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pre-funding and 415


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5 hours ago, Luke Bailey said:

I have not read all the above, but I think I am siding with Mojo. You could draft a plan that was basically one with individual investments to say that the employer may also contribute amounts to be held temporarily in a suspense account that shall be invested for the benefit of all participants and that will be allocated to participants with the gain, but not counting the gain for 415(c), but if you are using compensation or other participant facts that are not in existence at the time of the contribution, so that the amount could not be allocated when it is contributed even if you wanted to take the time to do it, it seems like it violates definitely determinable. 

Something is definitely rotten in Denmark, here. I repeat my request for a citation saying that anything contibuted before an allocation date (typically the last day of the plan year) yields a violation of any kind, whether balance forward or individually directed.  Heck, I'll even lower the bar from citation to plan document provision. This has all the makings of a good Twilight Zone episode, though.

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14 hours ago, Mike Preston said:

But on the off chance that there is no such thing as a balance forward plan that is qualified, I suppose this is about the right time to ask for a citation. Betcha one can't be found.

I'm sorry Mike, but that is just a ridiculous response.  First, look above - and I talk about the balance forward account we handle.  Second a balance forward account is ALLOCATED.  When the money goes in, it is ALLOCATED to the participants.  PERIOD.  You may not update the earnings, but the money is ALLOCATED.  What part of that is not understood?

That is vastly different from a plan sponsor who "parks" money in a unallocated suspense account PENDING ALLOCATION.

What we are seeing RIGHT NOW is some plan sponsors are getting PPP money, that must be "spent" within 8 weeks, parking the money into a plan and NOT ALLOCATING IT, until some subsequent allocation condition is met (1000 hours, end of year, etc.)  THAT IS NOT PERMISSABLE as there is no certainty those allocations conditions will ever be met - and the money is truly UNALLOCATED.

God help you if you allow a client to do that, and the IRS comes a callin'.

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12 hours ago, Larry Starr said:

You are getting hung up on semantics.  Money put into a trustee directed plan early in the year is not yet allocated since allocations are only done on the last day of the plan year.  If it is not allocated (yet), then it's unallocated. That is NOT a suspense account or a forfeiture account; it's just part of the natural order of things for a trustee directed pooled account. I would suggest this is not a situation where we can agree to disagree; your statement above is simply wrong, whether you recognize the difference or not, and no matter how many plans "you have".  FWIW.

This isn't semantics.  It is a clear definitely determinable issue.  I don't know how you handle trustee directed plans, but we ALLOCATE the money when it goes in - based on the formula of the plan (usually comp to comp) - and then VALUE the plan later to account for earnings.  But - the money is NOT subject to subsequent allocation conditions.  That would be a problem.  We use the term "allocate" to account for earnings - but the principle has been allocated.

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12 hours ago, Larry Starr said:

MoJo, safe to say you misunderstand our discussion.  A pooled plan is where the participants have no control over the investments; trustees make the decisions for all the money and all participants have the same rate of return. The whole plan is pooled, not just one pooled account in a participant directed account.  And of course, you CANNOT "definitely determine" the benefits of each and every participant from the moment it is contributed to the plan, because the allocation to participant accounts takes place at year end.  And, the allocation almost always includes funds not yet contributed, because a pooled, trustee directed plan is almost always reported on an accrued basis, so contributions that are made after the plan year FOR the plan year are shown in the year end balances (even though the money might not even be in the plan yet).  The plan as an "accrued contribution" on the books.  Hope that helps.

No I understand completely.  A pooled plan is one where the participants do not control investments.  But in a pooled plan - the money is ALLOCATED.  You may or may not value the plan daily - which means you may not have a number of what earnings are allocatable to each participant's account until you do that valuation - but it can be done at any point in time with no other conditions or information.  The lack of a current valuation does NOT mean the money is not allocated.  It is.  What the OP was asking about is "prefunding" into an UNALLOCATED account that cannot - I repeat CANNOT be attributable to participant accounts until the happening of a subsequent event (1000 hours, end of year, etc., or even the discretion of the plan sponsor (the WORST of all possible situations).  That is the difference - and when others have said "prefundung" is "just like" a pooled account plan, I DISAGREE.  They are vastly different in terms of whether it is allocated or unallocated.  That is my point - and that is what you misunderstand.

