austin3515

And to follow through one inch further, a plan with no Roth 401k option does not have any Designated Roth Accounts. Also, in this situation it appears to clearly be a rollover and not a transfer because the plan terminated prior to the acquisition.

What QDROPhile said, which says 50% of the missed deferrals (i.e., if he elected 6%, the correction is 3%) plus 100% of the missed match. So if the match is 50% of this first 6, match correction is 3%.

From 1563(a) a) Controlled group of corporations For purposes of this part, the term “controlled group of corporations” means any group of— (1) Parent-subsidiary controlled group One or more chains of corporations connected through stock ownership with a common parent corporation if— (A) stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote or at least 80 percent of the total value of shares of all classes of stock of each of the corporations, except the common parent corporation, is owned (within the meaning of subsection (d)(1)) by one or more of the other corporations; and

First of all, there is no bigger proponent of vlookup than me. I should be paid a commission for how I tout vlookup. And lest you get the impression that I am technology averse, I can assure you that we've embraced technology (whether through Access databases, custom crystal reports, etc) to the extent that promotes efficiency and accuracy, and is not a hindrance to them. That is the guide I rely on. And ESOP Guy, it is the very moment you stop checking that you end up regretting it. And formula errors do happen. I use a "trust but verify" approach (Reagan, right?) Automate through vlookup, but then spend a moment making sure the vlookup worked correctly (usually can be done in Excel). Here is my dilemma. It seems to me that some sort of occupational consulting group would have actually sat down and asked the question: Are people able to achieve the same levels of accuracy and review on a monitor as opposed to paper? The latter affords the opportunity to write a quick note, document checks back and forth. It seems to me that with everyone jumping on board the USS Paperless someone would have done this "obvious" analysis. Example. I can't tell you how many times I've writte a letter in word, read it through 10 times over, agonized over every word, print it out, and realize that I forgot to change the client's name under "Dear Steve" (having only changed the address). That's the kind of thing I'm talking about. It hits you in the face on paper.

Bingo, that's the question. Especially when it is a wholly owned sub.

Boxes 12-17 are for state taxes. If there is no withholding are others just leaving these boxes blank?

Wholly owned sub started taking 401k contributions for remittance starting in 2015. Am I correct that this could be considered a discretionary amendment that can be signed by the end of the plan year (12/31/15)? If anyone has something on point, such an ASPPA Q&A, that would be awesome... It seems to me like this is one of the grayest areas I can think of. Is it even an amendment? I say yes because it is expanding the scope of eligible employees. No different than amending to include Division A in the Plan.

Any basis for treating as a discretionary amendment, giving until the last day of the Plan YEar for execution?

Have you guys found it challenging to review the work of other people? We talk about it, but this is my big dilemma. There is just so much I see flipping from this to that report. Looking for HCE's, comparing lists back and forth, etc. Will I notice on screen that no THM was provided? This is my big struggle. I love technology but I'm concerned that the review process will suffer...

Every now and again we talk about going paperless. My issue has always been that when reviewing people's work, printing it out on paper has OFTEN manifested errors that I never would have caught in a paperless environment. Take for example reviewing HCE's. I have last year's census on my desk and the ADP test on my desk. I check back and forth, running fingers from person to person, or perhaps using roller going down a page, putting checkmarks on those I have reviewed, to ensure that everyone on both lists is accounted for. How is that possible in a paperless environment?

So Bird... If we had 1,000 hours and last day rule in profit sharing and elect the 5% THM in DC Plan. Someone terminates in November after working 1,000 hours, you would expect that the basic plan document's top-heavy rules should override the last day rule in the same way that the top-heavy rules override the 1,000 hour rule in a DC only arrangement? That would seem hyper-logical, but for some reason that's never the answer I get from any actuaries. I actually did not get that answer from Corbel either.

I swear someone could have a two hour training or more just on THM in DB/DC Combos. Has anyone seen one from ASPPA or something like that? I'm reading what you're writing and I get it, but then I ask well "what about_____" and my head just starts to swim.

