for Human Interest (Remote / Tacoma WA)

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for Centers for Medicare & Medicaid Services [CMS] (Seattle WA / Denver CO / Dallas TX / Boston MA / Woodlawn MD / Hybrid)

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A plan has life insurance contracts, mostly whole life, with very sizeable cash values.  A participant that is well beyond RMD age is planning to retire this year.  To date, no portion of the  Life insurance has been swapped out.  Participant will continue to do some consulting and have continuing 1099 income.  Financial advisor wants to pitch the idea of rolling over the life insurance policy in-kind into a solo-K for the participant (along with the other plan assets), so that life insurance policy can continue.  It is my understanding that life insurance can be rolled over in-kind as long as the distributing plan allows (which is does) and the new plan allows for life insurance (it will be drafted as such).  It is also my understanding that rollovers do not count toward the incidental benefits test, so the plan would not violate this if the premiums are being paid from rollover funds.  Is this correct?  

Forgive my ignorance, I have very little experience with life insurance.  What happens with the 40 years of PS 58 costs that have accumulated to date under the original plan?  Going forward  the premiums will be paid by employee (pre-tax rollover) contributions, would these be includable in income (would he still need a 1099 for PS 58 costs each year?) H

He has sufficient assets (if he rolls over his other funds) to take his annual RMDs from those assets.

What pitfalls do you see with this plan?  How does he get ultimately get these policies out of the plan into his personal ownership?  Can partial swap outs be made?   

Thank you for any input.

Hi

I have not had an experience with low balances for many years and just want to confirm my findings.

Checking a PBGC termination for a CB plan - official termination date is late August 2026.. There are a few participants missing but their balances are less than 7k. Some are as low as $500

Plan just got amended to increase the force-out to 7k.

If the participants cannot be located, PBGC will take over their balances as lump sum since no annuities, correct?

Instead of PBGC taking over, can the balances be transferred to an IRA thru a company like Penchecks? If yes, is this subject to PBGC approval?

Thank you

Hello all,

I'm an Enrolled Actuary working in pension consulting and I wanted to share a project I've been building: ZAP Tools, a free and open source pension valuation suite targeting US single-employer defined benefit and cash balance plans. Perhaps due to my younger age, I find current legacy solutions reasonably clunky and dated to execute work in, so this is my good faith attempt to build something modern for all pension actuaries and retirement professionals.

The suite consists of two components: an Excel add-in for light valuation work, benefit calculations, and plan design modeling, and a full desktop application for formal funding valuations. The full actuarial engine is complete, the Excel add-in is production ready, and the desktop application is in active development with a public release targeted for later this year under the AGPL license.

One design decision worth highlighting for this audience: every expression in the desktop application, benefit formulas, participant filters, data validation logic, uses standard Excel syntax. No proprietary scripting language to learn while maintaining maximum flexibility in defining plan provisions or benefit formulas.

I've posted more detail and screenshots on LinkedIn and Reddit for those interested:
LinkedIn Post
Reddit Post

Happy to answer any questions or discuss here. Always interested in feedback from practicing professionals. Thank you for your time and attention!

Hi all, 

I've been doing this for what seems forever and I've started to think maybe I should be working for myself.  Does anyone have any leads or are aware of someone wishing to sell their TPA practice in the near future?  

 

thanks!!

 29 CFR Section 2530.206(c) states that 

"(c) Timing.
(1) Subject to paragraph (d)(1) of this section, a domestic relations order shall not fail to be treated as a qualified domestic relations order solely because of the time at which it is issued."  We all know what this means or do we.  It certainly means that a QDRO can be entered for the benefit of the Alternate Payee if the Participant had died before a QDRO is approved. But does it also mean that the estate of the Alternate Payee can obtain a QDRO if the Alternate Payee dies before a QDRO has been entered? 

We know this means that, with respect to defined benefit an defined contribution plans, a QDRO can be entered in favor of an Alternate Payee if the Participant has died before the QDRO was approved. 

But can the Alternate Payee's estate obtain a QDRO when it is the Alternate Payee that has died before the QDRO has been entered and you are dealing with a ERISA qualified defined contribution plan? 