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Im with MoJo on this one.  

You have a pooled plan, you deposit $100k on January 1, 2020.  It is a contribution for 2020, it is allocated for 2020, it is invested according to trustee direction when it hits the account.  Just because we don't have a valuation (per the plans formula) that says $3K to Joe, $20k to Sally, etc, doesn't mean that we dont have $100k allocated for 2020.  

That is very different from a participant directed plan with "holding account" where they park contributions until they figure out who gets what.  Unless the plan document is drafted very specifically, you have a problem either way you twist and turn it.  If it is allocated when it hits the holding account, then you have failed to properly invest the contribution for each participant once the valuation tells you that Joe gets $3k and Sally gets $20k.  If it is unallocated, then you have the problem of an unallocated account.  

If you want to make deposits as you go to make sure you don't spend it, open a separate corporate account to hold cash until you are ready to make a contribution.  You don't get the benefit of shielding the cash from creditors by putting it in an unallocated plan account.

We have one PITA plan that insists on funding during the year, and we make them contribute directly to the participant accounts, knowing that once the contribution hits the account it is allocated and cannot come back out.  It requires ongoing calculations throughout the year, and the all but guarantees that a maximum contribution will be made.

 

 

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There was a fair amount of discussion about pre-funding to use up PPP money and one solution was to open a separate plan checking account to hold it.  Are those of you saying you can't have a plan holding account saying you can't open a separate checking account?

Also waiting for an explanation of how you contribute $100K and presumably deduct $100K but allocate, for 415, $105K.  

Ed Snyder

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22 minutes ago, Bird said:

Also waiting for an explanation of how you contribute $100K and presumably deduct $100K but allocate, for 415, $105K. 

$100k contribution, $100k deduction, $5K gains/earning.  Otherwise, it would have to be held in suspense, and think we have agreed that is improper right?

 

 

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5 hours ago, MoJo said:

This isn't semantics.  It is a clear definitely determinable issue.  I don't know how you handle trustee directed plans, but we ALLOCATE the money when it goes in - based on the formula of the plan (usually comp to comp) - and then VALUE the plan later to account for earnings.  But - the money is NOT subject to subsequent allocation conditions.  That would be a problem.  We use the term "allocate" to account for earnings - but the principle has been allocated.

I'm still waiting for any reference that comes close to agreeing with you.  I suppose we could agree to disagree but this is such a fundamental misunderstanding I just can't.

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So maybe the following are good test hypotheticals to get even closer to issue?

First case: Pure discretionary profit sharing plan, pooled account, comp to comp allocation with immediate (first day of next month) eligibility and last day of year requirement. Fairly large employer with lots of turnover puts $100k into trust on 1/1/2020. By end of year, obviously the folks who share in allocation of $105,000 ($100k contributed + $5k earnings) are a very different group from the folks there on day that amount contributed. But that's OK?

Second case: 401(k) plan with individually directed accounts to which employer may make discretionary nonelective. Discretionary nonelective has last day of year requirement. No specific language addressing nonelective contributions that are contributed early in year and not allocated until after end of year, but not clear that this violates plan document. The unallocated discretionary contribution that is contributed early in the year, but not allocated until after end of year, is invested by trustee in money market, so there are some earnings, and the earnings get allocated along with the contribution after end of year. Is this the same as above?

