Audrey

Thank you so much for the details!!!

the PSC requires last day and 1000 hours if the plan has 3% SHNEC, then for those participants who worked less than 1000 hours or terminated in the plan year will need to get PSC to meet gateway regardless PSC allocation conditions. how about SHM? SHM is not included in gateway test, but if a participant made deferrals and is entitled to SHM but didn't meet PSC allocation conditions. then is he/she required to get PSC to meet gateway minimum or he/she doesn't need to be tested on gateway test? thanks!

Thank you David!

thank you so much Corey!

hi Corey, thank you so much for these info! for distributions - for example, the distribution date is 7/15/2024, if the stability period is the plan year with 1st month lookback, then stability period is 2024 plan year and the applicable month is December 2023; if the stability period is calendar month with 1st month lookback, then stability period is July 2024 and the applicable month is June 2024. Am I understanding these correctly?

the stability period always starts on 1/1 for 417(e) purpose and it starts on the valuation date for funding assumption purpose. am I understanding it correctly? tried to find the regulation about the definition but can't find the specific definition of the start date.

hi there, if we are using the accrued to date method, is there any regulation mentioning which avg comp we should use? i.e. highest 3/highest 5 or the avg comp throughout the entire participation period?

EOY valuation plan, if we use $1k PFB to offset MRC for 2023 plan year (line 35 on SB), should I reflect that in AFTAP/FTAP calculation by reducing $1k PFB? and also override SB line 14? I think so but can't find an official guidance on this.

hi Andy, what if the participant didn't terminate, so is his accrued benefit still be limited/capped by the 415 limit at the time of frozen? or he can get the increase as he is still employed? thanks!

Thank you both!

deferral and SH have 1 YOS requirement, and PSC has 2 YOS. a participant is eligible for deferral/SHNEC but ineligible for PSC. should he be included in gateway test and get gateway minimum as he is benefiting SHNEC (an ER contrib)? thanks!

hi there, if there are 10 non-Keys benefiting in both plans; 3 of them are getting 2% in DBCB side, and 7 of them are having less than 2% in DBCB. do we need to allocate 5% in DC plans for all non-keys together? or we only need to allocate 5% in DC for the 7 non-Keys? i.e. does the TH allocation method have to be consistent for all non-Keys or it can be determined individually? Thank you so much!

a plan is frozen in 2022 - both accrual & participation are frozen, and the plan is not underfunded - not qualified for 401a26 exemption at the same time, there are some employee meet the eligibility requirements before the valuation date which means they are eligible to enter the plan if the participation is not frozen in this case, should these employees be counted as non-excludable employees in 401(a)(26) (ignoring the minimum participation relief in SECURE Act)? appreciate all replies and helps.