This is about as basic a 403b question as it gets: It seems like there is very little in the way of information that is needed when preparing a 5500 for a 403(b). Am I reading the instructions correctly that only the Form 5500 needs filed and that there are no schedules that need to be attached (e.g., not schedule H/I financial information)? Furthermore, participant count information on the 5500 is also not needed (line 6&7)?

Finally, if the above is true, then does the SAR omit the financial and participant count information as well?

Thanks for your help.

I am looking at a contract with an IRA vendor for purposes of implementing the automatic rollover process. According to IRS Notice 2007-7, the PPA expansion allowing nonspouse beneficiaries to make rollovers does not apply for purposes of Code Section 401(a)(31)(B), the automatic rollover provisions. Does this mean that if one extends the automatic rollover provision to nonspouse beneficiaries, the automatic rollover does not get the protection of ERISA Section 404©(3)?

It is my understanding that on and after 8/25/07 if assets are exchanged from one vendor to another and information sharing agreement may be required. That is, share information re loans, hardships, distributions, etc.

However, if an employee does not exchange assets, the information sharing portion goes into effect on January 1, 2009 when the plan document is in place. So, if an employee wants to take out a loan from an existing vendor before January 1, 2007, that can be done without first going to the employee to see if any other vendor offered a loan.

Is this correct?

well, ok, here is an attempt to pull/sort whatever

age 55 and 10 years participation for purposes of diversification

this report adds 10 years to date of entry

adds 55 to date of birth

then takes the later of the 2.

I suppose if someone doesn't complete a year of participation, then of course 10 years of participation will be wrong, so in fairness years of participation are printed. If ee terminated with less than 10 years of participation it will indicate ee not eligible to diversify.

and there is a note to indicate which year of diversification ee supposedly is in

(it will be negative if ee has not reached year of diversification.)

what the heck. its a free report, use at own risk

I guess I am confused. I am preparing an SAR for a welfare benefit plan. THe plan has health & dental insurance. Do I need to include specific insurance information on the SAR? By insurance information - I mean does the SAR need to include who the employer has contracts with and how much it paid in premiums?

I am confused because

1. the employer has a master group policy - does this mean the above info is not needed?

2. My software is not including the additional info which makes me think it's not necessary.

Thank you!

I guess I am confused. I am preparing an SAR for a welfare benefit plan. THe plan has health & dental insurance. Do I need to include specific insurance information on the SAR? By insurance information - I mean does the SAR need to include who the employer has contracts with and how much it paid in premiums?

I am confused because

1. the employer has a master group policy - does this mean the above info is not needed?

2. My software is not including the additional info which makes me think it's not necessary.

Thank you!

I have a prospective New Comp plan that is considering a Roth 401k feature. Do the Roth 401k deferrals effect the employer contribution to the New Comp plan any differently than they would if they were from a traditional 401k plan with regards to limits and testing?? Thanks.

On schedule H, is the value of "benefits responsive" insurance contracts reported at fair market value or contract value?

The instructions to Schedule H say use the same basis as line 3 or line 6 on schedule a, but the instructions in those line items don't tell you what basis to use?

Is anyone inquiring regarding Fair Market value? Is there anything published which explicity states contract vs. fair value?

Greetings-

I realize that this forum deals with some very advanced and complicated 403b issues and many of you are professionals with a focus in Fiduciary Guidance. So forgive the ignorance implicit in my posting. However I do think this relatively general question and the corresponding input may be a valuable contribution to this forum.

Background:

I am the CFO for a small 501c3. I am a CPA but know very little about administering 403b plans. I do the payroll in-house using Quickbooks. We have 5 employees and I have been tasked with setting up our 1st 403b plan. There will be a 1% employer contribution to the new 403b. I know we are required to be ERISA compliant. We plan on hiring a professional to draft our Summary of Plan Description.

Questions:

What kind of time will I have to put in on a monthly basis to maintain our 403b once it's set up and running?

Is maintaining our 403b something that requires expertise above and beyond prudent investor level?

Am I getting in way over my head?

Is it practical to set up a 403b Plan for a 501c3 that is small and operating with a limited admin and overhead budget?

The company owner "borrowed" $100,000 from the plan a few years ago. He has been paying 8% interest on the loan to the plan, but no principal payments.

