Jump to content

compensation issue


Recommended Posts

Dealing with a cash balance/DC combo.  The Plan defines Comp period as the 12 month fiscal period ending within the plan year.

Example: 3/31 Fiscal Year End.  The 12 month comp period would be 4/1/2017 – 03/31/2018.

This plan has 4 entities (control group) participating. 2 w/ 3/31 fiscal years and 2 w/ 12/31 fiscal years.

The employer switched fiscal years after the completion of the 3/31 fiscal year to a calendar year.  I technically have two fiscal year ends (21 months of comp) within the 12 month plan year. 

4/1/17 – 03/31/18 and now 4/1/2018 – 12/31/18.  The plan year has not been changed and continues to be a 12 month calendar year.

We want to be able to include all 21 months of compensation for funding purposes during 2018 and then going forward 2019’s compensation will follow the 12 month plan year.  How do we include compensation from 4/1-17 – 12/31/18 for funding purposes for those 3/31 fiscal EE’s that had their fiscal year switched to 12/31?  

Can this be accomplished in the 2018 plan year?

Link to comment
Share on other sites

In order cover all pay periods, I think my 2018 plan year allocations would be based on comp from 4/1/17 – 3/31/18 (old FYE) plus comp from 4/1/18 – 12/31/18 (new FYE).  This is a 21 month period, but if I don’t include all pay and use only 12 months, wouldn’t that be a cutback in benefits?  How would I justify not providing allocations for the 4/1/17 – 12/31/17 period or alternatively not providing allocations for the 4/1/18 – 12/31/18 period?”

 

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
×
×
  • Create New...