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AmyO

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Everything posted by AmyO

  1. If this topic already exists, will happily take links (could not find in a few searches)... Employee enters the plan on the 1st of the month; payroll is typically run on the 1st of the month, but when it falls on a weekend or holiday, is paid the business day immediately preceding said weekend/holiday. Is the employee eligible to defer from that payroll? My interpretation is no, since the actual pay date is before their entry date, but open to other interpretations / guidance here! Example: Sally enters Company ABC 401(k) Plan on Sunday, October 1, 2023 Company ABC follows a monthly pay schedule, with payment on the 1st of each month Pay date typically scheduled for October 1, 2023 is instead paid on Friday, September 29th due to the normally scheduled pay date falling on a weekend Is Sally eligible for deferral on the September 29th adjusted pay date, or must she wait for her first monthly payroll actually paid on/after October 1st (in this case Wednesday, November 1, 2023)?
  2. Appreciate that analysis - because we're working on how to implement (with good faith interpretations) I also assumed it was nearly impossible but... could happen. Helpful outline (and I was getting myself stuck on whether or not rule of parity would play a part / whether you'd aggregate periods and having a hard time finding a resource walking through this!). I should also note that some of my old notes around rule of parity, because of the verbiage used, ONLY applies to a participant, so you'd never exclude service if they never entered the plan. That said, I also have an old slide (without notes) from a Bill Grossman presentation with the concept of restarting an ECP after rehire >12 months later... hence me starting with an example with a period of severance and restarting the ECP at rehire.... 🤔
  3. I've been mulling this over, and was thinking of periods of severance potentially causing challenges; but also getting stuck on what the computation period is for LTPT in an elapsed time plan. Help me see what I'm not seeing here 😅 Plan Provisions Age - 21 Service - 12 months elapsed Entry - Semi-annually (Jan/Jul) Employee Example: Age - 27 DOH - February 7, 2023 DOT - August 1, 2023 2023 - Works 501 hours DORH - Aug 10, 2024 -- incurs a period of severance, over 12 months, correct? 2024 - Works 650 hours Original ECP - 2023-02-07 --> 2024-02-06 (no, period of severance does not give credit for 2023-08-02 --> 2024-02-06) Rehire ECP - 2024-08-10 --> 2025-08-09 (assume still employed) Entry date under normal plan rules = 2026-01-01 LTPT: would you look at calendar years 2023, 2024 for entry 2025-01-01?
  4. 10 Yr CMT Rates can be imported from NASDAQ - see the right sidebar (I can't use the Excel add on, I'm on a Mac; but it's working for me to use the API > CSV import to Google Sheets using =IMPORTDATA("https://data.nasdaq.com/api/v3/datasets/FRED/DGS10.csv?api_key=r_sHspCBe6eXM5VoV57h",",","en_US")) Haven't been able to locate an importable mortality table yet...
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