There is definitely something bothersome about the above examples, assuming the earnings are counted as earnings and not annual additions. Money is contributed to the trust, and yet many folks who are plan participants at the time of the contribution will not share in the allocation of those funds, because at the time of allocation they will not fulfill a condition of allocation. Furthermore, think about an employer who actually wants to contribute $105k, but figures he might as well earn $5k of that on a sheltered basis, rather than through taxable business. And what if, while the amount is unallocated, the employer lays off 40% of its workforce and calls a partial termination so that the affected group's vesting is accelerated. Do they not vest in the unallocated $100k, or $102k or whatever it is at the time of the partial termination? Troubling.

However, the 415(c) regs, which follow the statute, seem to support the theory that in both cases the total annual additions are just the $100k, and do not include the $5k of earnings. "Annual addition" is defined not as the amount allocated to the account at the time it is actually allocated (which I think is maybe Mojo's position, that I was originally sympathetic to for the definitely determinable reason), but rather the employer contributions that are allocated to account, and it is hard to call the $5k of earnings "employer contributions." See Treas. reg. 1.415(c)-1(b). I guess if the IRS really didn't like the $5k in the example being treated as earnings, and not an annual addition, e.g. because of the definitely determinable issue, it could invoke its authority under 1.415(c)-1(b)(4) to call the employer's parking the $100k in the plan to "juice" it with tax-sheltered earnings a "transaction with the plan," but I am unaware (have not looked either) for any guidance doing that.

I think this is a tough one.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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55 minutes ago, Mike Preston said:

I'm still waiting for any reference that comes close to agreeing with you.  I suppose we could agree to disagree but this is such a fundamental misunderstanding I just can't.

Our normal operating standards (and the standards of every other recordkeeper I've worked for) and 40 years as an ERISA attorney.  What are you looking for for in terms of a "reference?"  What do you need me to point to a "reference" about?

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4 hours ago, RatherBeGolfing said:

$100k contribution, $100k deduction, $5K gains/earning.

Well we agree on that.

4 hours ago, RatherBeGolfing said:

Otherwise, it would have to be held in suspense, and think we have agreed that is improper right?

I don't understand the "otherwise" part.  I'm not sure what to call where it was held but the original posting was about a $100K contribution that was put in a plan but not immediately put in participant self-directed accounts, and earned $5000.  I objected to the position that $105K was allocated for 415 purposes.  Then things went off the rails.

I get that there is an argument that you can't do it, but if you do it, it is effectively just a pooled account.  

 

Ed Snyder

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22 minutes ago, Luke Bailey said:

First case: Pure discretionary profit sharing plan, pooled account, comp to comp allocation with immediate (first day of next month) eligibility and last day of year requirement. Fairly large employer with lots of turnover puts $100k into trust on 1/1/2020. By end of year, obviously the folks who share in allocation of $105,000 ($100k contributed + $5k earnings) are a very different group from the folks there on day that amount contributed. But that's OK?

ok

22 minutes ago, Luke Bailey said:

Second case: 401(k) plan with individually directed accounts to which employer may make discretionary nonelective. Discretionary nonelective has last day of year requirement. No specific language addressing nonelective contributions that are contributed early in year and not allocated until after end of year, but not clear that this violates plan document. The unallocated discretionary contribution that is contributed early in the year, but not allocated until after end of year, is invested by trustee in money market, so there are some earnings, and the earnings get allocated along with the contribution after end of year. Is this the same as above?

I guess that is the bone of contention.  I say it is the same.  

Ed Snyder

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54 minutes ago, Bird said:

I guess that is the bone of contention.  I say it is the same.

It's a really tough  issue. In practice, whenever a client has called with a problem that deals with money being in the plan that cannot immediately be allocated, typically on account of a mistake of some sort or other, unless this specifically contravenes the plan document I will tell them just suspense it and use it up as soon as you can. Occasionally a recordkeeper will push back and say, "the IRS hates suspense accounts." I've never been able to find the statutory or regulatory basis for that "hate," and I've never had to deal with the issue in an exam, but they do definitely present some difficult issues. I will remain agnostic on this subject. Maybe just avoid if possible, and deal with on a case by case basis when comes up.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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9 hours ago, MoJo said:

No I understand completely.  A pooled plan is one where the participants do not control investments.  But in a pooled plan - the money is ALLOCATED.  You may or may not value the plan daily - which means you may not have a number of what earnings are allocatable to each participant's account until you do that valuation - but it can be done at any point in time with no other conditions or information.  The lack of a current valuation does NOT mean the money is not allocated.  It is.  

