Audrey

For a calendar-year DB plan, if the employer makes the 2024 plan year contribution after 9/15/2025 (the 8½-month funding deadline) but before 10/15/2025 (the extended tax return due date), does it still count as a 2024 plan-year contribution under IRC §404(a)(6)? My understanding is that it should still be deductible for 2024 and but can't be reported on the 2024 Schedule SB/counted as 2024 funding. Am I interpreting §404(a)(6) correctly?

Thank you so much!

Thank you so much!

hi there, are there any regulations out there which mention all the required deliveries for DB/CB plans? do you normally send out the valuation reports directly to client and do you send out the AFTAP with the valuation reports or government forms, or all 3 things together?

thank you! this plan also counts YOS and avg comp while participation, instead of since DOH.

hi David, the plan has been TH since eff date, e.g. 1/1/2020 the participant was hired in 2021 and became eligible on 1/1/2023. I'm wondering if I should use his YOS (>1000) since hired or entry year. probably I should rely on the plan document but just want to check to see if there is a default language on this. thanks

for TH minimum benefit in DBPP: year of service and avg compensation should be calculated starting from the year of participation right? or both should be counted from year of hire? try to find it on § 1.416-1 but it doesn't show the definition. thanks!

Deferrals/SH: age 21, 2 months, quarterly entry PSC: age 21, 1 YOS, Immediate entry both SH and PSC exclude pre-entry compensation if an employee who became eligible for def/SH on 7/1/2024 with a pre-entry compensation. since he is entitled to SH, then he needs to get GW min. we use 5% GW test method which allows us exclude pre-entry compensation. can I use the SH post entry compensation for GW min calculation in this case? or we have to use full year compensation for GW since the post entry comp is for SH but not PSC? thanks in advance

this is a take over one man plan with BOY val date, I'm wondering if we can change that to EOY val date assuming auto approved

thanks!

good morning, yes, I mean the actuarial/market asset value for an EOY valuation (small plan, so it is the market value without any adjustments), thanks, I think I will include it too, but can't find any guidance

Should Accrued Interest be included in actuarial asset?

much appreciated Effen!

Thank you Bri!!! Will read through today

if a participant had took a couple distributions and would like to increase the benefit formula to reach 415 limit in 2024 1) should we project the distribution amounts from the distribution dates to 12/31/2024 or simply use the actual distribution amounts? 2) do you normally calculate the 415 lump sum (excluding the exiting distributions) first then back in the accrued benefit/ cash balance credit to reach max 415 lump sum? or do you convert the exiting distributions into accrued benefit then subtract it from the 415 limit? do you handle this differently between DB and CB plans? 3) are there any guidance or regs that can answer these questions? thanks in advance!

the eligibility requirements in DC and DB plans are different, so NHCE A is eligible in the DB plan but ineligible in the 401(k) plan. when running combo 401a4 test, do we need to prepare an amendment to bring A into the 401k plan so that he/she will be able to get the GW min in 401(k) plan? OR A is not required to get the gateway minimum as he/she is ineligible in 401(k) plan?

Thanks Lou, when calculating the APR, do you also use 2023 mortality table and post retirement interest rate in this case? or you use 2024 mortality table and pre retirement rate?

for example: calculating a 2024 RMD using the accrued benefit on EOY 2023 valuation (small plan) NRA in plan document is 62 the owner is 74 in 2024 and is active in the plan (still working at the company) when calculating the APR, 1. use 2023 mortality table, and 2. post retirement actuarial equivalent interest rate I'd like to confirm if the 1 and 2 assumptions above are correct, and see if there are any regs about these assumption determinations. another question is if the plan actuarial equivalence mortality table is 94 GAR, do we need to use 94 GAR for all RMD cals or we should use the 2023 mortality table when using the accrued benefit on 2023 valuation? Thanks in advance.

Yes, the excess is not that large and can be fully allocated in 2024. Thank you Kenneth!

if a DBP terminated in 2023 with 4 active employees (2 owners and 2 staffs) in 2023 and the sponsor wants to move the excess asset to the 401k plan to avoid excess tax, however, both staffs (one is HCE, another is NHCE) terminated in 2024, the NHCE needs to get GW so she/he needs to be benefiting in 2024 xtest, what about the HCE? he doesn't have any required contribution (GW or TH). Also, I find the following language from ERISA Outline Book, in this case, he doesn't need to be benefiting in 2024 in order for the 401(k) plan to be qualified as a replacement plan (95% active participants), right? Thank you in advance! 5.a.3) Restrictions on allocations to HCEs. Pursuant to IRC §4980(d)(4)(A), an amount allocated from the suspense account may not result in prohibited discrimination under IRC §401(a)(4). Thus, if the employer restricts allocations to HCEs who were active participants in the terminated defined benefit plan, such restrictions will not cause the plan to fail to satisfy the 95% requirement described in 5.a. above. See PLR 201147032 and PLR 201221059.

Thank you Kenneth!

if a plan has been frozen from 1/1/2024 (both accrual and participation are frozen), a participant met all eligibility requirements and should enter the plan on 1/1/2024 if the plan is not frozen. we don't need to test 401a26 test due to SECURE act 401a26 relief; there is no accrual so no 410(b) test. but I'm just curious - in this case, should he/she be included in non-discrimination testing due to meeting all eligibility requirements? or he/she should not be included in tests due to 1/1/2024 freeze date? thanks!

Thank you so much again Corey! have a great weekend!

an EOY valuation small plan, the plan sponsor made the contributions throughout the plan year and nothing else was made after the plan year. I will need to project the contributions as of the valuation date 12/31/2023 then subtract these amounts from EOY asset value as the market value in the valuation. but in AFTAP calculation, I just use the EOY asset value without project the contributions, am I right? are there any regulations specifically mention these? thanks!

thanks Bri!