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Permitted Disparity Language on Statements--New Comp?


BG5150

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I know participant statements must get a blurb if the PS is allocated using a permitted disparity formula (integrated with SS).

What if the formula is grouping method and subject to testing?  The contribution COULD be allocated using permitted disparity.  Is that same disclosure needed on the statements in that case?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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I would say no. The allocation method is whatever it says in the plan document, presumably individual groups if it's new comp. Just because you choose to test the allocation by imputing permitted disparity, does not mean that the allocation is based on permitted disparity.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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