Thanks,

David

for Wolters Kluwer (Remote / Madison WI / Hybrid)

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Two corps have the same owners and are a controlled group. 

Instead of opening one DB Plan to cover both corps, two DB plans were set up. 

One DB plan for each corp.

One owner was placed in plan A that covered him and the employees of corp 1 and the other owner was placed in the plan B that covered him and the employees of corp 2.

1. Owner 1 in plan A was supposed to take an RMD from plan A. Inadvertently took the RMD from plan B. 

Is this an issue, or since this is a control group, the plans technicly cover both entities?

2. What if owner 1 in plan A for a few years deposited his contributions into plan B, Inadvertently? 

 

Thank you for any insights into this!

for Vestwell (New York NY / AZ / PA / TX / Hybrid)

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for Vestwell (Remote / New York NY)

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for Vestwell (New York NY / AZ / PA / TX)

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Is it common to send COBRA participants as of prior eoy who no longer have COBRA a copy of the prior year SAR?

One client is resistant.

We are in the US and the employee in question works in the US.    We use the safe harbor hardship definition.  This participant was originally hired in 2017 but had two small periods of non-employment (1-3 months) before being rehired in 2019 and working uninterrupted since then.  They are applying for a hardship withdrawal to prevent eviction from their "primary residence"--which is in Australia.  I vote not to approve.  Any thoughts?

Logistics of the situation:

- PBGC Plan, S Corp, Involves testing, Plan Eff date is within the last 5 years (for purposes of 436 restrictions)

- 2025 Valuation completed (signed report but no SB) by prior Actuary, BOY Valuation, AFTAP over 100% certified before September 2025

- After takeover, decided to redo the 2025 valuation and valuation date changed to End of Year. No other assumptions changed. Automatic approval for change to end of year due to Revenue Procedure 2017-56 Section 4.01. 

Do I need to re-certify the 2025 AFTAP or can I rely on prior Actuary's AFTAP and use it on the 2025 SB?

To clarify, the 2025 valuation report is expected to be recertified in next few weeks (say 6/15/2026). So, if I cannot rely on prior Actuary, will the AFTAP restrictions apply until certified?

Thanks!

 

for Employee Benefits Security Administration [EBSA] (Washington DC / Hybrid)

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Terminated participant took final distribution. Nonvested portion has been forfeited.

As this was the only non-key participant, the full forfeiture account balance is from this participant.

Plan has since decided to make a PS contribution for the prior plan year, and this participant is due a top heavy min 3% contribution.

Plan doc allows forfeitures to be used towards top heavy minimum contributions.

Doesn't seem to feel right, but any reason the top heavy minimum contribution cannot come from participant's own forfeitures?

 

for Teachers Retirement Association (Saint Paul MN / Hybrid)

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We have a plan that has moved from a group variable annuity to a mutual fund based investment arrangement.  Do I need to file a schedule D if the plan only has mutual funds? As from our knowledge it does not meet the 4 required entities to file a schedule D.

Short plan year with 415 limit at $24k and comp limit at $120k.  Basic SH Match formula (100% of 3% and 50% up to 5%) = max match of $4800.

Employee's original comp = $278,913.71 with $19.397.03(6.95%) in deferrals and $11,156.55(4%) in match.  Exceeds 415 limit by $6553.58

Step 1:  Distribute unmatched elective salary deferral contributions (adjusted for earnings) to the affected participant.  Is this based of original comp of $278,913.71 or the pro rata comp of $120k ?  If it is original comp of $278,913.71, then reduce deferrals by 1.95% or $5438.82.

Step 2: Distribute elective salary deferral contributions (adjusted for earnings) that are matched, and forfeit related employer matching contributions (adjusted for earnings).  $1114.76 of excess still remains after Step 1.  Reduce deferrals by $557.38 and forfeit match by $557.38

If employee is eligible for catch up contributions, then no refunds of deferrals, only forfeiture of $557.38 of match.

With the forfeiture of $557.38 of match, this brings the match total down to $10,599.17.  Would I then reduce the match down to $4800 ?

 

Does this sound correct ?

 

Thanks in advance for the help.