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Non-Electing QCCO Needs Pre-approved 401(k) Document


Patricia Neal Jensen
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A Non-Electing QCCO (prospective client) needs a pre-approved 401(k) (not 403(b)) plan document.   So far I have not found one.   This is an existing plan using a 401(k) document and doing testing but not filing a 5500.  Their vendor holding the assets wants them on a document with an IRS Letter.   So 2 questions:

1. Anyone know of a Non-ERISA  (Non-Electing) Church or QCCO document for 401(k) with an IRS Letter?

2. Suggestions on what to do instead?  Have thought of freezing the 401(k) and starting a Non-Electing 403(b) for which I have a pre-approved document.  Cannot merge the 2 documents but the 401(k) does not file 5500's so might be the best we can do?

Thanks!

Patricia Neal Jensen

Vice President and Nonprofit Practice Leader

| QBI, an Ascensus company

21031 Ventura Blvd., 12th Floor

Woodland Hills, CA 91364

E patricia.jensen@QBILLC.com

P 818-449-6096

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Pension Pro....We do have approved PPA documents for 403(b) for churches and QCCO's.  Just not 401(k).

Flyboy john.... actually not a bad idea.  It will void the reliance to do that, however.  That was the best our document provider came up with as well.

Thanks for your thoughts and ideas!

Patricia Neal Jensen

Vice President and Nonprofit Practice Leader

| QBI, an Ascensus company

21031 Ventura Blvd., 12th Floor

Woodland Hills, CA 91364

E patricia.jensen@QBILLC.com

P 818-449-6096

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Be careful about what you send out to participants if you use a preapproved ERISA document (assuming you can find one that accommodates all of the plan's features); the participant communications generated may reference ERISA in ways that confuse participants and create unnecessary risk for the plan sponsor.

At the risk of stating the obvious, you could also obtain a determination letter on it, assuming that it has not been submitted for one before.

 

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