Leaderboard

In today’s prepublication release about Form 5500 reports on 2022: The Agencies are still evaluating public comments on elements of the September 2021 proposal not included in these final forms revisions, including . . . changes in participant counting methodology for Independent Qualified Public Accountant (IQPA) purposes[.]”

Bottom line: Were they paid for 12/31? If so, they were employed on that day.

Several issues here, but I will assume the participant received a valid Suspension of Benefits Notice when they attained NRA. The SOBN eliminates the need to provide an actuarial increase from NRD, but the participant is still entitled to plan formula increases for continuing to work. If they didn't receive the SOBN at NRD, you may have other issues. However, post MRD, the plan must provide BOTH the actuarial value of the delayed payments, plus any additional service/compensation related increases. Plan document should detail the specifics of each scenario and there are a few possible ways to handle it. Are you saying this 95 year old participant is still actively employed? Check out 1.401(a)(9)-6.. Q/A 7, and others.

Did she freeze the benefit AT her 415 limit? Could the plan allow for excess assets to be reallocated to the participant up to her DB 415 limit first?

Dislike: Too much government interference which, unfortunately, is becoming the norm/ Like: Helps EEs save for retirement/may help testing pass/encourages plan participation/the added bonus of a matching contribution

I think David Rigby meant the agreement should not say the seller's employees "will" roll over their balances, but that they "may" roll over their balances (although he can correct me if I'm misinterpreting). And, as he mentions, plans can allow immediate rollovers in even if the employee has not yet reached the regular eligibility requirements. Terminating the plan now or 60 days from now generally won't make a difference.

I thought the consensus was that -11g amendments could be used even without any sort of failure.