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Showing content with the highest reputation on 05/12/2022 in all forums

  1. I put together a spreadsheet that will calculate single life and 100% J&S APRs. This was inspired by comments from @401king and others in another recent thread. You must enter the interest rate and age on the Input tab. You can optionally enter an account balance, if you do it will calculate the annuity amounts in addition to the APRs. Important: you must enter the values from the correct mortality table on the "Mortality" tab. The mortality tables are published by the IRS, for example the 2021 table is here: https://www.irs.gov/pub/irs-drop/n-19-67.pdf Use the values in the column labeled, For distributions subject to 417(e). If someone wants to enhance this workbook to automatically pull the 417(e) tables, or the 10-year CMT rates, that would be fantastic. Use this workbook at your own risk. I believe it will generate correct results based on the inputs but I can not be responsible if it fails in some cases. I can not promise that it will not immediately delete all your files and melt your CPU the second you open it, either. Treat it like any other file you would download from an anonymous internet stranger. APR calculator.xlsx
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  2. The prior thread with a spreadsheet that computes the amount. I assume you would still need to update the monthly interest rate that is based on one of the US Treasury bill/bonds. We have put numbers in this spreadsheet and what is coming off our software and get the same results.
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  3. Check Revenue Procedure 2021-30. I don't think your case falls into on that is specifically addressed but I do think you fall into an Operational Failure than the can be corrected under Self Correction under the Rev Proc if you follow the timing in 9.02 which it seems you have (assuming you've credited lost earnings for the late deposit). Though I'm not an attorney so you should probably run it by ERISA counsel before making a final recommendation to the client.
    1 point
  4. CuseFan

    cash balance/psp

    This happens all the time (<0.5% accrual) in CBPs, especially those with a relatively low interest crediting rate. The "worth" is in the large contributions attainable for the business owner(s).
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  5. They would be on the new schedule, since they weren't a participant yet as of when the vesting formula changed. Much as coffee is for closers, vesting is for participants.
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  6. For a non-hce, absolutely. The requirement is that 401(a)(4) passes with and without considering any QNEC (11g exclusive) because a bottom-up QNEC will undoubtedly skew the results towards passing while not necessarily benefitting other non-hce's in the anticipated fashion. And a corrective contribution is likely going to a similarly profiled participant. But in the case of a HCE corrective, you have the opposite issue, and would need to consider it in the test.
    1 point
  7. CuseFan

    DC/DB Combo - Gateway

    7.5% is the maximum gateway required in any combo situation - the gateway can never be higher but a greater contribution may be required to satisfy the nondiscrimination testing. Also be careful if your DB is a CB - the normal allocation rate is NOT the contribution crediting rate, so 3% SHNE + 2% PS + 2.5% CB does NOT equal 7.5% gateway.
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  8. No. To satisfy the combo gateway, the aggregate normal allocation rate (ANAR) has to be at least 7.5% for all NHCEs if the ANAR for any HCE is greater than 35%. Aggregate means the sum of the DB and DC allocation rates. You convert the annual accrual in the DB plan into an allocation using the interest rate and mortality selected for testing. For NHCEs getting an accrual in the DB plan, you can also substitute the average DB allocation rate for all NHCEs instead of using each individual's allocation rate; this avoids having different PS allocation rates needed for every employee to satisfy the gateway.
    1 point
  9. PMZJohn, there is a transition rule where you have been using the life expectancy of the beneficiary minus 1 each and now the table has changed. Basically, you go back and start with what would have been the beneficiary's life expectancy in the first year that he or she received a distribution, using the new table, and then subtract 1 from that for every year, including the pre-2022 years. So in your example, it would be 23.1. See Treas. Reg. 1.401(a)(9)-9(f). But this only applies where you have a nonspouse beneficiary, or the surviving spouse was older than the participant. Otherwise you should be recalculating the surviving spouse's life expectancy each year. See Treas. Reg. 1.401(a)(9)-5, Q&A-5(c)(2).
    1 point
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