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Belgarath

403(b) non-ERISA matched with a SEP

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How often do you see this combination - a non-ERISA deferral only 403(b), so no 5500's, and a non-IRS "prototype" SEP for the employer contributions, so no 5500's? Just curious.

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By "matched with a SEP" in your title you mean paired with a SEP, not that matching contributions on 403(b) deferrals are made to the SEP, which would violate the uniform contribution requirement, right?

Haven't seen that before, interesting strategy to avoid government filings. 

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You have obviously done your homework as the key to making this work is your reference to “non-IRS Prototype”.  You can’t do it with a 5305-SEP Form.  

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Cuse - yes, "paired" with a SEP. It isn't a situation where the SEP contribution has anything whatsoever to do with 403(b) eligibility, deferrals, etc., etc. - it just exists completely independently.

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Belgrath.... last comment critical.  "Paired with" makes us nervous because a Non-ERISA plan cannot be actually "paired with" anything or it will be ERISA.  But "paired with" means something in the "other plan" references or requires an action in the Non-ERISA plan.

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Would this calm your nerves? The plans are maintained simultaneously. There is no language that "pairs" them.

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