I work for a TPA that outsources our actuarial work to another company. Can someone please explain to me the best way to ensure that terminated people with more than 1,000 hours get the 5% THM and ONLY the THM in a DC Plan. We've been told that we need to get rid of the last day rule. So that's what we did. But now we have a plan where we're doing a 6% total allocation, and I'm stuck giving the extra 1% to a term. Shouldn't our document automatically give the 5% THM even though there is a last day rule, because in the document I specified that the THM wll be provided in the DC Plan? We use the Corbel VS formatted Prototype.

I'm drafting the Plan...

Nonqualified Deferred Comp (perhaps you didn't notice which forum this is ).

Thanks Tom, I'd like to think I would have thought of that if my plan was top-heavy but fortunately the TH %age is zero so far! And the Plan is a 3% SHNEC. Thanks guys!

Benefit in the Plan is a discretionary contribution each year, payable in 15 years. The amounts re not going to be separately invested in a brokerage account. The benefit is essentially tracked on a spreadsheet. Do I HAVE to pay interest? There is a rolling vesting schedule, so I think it is unfair that the participant will be paying payroll taxes on amounts that vest without even receiving the benefit of interest, but ultimately that is not up to me. I just need to know if it is possible to credit no interest.

No good meaning I just have to run the ACP test, correct? Of course such a cap usually means the test will pass (as is the case in my situation). It's just a question of whether or not I need to run it,.

I am thinking applying a $2,500 cap on a "100% of the first 4%" match would blow the ACP Safe Harbor because it is possible that an HCE who terminates early in the year might have ALL of his/her 401k matched, whereas other NHCE's might be subject to the cap. Also, an HCE deferring say 1% might have 100% of his/her contributions matched whereas again the NHCE could have less. Note that the reg below merely talks about the ratio of match to deferrals with no exceptions. Everyone agree? Seems strange as this sort of provision obviously disproportionately (although not exclusively) affects HCE's. From 1.401(m)-3 (4) Limitation on rate of match. A plan meets the requirements of this section only if the ratio of matching contributions on behalf of an HCE to that HCE's elective deferrals or employee contributions (or the sum of elective deferrals and employee contributions) for that plan year is no greater than the ratio of matching contributions to elective deferrals or employee contributions (or the sum of elective deferrals and employee contributions) that would apply with respect to any NHCE for whom the elective deferrals or employee contributions (or the sum of elective deferrals and employee contributions) are the same percentage of safe harbor compensation.

What bearing does a rating regarding their ability to pay claims when due have to do with the quality of the investments that they manage? You're referring to Moodys and S&P, etc., correct?

Well, couldn't; they advise participants to leave the investment and/or transfer their old accounts to the new "fiduciary friendly" contract?

Sorry... I had enough qualms about even posting the name! It's not my document. Scary thing is that I don't think there is anyway to stop it. Anyone with a Larkspur account can pull enough information to make labels for a good chunk of your clients and tell them whatever they want...

Revenge was on my list of possible motives

Has anyone ever heard of this company before? They sent out what appears to be a mass mailing to the clients of a particular large TPA (not us!) making all sorts of accusations and recommending that they fire the offending TPA forthwith. Believe me, the accusations are not scandalous. My 2nd or 3rd thought was "scam?". But there is zero contact information on the letter (it merely lists the county and state as Camden County New Jersey). It does not request any information nor response. And here is the kicker - they cc'ed (at least according to the letter) 6 or 7 different field offices of both the IRS and the DOL. I googled the company but found nothing. We're going to forward the letter as a courtesy to the named TPA (a firm that we "know of").

Got a TIAA client and we are restating their document onto ours. TIAA's plans say "are loans allowed - yes or no." What I am wondering is, do I need a separate loan program, or do the TIAA contracts incorporate the true loan program? I am also told by TIAA that each individual promissory note includes all of the provisions regarding default, payment terms, etc. Additionally, the loan is actually with TIAA-CREF and merely collaterized by their account balance in the TIAA Traditional account, and I'm quite sure that any loan program would have to describe all of this. So what are people doing who work with TIAA with respect to a loan program? We're using Corbel's PT Formatted 403b document.