Amazing, you say you understand and then you spout nonsense.  I have a 401(k) plan for my company QPC.  We contribute approx 5% of payroll with every payroll period, then true it up at the end of the year to make sure I have a 5% contribution.  Since I have a last day of employment provision to get an allocation, there is no way the contributions made during the year are ALLOCATED until we reach the allocation date, which is also the valuation date, which is the last day of the plan year.  Until that point, it's invested in the pool but it has not been allocated to anyone's account.  If someone terminates on 5/1 of the calendar year plan, they get nothing of the 5% contribution that I'm planning on making for that year and those funds are freed up to help pay for the other people who, at the end of the year, are going to get their funds allocated.

BTW, I'm done responding.    You are entitled to your opinion, wrong though that it is.?

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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22 minutes ago, Larry Starr said:

Amazing, you say you understand and then you spout nonsense.  I have a 401(k) plan for my company QPC.  We contribute approx 5% of payroll with every payroll period, then true it up at the end of the year to make sure I have a 5% contribution.  Since I have a last day of employment provision to get an allocation, there is no way the contributions made during the year are ALLOCATED until we reach the allocation date, which is also the valuation date, which is the last day of the plan year.  Until that point, it's invested in the pool but it has not been allocated to anyone's account.  If someone terminates on 5/1 of the calendar year plan, they get nothing of the 5% contribution that I'm planning on making for that year and those funds are freed up to help pay for the other people who, at the end of the year, are going to get their funds allocated.

BTW, I'm done responding.    You are entitled to your opinion, wrong though that it is.?

Oh I understand.  You are simply not doing it the way the law requires.  You're not alone.  But that doesn't make it right.

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2 hours ago, Luke Bailey said:

It's a really tough  issue. In practice, whenever a client has called with a problem that deals with money being in the plan that cannot immediately be allocated, typically on account of a mistake of some sort or other, unless this specifically contravenes the plan document I will tell them just suspense it and use it up as soon as you can. Occasionally a recordkeeper will push back and say, "the IRS hates suspense accounts." I've never been able to find the statutory or regulatory basis for that "hate," and I've never had to deal with the issue in an exam, but they do definitely present some difficult issues. I will remain agnostic on this subject. Maybe just avoid if possible, and deal with on a case by case basis when comes up.

It is NOT a tough issue.  It isn't even close to a tough issue. Other than arm waving nobody has provided anything that puts the above into any sort of prohibited activity. Here's a slightly different example.  Take the case of a plan that defines employee grouping as "everybody in their own group". Putting aside the (red hering) as to whether it is individually directed or pooled, since the issue is the same in either case, the IRS is on record as saying that there must be a written instruction to the Trustee/Administrator from the Plan Sponsor that evidences who gets an allocation from the funds deposited.  So, the question is when this written instruction must be made? I believe there is a direct reference in the IRM that makes it clear that this written instruction must be made no later than the due date of the tax return of the Plan Sponsor. Given the (obviously false) assertion that the actual allocation must be made when contributed there would be absolutely no reason to define such a deadline.  None. This question came up towards the end of the Ask The Experts panel at the 2019 Los Angeles Advanced  Actuarial conference.  I initially answered that the deadline was well after the plan year end.  But I was getting that tingly sensation when you know there is a better answer.  A few minutes before the end of the session, as Kevin Donovan was approaching the microphone to provide the exact answer, I beat him to the punch by citing the correct deadline for the writing in question.  Since he was already at the microphone he stuck around long enough to say "agreed" if I recall correctly the sequence of events. So, to those who know him, my citation is "Kevin Donovan". 

