austin3515

It doesnt say that which is very disappointing thing. So top-heavy sh match plans really get no benefit. I think that is widely acceptd by the "pension elite" (Watson, Ferenczy, etc). At least I recall they said as much in their articles and webinars.

Now that we have some top-heavy relief and some audit relief that is going to be a much more popular option. Thanks!

Well and of course not all plans are top-heavy, there is that aspect as well. And not all plans have that many people who WOULD be eligble under LTPT rules but NOT eligible under 1,000 hours/12 months. It is those plans in particular that I am advising changes to 500/12 months.

That doesnt work because if someone does not work 500 hours in 6 months, the fall back is required to be 1,000 hours in 12 months. And then guess what? IF they don;t meet that now you have to review for 500 hours in 2 years. So this eligibility is the most bazaar of all becasuse it requires 36 different reviews of eligibility for one person (yes I'm exaggerating a lot but it's a nutty design). I should clarify that I work with a lot of small sponsors. I think the term "small" for these purposes goes up to a couple hundred employees. A straight 1,000 hours in 12 months is a challenge for that market. Adding this level of complexity for those smaller employers is something that I see as critical because I KNOW it was too complex for them to want to deal with it (even if they could handle it). I still haven;t gotten that Amen I was looking for...

First I've heard of anyone pointing that out, thanks!

I think that maybe I was not clear enough. Plan A has eligibility of 1,000 hours in 12 months. The LTPT Rules will be incredibly burdensome to track, particularly since they changed the rules from 3 to 2 years and included complex transition rules. Even if they can track all of that the vesting rules are an additional burden. What I am proposing to clients who want to keep things simple is to just change their eligibility from 1,000 hours in 12 months to 500 hours in 12 months. This avoids all of the insanity in the eligiblity rules created by these new standards. I understand that there are other alternatives, and I understand the top-heavy rules. My quesiton really has to do with the fact that even the most sophisticated clients are going to struggle figuring out who worked 1,000 hours in 12 months, and if not 500 hours in 12 months and 500 hours in a subsequent plan year or 1,000 hours in a plan year after that. It's just too much review to be the least bit practical. So I am talking to clients about changing eligibility to avoid all of that insanity (such as amending eligiblity to be 500 hours in 12 months--which by the way for most employers is barely a change at all since "most" employees are full-time (of course I understand that is not always the case).

The more I read these rules the more convinced I am that the only possible option is to avoid these rules altogether by designing eligiblity rules to avoid exlcuding LTPT Employees. So for example the most simplified approach here will be to change the 1,000 hours in 12 months eligiblity to 500 hours (at least for 401(k)). There are other options, but I am concluding that what is not an option is for a client to try and administer these LTPT rules in the context of a plan with 1,000 hours and 12 months "normal" eligibility. Can I get an Amen?

I just tried the math as you wrote it and it comes out the same way.

The increased catch-up limit is the greater of $10,000 or 150% of the regular limit. The regular limit in 2023 is $7,500 and 150% of even that limit is $11,250. Yet I cannot find a single article that references this contradiction. I realize the $10,000 is indexed for inflation but so is the catch-up limit. The 150% is so far ahead I can't see the $10,000 (even indexed for inflation) will ever be relevant. The lack of commentary on this is so glaring I am starting to wonder if I'm the one missing something?

That rule is limited just to new plans thank goodness. Any plan adopted after 12/29/2022 is subject to the new mandatory auto enrollment but no others (at least for now).

Plan has QACA Match, so changing to SH Match effective 7/1 would be an amendment that increases everyone's match for the whole year. Do we think this is possible? The primary objective is to eliminate the auto enrollment.

That does work, so we'll go with it. Thanks RBG!

I'd say in the last month or so, but yeah using the same link for probably 6 or 7 years. So this one then? We used to be able to start right from the page that has the user name/password inputs... https://eob.asppa-net.org/

LAtely the website i had bookmarked for the EOB login page is not really working anymore. I finf that I have to google it every time, and even when I find a page that works, it seems to be a challenge to actually get to the book itself post-login. Anyone had this problem and no of the best way to get in? Obviously we can call ASPPA too...

Not having a SOC1 in and of itself doesn't mean they cant finish the audit. It just means they can't place any reliance on the recordkeepers controls and have to do more testing. Obviously no one wants to do that, but that's an important distinction in terms of why the client isn;t able to file the audit report. Not to be confused with the fact that I would not finish the audit either (if I was the auditor), I would want to wait for the SOC1 to be finished. If the DOL comes calling, I would not hesitate to throw the recordkeeper under the bus. I agree a traditonal TPA (such as yours truly) doesn't have a SOC1 (we're not doing high volume/systems heavy work). So if they are waiting for a plain vanilla TPA to produce a SOC1 they'll be waiting a long long time! We definitely get asked for our SOC1 all the time so it's a common question.

They did confirm YEDC is in fact Year End Data Collection. Nicely done!

Ahh, that makes sense! Thanks!

Oh so we weren;t the only TPA who couldn;t decipher that ridiculous communicaiton? I'm sorry but I am losing it with those people. We also just confirmed same.

What is YEDC? The first communuicaiton included Relius ASP on affected systems. We're hooting and hollering to try and get a simple answer from them. I will let you know what I hear...

We think Relius is telling us their system will be off line this weekend? Can someone please tell me this is not the case? The timing clearly could not possibly be any worse.

Bracketed/bolded text text is me. This is the text from the reg you cited. Really (3) is what is most relevant. Again, this reg, and the article you cited are not related to my approach, they're about something completely different. (g) Employees of certain governmental or tax-exempt entities (1) Plans covered. For purposes of testing either a section 401(k) plan, or a section 401(m) plan that is provided under the same general arrangement as a section 401(k) plan, an employer may treat as excludable those employees described in paragraphs (g)(2) and (3) of this section. (2) Employees of governmental entities. Employees of governmental entities who are precluded from being eligible employees under a section 401(k) plan by reason of section 401(k)(4)(B)(ii) may be treated as excludable employees if more than 95 percent of the employees of the employer who are not precluded from being eligible employees by reason of section 401(k)(4)(B)(ii) benefit under the plan for the year. (3) Employees of tax-exempt entities. Employees of an organization described in section 403(b)(1)(A)(i) [i.e., a tax exempt 501(c)(3)] who are eligible to make salary reduction contributions under section 403(b) may be treated as excludable with respect to a section 401(k) plan, or a section 401(m) plan that is provided under the same general arrangement as a section 401(k) plan, if - (i) No employee of an organization described in section 403(b)(1)(A)(i) [again this means a 501(c)(3) tax exempt entity] is eligible to participate in such section 401(k) plan or section 401(m) plan; and [This requirement is not met in my scenario. ALL of the employees except for the HCE’s are eligible to participate in the 401(k).] (ii) At least 95 percent of the employees who are neither employees of an organization described in section 403(b)(1)(A)(i) nor employees of a governmental entity who are precluded from being eligible employees under a section 401(k) plan by reason of section 401(k)(4)(B)(ii) are eligible to participate in such section 401(k) plan or section 401(m) plan.

Its mindblowing that there is not more attention. I can't understand it.

First paragraph of the pdf in my link: SUMMARY: This document contains final forms and instructions revisions for the Form 5500 Annual Return/Report of Employee Benefit Plan and Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan effective for plan years beginning on or after January 1, 2023.

Agreed, but from what I heard the AICPA was fighting this hard for obvious reasons.

Yeah me too. A lot of them I know spent years building up and growing their practices. Probably the ones they are not auditing anymore are the least profitable engagements but still, revenue is revenue. If there was a parraellell to the TPA world I would be ripping mad.