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PensionNewbee

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  1. any suggested language out there?
  2. Can a 403(b) that is not subject to ERISA in operation - meaning it meets all of the requirements - limited employer involvment, no employer contributions, etc. but which has a document that subjects it to ERISA claim NOT to be an ERISA plan?
  3. Very helpful, thanks!
  4. Are plans established by charitable aid societies considered church plans?
  5. I'm actually looking for something internally created by a TPA - for quality control purposes. There are so many details to keep track of while working on a plan a checklist would be really helpful to me
  6. Does anyone have a checklist for defined contribution plan administration that is complete but concise (I hate checklists that are longer than the report I prepare) that you are willing to share?
  7. well, it SHOULD, but, since it is a PLR and not a Rev. Rul., does it carry the same weight, or can it be narrowly applied to just the instance discussed in the PLR?
  8. What's the difference between the new sidecar IRA provisions and the old QVECs?
  9. I'm fairly new to the conversion process, but I have seen the new investment company pay a % of the deferred sales charge and allocate that to each participant's account to help make up for the loss created by transferring the assets.
  10. I'm fairly new to the whole conversion process - fairly new to the pension industry in general. I work for a small TPA in the midwest, and I was wondering what other TPAs do as far as "conversion work" is it normal for the TPA to be involved in the transfer of assets? By that I mean is it normal for the TPA to tell the new service provider how to break out the assets to be allocated to participants' accounts? Does that have any bearing on fiduciary issues? I've seen a couple conversions where the asset providers do all the work, including breaking out the assets to be allocated to participants' accounts, and then I've been involved in a conversion where I've had to break out the assets and show the new asset provider how to allocate the funds. Is there a standard way to do a conversion properly?
  11. This is a takeover plan, with an after-tax source, as well as a related rollover source (old DB $). at the previous provider, the assets were rolled into a new investment product without preserving the separate sources - now, instead of deferral, profit sharing, rollover and after tax, there are two sources - employee and employer. In order to properly account for the assets, the sources should be split out, but the rollover to the new investment product happened about 2, maybe three years ago and when the assets were converted to the new provider, a participant (also the CEO) noticed that something was wrong with his account. Any suggestions?
  12. thanks Tom! This helps a LOT! So, to summarize, anyone who is a more than 5% owner is an HCE regardless of compensation, and they won't get knocked out of the box by applying the top paid group election, since that's based on compensation, not ownership. And it says this in 1.414(q)-1T ??
  13. not just the rounding, but the whole concept - that a 5% owner with comp less than the HCE limit is still an HCE even if the top paid group election is made... where can I find the regs online?
  14. OK, just in case I have to fight against raging skepticism, where can I find this information written down? Code/Regs/Tripodi?
  15. Someone told me that I didn't have to include 5% owners in the top paid group if their compensation would knock them out of the group, but as I understand what I'm being told here, there are actually two tests to determine HCEs - the ownership test AND the compensation test. I know that >5% owners are always HCEs, but the person had me almost persuaded that the top paid group election trumped that. So, for small groups, it won't always help to invoke the top paid group. I guess that about sums it up.
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