View the full text of this job opportunity

View the full text of this job opportunity

Hi,

A PBGC covered plan received the following email from the pbgc...

This letter is to inform you that the Pension Benefit Guaranty Corporation (“PBGC”) was notified that a Reportable Event has happened.  According to the information we have received, "A" Corporation (the “Plan Sponsor”) has failed to make the required minimum contributions

1. Who are they referring to when they say they were notified? Who could have notified them?

2. The minimum required contributions that they are refering to are the possible  MRC that would be shown on the 5500 (that were not filed for a few  years) or are they referring to the pbgc annual.premiums that have not been paid?    Thank you as always for any insights. 

A client whose plan is terminating needs to locate the beneficiaries of two deceased participants.  One participant has a beneficiary designation on file; the other does not.  The employer is located in Pennsylvania.

Any recommendations for a commercial locator service?

View the full text of this job opportunity

I apologize if this type of question has been answered previously, i could not locate it.

Is it best practice to carryforward Beneficiary data from a prior plan during a Plan Merger or Plan Takeover client, or to require all participants to re-enter their Bens in their new account?

Notice 2025-67  just released, with the official retirement plan limits for 2026.

This is been a problem for a long time and I haven't asked this question in a while: 

What is the easiest way to find old terminated employees to try and pay them out? 

Thank you.

Hello.

Participant is looking to take a loan to purchase a primary residence.    He is purchasing a house.  However, he is not planning on moving in right away, as he has a lot of repairs to do. 

Is there a time frame to consider this his primary residence?   

Thanks!

View the full text of this job opportunity

I realize versions of the question have been asked, but I cannot find a specific clear answer. In fact, I have received differing opinions on it from my normal go-tos.

There are four business in question. We are looking at various retirement plan options available. Owners are spread between a married Father and Mother, their Son (over age 21), and the Son’s Wife.  There is no trust involvement, nor is there any buy-sell agreements or options agreements across these businesses.

Here is the ownership structure:

“A”

Father, 1/3

Mother, 1/3

Son, 1/3

“B”

Father, 1/2

Mother, 1/2

“C”

Father, 1/2

Mother, 1/2

“D”

Son, 99%

Son’s Wife, 1%

A, B, and C have several employees. D is a separate business that does not have employees (owner only).  All of my normal resources agree there is no issue with an Affiliated Service Group, leaving the only questions one of ownership control group.

Here is my take:

1. The son would not be attributed ownership of either parent for any of the other companies, as he has less than 50% ownership in A.
2. If 1 is true, a SEP should be allowed in D, with a separate 415 limit available.
3. B and C are certainly a control group.
4. Father and Mother would be attributed each other’s ownership, placing them above the 50% threshold in A to also then require they be attributed the son’s 1/3^rd share, placing the mother and father at 100% effective ownership, making A, B, and C all a combined Control Group, but still leaving D separate.

One TPA has said that #4 is wrong, and that A is not brought into the CG. Other's in my sphere agree with my read as above.

For now, the A/B/C question is moot as we will open the same Plan across each of these anyway. But it matters for future potential changes, as well as needing to know if we are clear to do the SEP in D for the son.

Thanks in advance.

View the full text of this job opportunity

Is this possible?  Another work around we thought of is to exclude HCE's from the safe harbor match and benefit them with a discretionary match.  It seems like just limiting compensation would be easier.

https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/advisory-opinions/2025-03a

Do people agree that if a plan is designed as a top-hat plan specifically, the concerns outlined here are not applicable? The Morgan Stanley plan does not sound like a plan exclusively for HCEs and management.  Sounds like a plan offered widely to all advisors.  I assume that is the issue.  And I further assume that because the benefits are paid when vested there is no deferral of income anyway which eliminates concerns about "funding." 

Do I have this about right?

The plan provides a Safe Harbor Non-Elective Contribution (SHNE) and excludes Highly Compensated Employees (HCEs) from safe harbor contribution. In this situation, there are five HCEs in the plan, and the client wishes to provide the SHNE to only two of these HCEs while giving no safe harbor contribution to the remaining three. The question is whether this allocation is allowable under IRS regulations, and if permissible, which specific regulations authorize it. Refer the adoption agreement snip.

View the full text of this job opportunity

View the full text of this job opportunity

What is everyone following as far as a retention schedule for distribution information? Meaning, how long are you holding onto copies of outgoing correspondence on plans? 

View the full text of this job opportunity

Are we all agreed that the rule is $145K of FICA wages to be a Highly Paid Individual (or High Earner or whatever your favorite acronym is) for 2026?  I thought I heard something about it being increased for cost-of-living from 2024 to 2025 and that might make it $150K, but I don't see anything official on that.  Thanks.