to me that it should be feasible to have some sort of coding at Prometric, an alert, if you like, that specifically prompts the committee relook at a question. Part of the current process already includes collecting statistics on each exam question and additional reviews and rewrites if the statistics look "off".

In response to ERISAgeek - Unfortunately we no longer release exam questions to candidates. I think any old exams that may be floating around out there probably are pre-EGTRRA and would really be more of a hindrance than a help. If you do the reading, review the study guide, practice the questions at the end of each chapter, and then take the sample exam provided with the guide, you will be fine. I think ASPA still offers weekend review courses, if that appeals to you.

For those of you who are new to the process, we have truly come a long way with the Prometric. The QPA exams used to be pencil and paper, offered on one day only, and it took FOREVER to get results. One of the compromises to having a truly random exam that is offered in a windowed period with immediate pass/fail feedback is the inability to release these exams for future candidates.

Finally, to the candidate, congratulations on your pass mark. If you still don't believe us about the ACP test see the ERISA Outline Book, Chapter 11, Section VII, Part B for a discussion with several helpful examples outlining who is eligible to be included in the ACP test.

Michele

Link to comment
Share on other sites

Stevena, I found your posting of 6/17 at 6:11PM and your comments re Actuaries on the mark and at the least entertaining. I was however a little disappointed to see your follow up post at 6:49PM when you apparently suffered "commentators remorse" your first remarks are exactly why increasing numbers of us "lower life forms" no longer submit questions or answers. There is no need for you to feel bad. I do admit that I read the site almost everyday and appreciate the time everyone takes to be an active part.

Link to comment
Share on other sites

Please don't perpetuate stereotypes of actuaries. Remember the 1/9/03 News Release from the Society of Actuaries where it stated that the "Portrayal of Actuaries as Math-Obsessed, Socially Disconnected Individuals with Shockingly Bad Comb-Overs [is] 97.28892% Incorrect"

...but then again, What Do I Know?

Link to comment
Share on other sites

WDIK,

You mean that it really is partially correct???

Way back in 1967 I was 1 of 2 finalists for the position of "Trainee" Actuary for a large Insurance Company (also did pensions) but lost out because of a too active social life although I had everything else including the obsessions. Those were their actual words.

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

Link to comment
Share on other sites

A lot of people were very happy then and even more now.

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
 Share

×
×
  • Create New...