Before Vanguard exited its “Individual 401(k)” business, Vanguard sent a customer a “beneficiary verification” that included this information:

Beneficiary                  To the person I am married to at the time of my death

Backup Beneficiary     Benjamin Brother 50% / Roberta Relativebyaffinity 50%

Here’s what I don’t know:

Could the lingo “To the person I am married to at the time of my death” have resulted from Vanguard recording exactly what the participant typed in the website?

Or had a participant tried to type in that phrase, would Vanguard’s system have rejected the entry because it was too many characters or because it seemed not to be a name?

Did Vanguard set up that lingo as a programmed choice a user could click on?

Did Vanguard set up that lingo as a plug-in for a situation in which the participant declined to name a beneficiary and Vanguard’s records about a participant showed the participant as having a spouse?

In the circumstances I’m advising about, whether “To the person I am married to at the time of my death” resulted from the participant’s considered writing (which might be plausible because the participant had filed a divorce petition, and was lawyer-advised), or partly or wholly because of something Vanguard set up might matter in how the retirement plan’s administrator interprets the participant’s “backup” or contingent beneficiary designation.

BenefitsLink neighbors, thank you for your gracious help.

I'm curious to know the names of third-party administrators or recordkeepers who provide service to and have access to a non-ERISA governmental plan document that is keyed to Tribally relevant tax code and regulatory matters? Any help would be appreciated. Google doesn't give me enough to work with.

 

Best

for UFCW Local 1262 and Employers Fund Office (Clifton NJ)

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An employer has a § 403(b) plan, elective deferrals only, with only TIAA-CREF.

The employer is considering a different provider for ongoing § 403(b) elective deferrals.

The employer assumes it lacks power to remove assets from TIAA-CREF. Even if it might have some such power, the employer would be reluctant to interfere with an individual’s choice to continue with TIAA or CREF for previously accumulated assets.

If it matters, this governmental plan cannot be ERISA-governed, no matter what provisions or restrictions the employer might set.

If an individual considers rollovers, if 59½, or § 403(b) transfers from TIAA or CREF to the new provider:

What exit expenses will that bear?

Is there a lock-up on all or some of the TIAA credited-interest contracts?

What else should an adviser to this employer or its participants tell them to worry about?

for The MandMarblestone Group, llc (Remote)

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Based on documents from several different plans, I've operated under the assumption that a participant's non-defaulted loans from a DC plan reduce the vested portion of a total account balance, even though they do not reduce the overall total account balance for other purposes, such as for calculations of assignments to alternate payees (except where the loans would limit the assignable amount), because non-defaulted loans are considered assets of an account, even if they reduce the vested portion. Am I wrong, or do different plans handle this in different ways?

	ADP	ACP
NHCEs	4.51%	1.21%
HCEs	6.06%	2.55%

for NPPG (Shrewsbury NJ)

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For those of you working with 401(k), 403(b), profit sharing, safe harbor, or cash balance/DC combo plans, where do your current systems still make things harder than they need to be?

A few areas I’ve been wondering about:

• Census cleanup and eligibility issues
• ADP/ACP or coverage testing edge cases
• SECURE 2.0 implementation
• Roth catch-up readiness
• LTPT tracking
• Payroll / recordkeeper data issues
• Contribution timing review
• Plan document provisions not lining up cleanly with system logic
• 5500 / plan-year workflow bottlenecks
• Client communication around exceptions and corrections

I’m not trying to bash any vendors or software. I’m genuinely trying to understand where experienced administrators still have to rely on judgment, spreadsheets, workarounds, or just knowing how things really work because the system does not quite handle the real-world mess.

Where do you think better software would actually save meaningful time or reduce risk?

for Compass (Remote / Stratham NH / Hybrid)

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for The Retirement Advantage, Inc. (Remote)

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for The Retirement Advantage, Inc. (Remote)

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for EGPS (a Blue Ridge Company) (Remote / Baxter MN)

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for EGPS (a Blue Ridge Company) (Remote / Baxter MN)

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for Associated Pension Consultants, a Prime Pensions Company (Remote / Chico CA)

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A fiduciary assembling an ERISA rule 404a-5 disclosure to participants and other investment-directing persons plans to use a “Sample Glossary Of Investment-Related Terms For Disclosures To Retirement Plan Participants” collected by The SPARK Institute, Inc. and other trade associations and related charities.

The document the fiduciary has is labeled “Version 1.01 April 26, 2012”.

A visit to https://www.sparkinstitute.org/resources/best-practices-industry-standards/ shows that 2012 version.

But is that first version still the current version?

If not, what is the current version?

BenefitsLink neighbors, thank you for your gracious help.

I know I've seen this discussed before, but I'm not finding it...

401k plan with SHNEC and profit sharing.  The partners have their valid deferral elections in place by 12/31/25 to both do the max.  We sent a contribution report telling them to deposit the SHNEC and PS and also the deferrals for the partners before the due date of the tax return... and they forgot to do the deferral part.  2025 taxes are filed.

What recourse is there for the partners at this point?  I thought I remembered that it was treated like a missed deferral opportunity for them?  Appreciate anyone pointing me to where this is covered.  Thanks!

 

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.