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Showing content with the highest reputation on 02/14/2019 in Posts

  1. Not disagreeing with Lou - just mentioning that the terminology of the Notice is different for different for different people. Many people refer to the "maybe" notice as the notice one gives when a plan utilizes the "maybe" election - that is, the plan is NOT a safe harbor UNLESS the plan is amended into safe harbor status for the year. In your situation with a 3% SH contribution, we would refer to this as a "maybe not" notice, which as discussed previously allows you to amend out of SH status. Sample wording contained in the annual Safe Harbor Notice - we use the FIS/Relius document system. IV. Suspension or reduction of safe harbor nonelective contribution. The Employer retains the right to reduce or suspend the safe harbor nonelective contribution under the Plan. If the Employer chooses to do so, you will receive a supplemental notice explaining the reduction or suspension of the safe harbor nonelective contribution at least 30 days before the change is effective. The Employer will contribute any safe harbor nonelective contribution you have earned up to that point. At this time, the Employer has no such intention to suspend or reduce the safe harbor nonelective contribution.
    2 points
  2. Pam Shoup

    ASPPA DC-2 Exam

    What I do with my staff is have them identify those things that always seem to trip them up. I then have them write down tips on those things on a sheet of paper, usually in a grid format. For example QACA, EACA, ACA across the top and things like vesting, auto esclation, etc. down the side. I have them do that writeup over and over again until they can do it from memory. On the day of the exam, the testing center will give you blank paper and a pencil. Before they start the exam, the candidate writes up their tips/grid on the blank paper. Then when you get to those questions, you have something in writing to look at to help keep things clear in your mind. Do the practice exams over and over again, as some of the questions from those will appear on the final exam. Also, is there anyone else in your office that you can sit down with? For example, I have my ERPAs do training sessions with my QKA candidates on things they needed some additional guidance on.
    2 points
  3. Yep, I believe Derrin Watson coined the "maybe not" term in an ASAP or Relius update after they came out.
    1 point
  4. @Pam Shoup suggestion above is great. It needs to be done by hand rather than typed on a computer. Studies have shown that doing it by hand increases memory retention significantly. When I was in law school I took all my lecture notes by hand and I did my outlines by hand before I put them into a word document. I do the same thing whenever I study for a designation or read a new proposed rule or law change. For actual studying I do something like this Week 1 Read Ch1 (or part 1, section 1, whatever), then outline Ch1 on the second read Week 2 Read Ch2 , then outline Ch2 on the second read, study Ch1-2 outline Week 3 Read Ch3 , then outline Ch3 on the second read, study Ch1-3 outline Do this until you have outlined all of the required material. The outline should mainly focus on the learning objectives from the syllabus unless there are new things there that you also feel are important. Since different sections are weighted more or less on the exam, you can substitute Ch1 above for whatever section is going to be used more on the exam, that way you read that outline each week and should know it well before the exam. There is no point in doing a 5 page outline on plan loans and a 1 page outline on testing if you are going to get one loan question and 10 testing questions...
    1 point
  5. If it complies, it complies. We routinely get divorce decrees in lieu of a DRO, but in most cases, it doesn't qualify and we recommend a separate DRO. It can be fun reading them though! Our favorites involve who gets a half bottle of Johnny Walker Blue Label scotch (wife, but there was a notation in the margin that it was moot because the husband drank it), and another where the husband gets the farm equipment, but the wife gets a "pitch fork."
    1 point
  6. As long as the match that was earned under the traditional safe harbor is preserved at 100% vesting, I think it is ok.
    1 point
  7. It should be fine - you can amend the vesting schedule with respect to benefits that accrue after the amendment date. That said, would anyone even be affected by this? Assuming the plan requires 1 year of service for eligibility, then someone hired in 2018 would enter the plan in 2019 while the traditional SH match is in effect and be fully vested. Then in 2020 it would change to the QACA but they will already have 2 years of service, so they would be fully vested regardless. Someone hired in 2019 would enter the plan in 2020 under the QACA and be subject to the 2-year vesting from the start. Obviously the calculation changes if you use more lenient entry than 1 year of service.
    1 point
  8. If you are using the EPCRS correction method for overpayments to correct payment of non-vested amounts and the participant does not return the overpayment, the correction method says that the employer or another person must contribute the necessary amount to the plan to make the correction and it gets allocated using plan provisions. But, note that a retroactive amendment as discussed above is also an option under (f) below. If you are not correcting by retroactive amendment, I would expect the correction to be done under SCP with no IRS involvement.
    1 point
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