Line 4d of Schedule I asks if during the year were there any nonexempt transactions with a party in interest.

The original transaction occured in a prior year. For excise tax purposes on the prohited transaction, I know each year that it is not corrected it is considered a new loan for calculating the tax.

Would this "loan" be put on line 4d each year until it is corrected, or would it be put on line 4d only in the year that the original tranaction took place.

Thanks.

Safe Harbor plan using 3% nonelective. The plan was prepared with an effective date of 7-1-07. The document defined the first plan year as a short PY (7-1 to 12-31). The 3% nonelective is based on compensation for the plan year. For the first year that means from 7-1.

Can the plan be amended now to state the first plan year will be from 1-1 thru 12-31 and still retain its Safe Harbor status inasmuch as the S-H Notice already distributed defined the first plan year as a short PY?

Also - if the Safe Harbor Notice already distributed didn't mention a Match (other Employer contributions), can the plan (same plan as above) be amended to include a Match without jeopardizing the Safe Harbor status?

Can a flexible spending account and a limited purpose flexible spending account (offered in conjunction with an HSA and HDHP) be combined and filed on one Form 5500?

A doctor uses only leased employees. Currently he makes no contributions on behalf of those leased employees. His current plan's contributions mirror those allowed in the leasing organization's plan; deferrals, safe harbor match, and discretionary profit sharing (3% of pay). The 3% profit sharing is proving not to be enough for the doctor's retirement needs.

Since the profit sharing is discretionary, can he increase his profit sharing to (let's say) 10% for himself and contribute an additional 7% on behalf of the leased employees to make sure that his plan passes coverage?

Any thoughts or concerns are greatly appreciated.

We have a client that changed service providers at the end of 2006, and the new provider made the client amend and restate to the provider's document platform. The client also decided to add Roth 401(k) contributions. The problem is that it is now August and nobody bothered to inform participants that they now have the ability to designate pre-tax elective deferrals as Roth Contributions.

Anyone else have this problem?

On the 401(k0 Board there is a thread aobut notifiying Participants of things they can do to get the full match and things they can do wrong.

Other than making sure it is discussed at education meetings, I have not found another way to bring this to the Particiapnt's attention.

Does anyone have other ideas?

Is this in SPD's or Relius commonly asked questions?

Our Plan requires that anyone on leave not subject to FMLA for longer than 60 days loses their medical benefits and is offered COBRA. Our company requires that employees make contributions while on leave by personal check directly to the company.

My question: The employee doesn't make the contributions, he doesn't enroll in COBRA and then returns to active employment after 90 days. Can he re-enroll in the medical plan? He has been without coverage for over 63 days so is he now subject to our pre-existing considitons clause?

Thanks.

Two questions I can't seem to resolve for a client......(even though I doubt they would actually adopt such provisions)

Are 401(k) plan sponsors required to allow participants to continue to make elective contributions if working past 70.5 or does each plan set their own rules?

Are 401(k) plan sponsors required to allow participants to continue to defer (not take minimum distributions) if still working with the employer past age 70.5, or is this governed by the plan document provisions adopted by the sponsor?

Thanks for feedback and any citations to regs if available.

running a 12/31/2006 plan year end. currently vesting is 3 yr 20%

at the end of the year lady has 2 yrs of svc. so 0% vested.

the census data indicates she quit January 2, 2007.

but now, for plan years beginning 1/1/07 plan has to be on a 2/20% schedule.

top that!

The 90 day period for considering certain distribution options is extended to 180 days. If the plan doesn't mention the 90 day period, is the extention to the 180 day period an item that must be mentioned in a PPA amendment (yes I know it does not have to be amended now)?

Employer X sponsors a cafeteria plan in which employees can elect core medical coverage among other options. Assume that Employee A has elected employee plus two or more health coverage for 2007 because s/he has two children from a prior marriage. During 2007, A acquires domestic partner B. Because there is no additional cost of coverage for adding B, A's health coverage amount does not increase. Assuming that the difference between employee plus one dependent and employee plus two or more dependent coverage is $1,000, how does one calculate the amount A has to include in his/her gross income because of adding B as a dependent? Is there no imputation or does the incremental cost of having at least two dependents get divided pro rata between A's child and B?