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Multiemployer MPPP Nondiscrimination Issue


luissaha

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I posted this topic under the "Correction of Plan Defects" section, but thought it might be more appropriate here. We have a multiemployer money purchase plan with a participating employer covering non-bargaining unit members, some of whom are HCEs. Apparently, it was believed by the administrator that all employees were covered by a cba, but it turns out this is not the case. The way this plan is designed, it does not look like it satisfies the safe harbor, so it is subject to the nondiscrimination rules. This is complicated, but it appears some of the HCEs were getting contributions of 15-20% of their salaries, while non-HCE were getting contributions in lower percentages. My questions are as follows: What type of discrimination testing needs to be done on a multiemployer money purchase pension plan? If the plan fails the testing, how can it be corrected? Also, one of the HCEs has retired and requested a distribution of his account balance. Can the plan delay the distribution until the nondescriminations problems are resolved? Any help would be appreciated.

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