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32 minutes ago, Mike Preston said:

It is NOT a tough issue.  It isn't even close to a tough issue. Other than arm waving nobody has provided anything that puts the above into any sort of prohibited activity. Here's a slightly different example.  Take the case of a plan that defines employee grouping as "everybody in their own group". Putting aside the (red hering) as to whether it is individually directed or pooled, since the issue is the same in either case, the IRS is on record as saying that there must be a written instruction to the Trustee/Administrator from the Plan Sponsor that evidences who gets an allocation from the funds deposited.  So, the question is when this written instruction must be made? I believe there is a direct reference in the IRM that makes it clear that this written instruction must be made no later than the due date of the tax return of the Plan Sponsor. Given the (obviously false) assertion that the actual allocation must be made when contributed there would be absolutely no reason to define such a deadline.  None. This question came up towards the end of the Ask The Experts panel at the 2019 Los Angeles Advanced  Actuarial conference.  I initially answered that the deadline was well after the plan year end.  But I was getting that tingly sensation when you know there is a better answer.  A few minutes before the end of the session, as Kevin Donovan was approaching the microphone to provide the exact answer, I beat him to the punch by citing the correct deadline for the writing in question.  Since he was already at the microphone he stuck around long enough to say "agreed" if I recall correctly the sequence of events. So, to those who know him, my citation is "Kevin Donovan". 

You make a very good point, Mike, and that explanation inclines me to think that indeed that is the correct answer. But I do think it is hard in terms of the competing principles and the lack of guidance on the specific issue regarding the earnings not being annual additions.

I guess your answer on the (highly hypothetical) partial termination issue would be that folks affected by a partial termination would not somehow "vest" in a portion of the amount in the "suspense account" (whether referred to as that in a plan instrument, or not), because they only vest in what is allocated and the amount was permissibly not allocated at the date of the partial termination?

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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14 minutes ago, Luke Bailey said:

You make a very good point, Mike, and that explanation inclines me to think that indeed that is the correct answer. But I do think it is hard in terms of the competing principles and the lack of guidance on the specific issue regarding the earnings not being annual additions.

I guess your answer on the (highly hypothetical) partial termination issue would be that folks affected by a partial termination would not somehow "vest" in a portion of the amount in the "suspense account" (whether referred to as that in a plan instrument, or not), because they only vest in what is allocated and the amount was permissibly not allocated at the date of the partial termination?

I've lost track of the partial termination question.  Are you sure it is not in another thread? IAE, something seems off.  The existence of a partial termination is plan year based. So, the relevant issue is whether an individual is an affected participant with respect to a given plan year.  If yes, then they are 100% vested in the account as of the last day of the plan year. The account AS OF the last day of the plan year INCLUDES all amounts allocated on an accrual basis for the plan year. 

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1 hour ago, Mike Preston said:

I've lost track of the partial termination question.  Are you sure it is not in another thread? IAE, something seems off.  The existence of a partial termination is plan year based. So, the relevant issue is whether an individual is an affected participant with respect to a given plan year.  If yes, then they are 100% vested in the account as of the last day of the plan year. The account AS OF the last day of the plan year INCLUDES all amounts allocated on an accrual basis for the plan year. 

OK. So it's admittedly a somewhat unrealistic hypothetical, although it seems like over time every unrealistic hypothetical is ultimately encountered at least once in actuality. So the point was, suppose that the employer, contemplating an "everybody in their own group" allocation as of December 31, 2020, to be calculated and allocated first quarter 2021, contributes the amount that it thinks will be approximately needed for the expected allocations, minus a year's worth of interest, in January, 2020, and the money is just parked in the plan. Plan has last day of year requirement for allocation. Employer RIFs 40% of its workforce in June, 2020. Does a participant who terminates in 2020 get a portion of what is allocated as of 12/31/2020, in first quarter 2021, notwithstanding the last day of year condition? Arguably, no, because participants affected by partial term only vest 100% in their account, and the 2020 discretionary should not be allocated to participant's account per terms of plan (last day of year requirement). But  this is at least an example of why having amounts in the plan allocated to a suspense account can at least appear troubling to some.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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2 hours ago, Luke Bailey said:

