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Showing content with the highest reputation on 12/14/2020 in all forums
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TPA/ Administrator's Workload
Bill Presson and 2 others reacted to Catch22PGM for a topic
A lot of great input here from a wide variety of experiences. I worked more than 20 years for an independent, family-owned TPA firm. My (now) business partner and I ran all of the operations of that firm for many years as the owners were not retirement plan administrators (long story). This included managing staff, establishing procedures, reviewing/auditing all work, etc. In addition to those managerial tasks we each were directly responsible for the administration of 120-150 plans each. We had three support staff and two were fired by the owners about 2 years before we left the firm. No reason for the firings of two long-term and dedicated staff members other than to cut costs. We left and founded our firm with a business model formed around that experience. We have a firm stance that no administrator will handle more than 65 plans. Like many who have posted here the actual number isn't completely relevant. We ensure there is an even distribution based upon plan size, design complexity, and revenue. We won't be the most profitable TPA out there and we are fine with that. Our intent is to maintain a good work-life balance for ourselves and our employees. Every person has a different breaking point and different financial needs. The advice I share, which is something that was shared with me many years ago - be happy. Money is necessary and we all do what we must, but life is too short to stay in a situation that makes you stressed and unhappy. There are a lot of good TPA firms out there that treat their employees with respect. Your resume should be strong enough to give you plenty of options so go out there and find a firm where you can be happy. Best of luck.3 points -
Beneficiary Question
Luke Bailey reacted to Bob the Swimmer for a topic
What does the Plan say ? If it goes to the estate, the probate court will decide if the new beneficiary meets the testator's requirements,1 point -
Also welcome to the forums, ABeach.1 point
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Safe Harbor Contributions Used in ACP Test
Bill Presson reacted to C. B. Zeller for a topic
1.401(m)-2(a)(5)(iv)1 point -
For Profit Sub of 501c3
Luke Bailey reacted to Peter Gulia for a topic
https://ecfr.federalregister.gov/current/title-26/chapter-I/subchapter-A/part-1/section-1.403(b)-21 point -
For Profit Sub of 501c3
Luke Bailey reacted to Belgarath for a topic
NYET. Unless the sub meets one of the other definitions of eligible employer. See 1.403(b)-2(b)(8)(ii) - if my magic thumbs typed the citation correctly...1 point -
Short Initial Plan Year Cash Balance/401(k) Combo
Catch22PGM reacted to Effen for a topic
I agree with "the other admin". I see no reason to do a short plan year - it just complicates the process. However, to answer your initial question, yes, having a short plan year can significantly reduce the amount of the DB contribution in year one. I would argue needlessly, because as the other amin said, "there is generally no compelling reason to have a short plan year".1 point -
payment question
Mainer reacted to gc@chimentowebb.com for a topic
You've simply converted a short term deferral into a 409A arrangement (payable for a permitted reason). I don't see an issue except that after you do this you can't change the timing without complying with the 409A rules. For example, if you later decided it was too long to be committed to this and wanted to cash him out, you wouldn't have that flexibility.1 point -
Beneficiary Question
Luke Bailey reacted to QDROphile for a topic
This is an interpretation question. It may well involve corporate law, e.g., is ministry B the legal corporate successor to ministry A? That might provide a satisfactory answer. It might not. I would start there, because it is conventional.1 point -
Short Initial Plan Year Cash Balance/401(k) Combo
Catch22PGM reacted to justanotheradmin for a topic
I'm curious, I rarely see small 401(k) plans with compensation as the calendar year, though many pre-approved plans do allow the option. I think for it to work the way you suggest, it would need to be very clear, such as plan compensation being defined as compensation in the 'calendar year ending in the plan year' , which would make the compensation period disregard the short plan year. Is that really how the document is written? More typically, I see plans use the default, plan year, which for a short plan year, does get limited to ACTUAL compensation earned during the short plan year. The compensation limits being prorated is a separated issue. To avoid the issue you've encountered, we often draft new plans with special deferral and safe harbor start date of 10/1, but the plan effective date is still 1/1. This makes is clear that is the employer wants to give a discretionary employer contribution ( or add a DB plan), the plan year is the full calendar year. There are some compelling reasons to have a short plan year from 10/1 -12/31 for an initial plan year, but I don't see them often. Which document provider do you use? Or are you willing to share the language from the 401(k) plan? Also - I suppose they could adopt a PS only plan effective 1/1/2020, would that make the actuary feel better when combined the PS, 401(k)/ SH, and CB benefits for testing?1 point -
@dmwe Yes, I agree. My position is the excess contributions (i.e., amounts contributed in excess of the reduced cap caused by the NDT) are no longer dependent care FSA balance amounts. Therefore, any amounts not already distributed prior to the reduction need to be directly returned or made available without the need to submit qualifying dependent care expenses. Here's a summary: https://www.theabdteam.com/blog/failing-dependent-care-55-average-benefit-test-2/ Excess Contributions Not Distributed: Refunded as Taxable Income or Recharacterized as Taxable Income The amount of HCE contributions in excess of the reduced limit that have not yet been reimbursed to the HCEs must also be made taxable income before the end of the year. There are two possible approaches: Refund/Return: Have the TPA refund the excess contributions to the company (skip if amounts are not held by the TPA), and then the company will distribute the excess back to the HCEs through payroll as standard taxable wages included in gross income and subject to withholding and payroll taxes by the end of the year. Recharacterize: Recharacterize the excess contributions as taxable income in the same manner as the excess distributions. Then inform HCEs that they may take a distribution of the excess contributions (which no longer have pre-tax status) from the FSA without the need to submit qualifying dependent care expenses.1 point
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Switching to more restrictive vesting schedule
Robin Wilson reacted to BG5150 for a topic
That applies to the accrued benefit. You can make it more restrictive going forward. You would just have to record-keep two buckets for each vestable money type. At least that's the way I've always seen it.1 point -
This is an interesting thread. It's not really about how many plans, for the reasons mentioned - size and complexity. A different metric, not necessarily the be-all and end-all, is revenue. I think most owners feel their admins should be billing at least 2 times their salary plus benefits; some maybe 3X. I'm a lousy businessperson/owner and never really got to 2X. 300 plans with one person primarily responsible sounds pretty crazy to me. I imagine they would be totally and completely screwed if you left...1 point
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TPA/ Administrator's Workload
Catch22PGM reacted to C. B. Zeller for a topic
Disregarding the "how many" question, since as RatherBeGolfing points out, it is basically meaningless, and focusing instead on the real question here - should I quit my job? This is not an easy question, and ultimately only you can decide what to do. There are countless posts on this board complaining about the quality of plans sold by payroll companies, and I think it's clear why - those companies tend to be solely focused on sales volume and not interested in providing their employees with the training or resources they need to do proper administration. There are always going to be stressful times of year in this field, no matter who you work for or what you do. In our firm, sales and ongoing administration are separate departments - for admin, the most stressful time of year is October 15. Different people respond differently to stress, and jobs with this sort of annual cycle are not for everyone. That said, having a good team makes all the difference when you know you are all in it together. I would start sending out resumes if I were in your position. If you haven't updated it recently, do it now; with 7 years experience working on plans you probably have a lot to add. I wouldn't suggest leaving your current job until you have something new lined up though.1 point