OK. So it's admittedly a somewhat unrealistic hypothetical, although it seems like over time every unrealistic hypothetical is ultimately encountered at least once in actuality. So the point was, suppose that the employer, contemplating an "everybody in their own group" allocation as of December 31, 2020, to be calculated and allocated first quarter 2021, contributes the amount that it thinks will be approximately needed for the expected allocations, minus a year's worth of interest, in January, 2020, and the money is just parked in the plan. Plan has last day of year requirement for allocation. Employer RIFs 40% of its workforce in June, 2020. Does a participant who terminates in 2020 get a portion of what is allocated as of 12/31/2020, in first quarter 2021, notwithstanding the last day of year condition? Arguably, no, because participants affected by partial term only vest 100% in their account, and the 2020 discretionary should not be allocated to participant's account per terms of plan (last day of year requirement). But  this is at least an example of why having amounts in the plan allocated to a suspense account can at least appear troubling to some.

You are preaching to the choir on the inadvisability of pre-funding. There are a bunch of my postings that rail against it.  What we are talking about here is labeling the pre-funding as disqualifying.  BTW, get rid of the "minus a year's worth of interest" because that is not allocable as a contribution. But you know that.

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56 minutes ago, Mike Preston said:

BTW, get rid of the "minus a year's worth of interest" because that is not allocable as a contribution. But you know that.

Well, maybe I know it, but it comes up so seldom I had not thought about it. So you are saying in the example only the $100k gets allocated comp to comp. The interest gets allocated in proportion to account size at some point in time. That does seem like the right answer, but shows how unusual the situation is. If it had been allocated when contributed, the interest in effect would be allocated in proportion to compensation, or some other nonaccount-balance-based algorithm, because that's how the underlying $100k was would be allocated. But as a result of waiting, the $100k gets allocated in proportion to account balance size, even though was not allocated to any accounts.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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41 minutes ago, Luke Bailey said:

Well, maybe I know it, but it comes up so seldom I had not thought about it. So you are saying in the example only the $100k gets allocated comp to comp. The interest gets allocated in proportion to account size at some point in time. That does seem like the right answer, but shows how unusual the situation is. If it had been allocated when contributed, the interest in effect would be allocated in proportion to compensation, or some other nonaccount-balance-based algorithm, because that's how the underlying $100k was would be allocated. But as a result of waiting, the $100k gets allocated in proportion to account balance size, even though was not allocated to any accounts.

The 100 k gets allocated per the formula. It does not get allocated per the account balance. Was that a test? Did I pass?

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OK, Mike. That's what I thought originally. But now, I don't really know. But I do feel we've plumbed the depths of this!

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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I have had plans that prefunded into suspense with individual accounts on several recordkeepers that allow for prefunding and allocating later with earnings split out. the reasoning i was always given from other recordkeepers for not allowing it was always a company rule (they didn't like the work involved with allocating earnings to each account I am guessing) and not anything related to any law.

A recent webcast I listened to you mentioned prefunding then allocating the contribution amount and using the earnings to offset expenses.  I had never operated in this manner but that seems reasonable as well. Would be interested on other's thoughts on that method.

 

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1 minute ago, mattmc82 said:

I have had plans that prefunded into suspense with individual accounts on several recordkeepers that allow for prefunding and allocating later with earnings split out. the reasoning i was always given from other recordkeepers for not allowing it was always a company rule (they didn't like the work involved with allocating earnings to each account I am guessing) and not anything related to any law.

A recent webcast I listened to you mentioned prefunding then allocating the contribution amount and using the earnings to offset expenses.  I had never operated in this manner but that seems reasonable as well. Would be interested on other's thoughts on that method.

 

That method seems fine to me.

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