Calavera

With the range certification by 9/30, the actual AFTAP needs to be certified by 12/31. Don't even need to certify 100% or higher, the range certification of 80% or higher should be sufficient.

For the EOY val you need to use actual net earnings, so if benefits are defined as a percentage of current compensation, someone would need to correct it. Just some suggestions: 1. Confirm how benefits are defined and go from there. For a DB plan it may be a percentage of an average compensation. For a CB plan it may be an amount specified in the plan document without referring to any compensation. 2. Ask prior actuary if it was assumed that both companies adopted the plan or ask him to justify compensations used for calculations. 3. See if you can get copies of all Schedule SBs and copies of tax forms to compare earnings and deductions. Or just tell this prospect to find another TPA, since you are not interested in this case

See if you can change any assumptions to at least reduce the 2024 minimum required contribution.

Is it beginning of the year valuation?

Just a reminder that 110% is calculated after the payment and the target liability could be used for the ratio. So, when majority of benefits belong to the retiree, it's usually not too hard to overfund the remaining target liability by 10%.

I vote that 110% rule still applies.

On a contrary, I would never say that this person enters on 10/1. I believe this question was discussed multiple times over many years, and people always had different opinions. Some from this board even changed their opinions over time. I am not aware of any official cites covering this question. The only article I found support entrance on 1/1/2025 in this case - https://williamskeepers.com/retirement-plan-deficiencies-a-look-at-the-most-common-mistakes-part-2/ And this is what Google's AI said: The entry date, coinciding with and next following one year from your hire date of 1/2/2021, is 1/2/2022. Explanation: The question specifies that the entry date is one year after the hire date. A year from 1/2/2021 is 1/2/2022. The phrase "coinciding with and next following" means the entry date is either exactly one year from the hire date or the first date after that which is designated as an entry date. Since you were hired on the 2nd of January, one year from that date is also the 2nd of January. Therefore, the entry date is 1/2/2022.

I would disagree with this. Callie completed one year of service at 1st second of 1/2/2023 and therefore cannot enter on 1/1/2023

I would also suggest recommending in writing to refile 2024 taxes, since that contribution was not deductible in 2024, just to have it on record, so you wouldn't be blamed later.

I assume it is a standard DB plan and not a cash balance plan, so I don't think amending the interest rate would affect the offset calculations at all. But if plan already terminated or deep in the process, I agree it may be not wise to amend. Method suggested by Lou S. looks very reasonable and defendable in case of any audits.

I like this approach You can amend the lump sum interest rates bringing payout up to 415 limit.

Not really. Depending on the vested service definition under plan document this person will either have 2 years of vesting service or 1.91667 years of vesting service.

I would disagree. The participant doesn't need to be employed on the anniversary date to receive vesting credit. Under elapsed time rules this participant will receive either 9 or 8 months of vesting service depending on the definition of vesting service. Some plans give 1 month for 1 day of work.

For a shared interest QDRO, AP is usually the beneficiary on the portion of benefits that are subject to a QDRO. You have one J&S factor and one coverture fraction. Result should be the same. What am I missing?

If a 3-year average W2 compensations was established already, you may not need any current compensation for a defined benefit plan. However, you may need a reasonable compensation paid for services, but this is the question to an accountant/tax advisor.

The goal of a QDRO in a defined benefit plan is to provide an Alternate Payee (AP) a portion of participant's benefit for AP's life. In a case of a Shared Interest QDRO, an Alternate Payee is assigned a portion of participant's benefit over participant's life. To ensure that the Alternate Payee will actually be receiving some benefits until he/she dies, the Shared Interest QDRO is forcing a participant to elect a J&S benefit, so upon participant's death, the shared portion payable to AP will stop, and J&S portion will start. However, this requirement applies only, and I am using words from your QDRO, "to the extent of the calculated interest". Here is a simple example: The total benefit is $1,000 per month under 50% J&S. Marital portion of this benefit is $600 per month. AP is assigned 50% of the marital portion under the shared interest QDRO. Essentially it means that you are "receiving" $600 and "sharing" it with your ex 50/50 (each receives $300). When you die, you stopped receiving $600 and there is nothing to share anymore. The 50% J&S provision kicks in where AP receives 50% of the total benefit of $600, i.e. AP continues to receive the same $300, she was receiving before you died. Furthermore, the remaining $400 are not part of the marital portion, and you should be able to elect any other beneficiary for this benefit. However, if your marital portion is 100% of your total benefits, I think there is nothing you can do to change it, unless you will be able to completely nullify the existent Shared Interest QDRO and create new Separate Interest QDRO. Your pension department should split your total benefit to "marital" benefit and "non-marital" benefit in regard to your ex and treat these separately. The "marital" benefit will be subject to the QDRO, and "non-marital" benefit will be subject to your election.

It sounds like this is a defined benefit plan, it was a Shared Interest QDRO, and neither you nor your ex started receiving benefits yet. If I am correct in these three assumptions, you cannot change the beneficiary for the portion of benefits subject to the QDRO, unless it is possible somehow to nullify the old QDRO and create a new Separate Interest QDRO upon agreement between you and your ex. However, if only portion of your benefits (<100%) were subject to a Shared Interest QDRO, you can elect your current spouse to be a beneficiary for the remaining benefits.

First you take into consideration whether you have a short plan year or a 12 month plan year. Then you look at the benefit formula and employment/participation history. See CuseFan's comments above. If you have a short plan year or if you have a benefit formula that using monthly compensations, you prorate. If you have a full plan year, and you have a benefit formula that is not using monthly compensation, you don't prorate.

I believe if your plan's benefit formula using 36 months and not 3 years, you have to apply a monthly limit to a month of compensation, essentially applying the proration.

Elapsed time means elapsed time. This person will have 1 year and 7 months of vesting service.

Scan 2023 signed SB with all 2023 attachments in one pdf file and attach it as "Other".

Usually having just PS/401k plan at that age is easier and comparable if the current compensation is high enough due to very low 415 benefits at the age of retirement. However, from the legal plan setting up perspective I would recommend NRA 62, ERA 55, benefits unreduced at ERA, expected retirement age for valuation and contribution purposes is whatever clients tell you.

Just file the amended 5500 ASAP attaching the auditor's report. From Form 5500 instruction – “If the required IQPA’s report is not attached to the Form 5500, the filing is subject to rejection as incomplete and penalties may be assessed.“ From DOL EFAST FAQ – “Q25: Will EFAST2 receive my filing if I do not attach the IQPA report to my Form 5500 annual return/report? EFAST2 will receive your filing, but the filing is incomplete without the required IQPA report. An incomplete filing may be subject to further review, correspondence, rejection, and civil penalties. Please note Schedule H, line 3 specifically asks for information regarding the plan’s IQPA report. If you do not submit the required IQPA report, you must still correctly answer these questions. If you have to file Form 5500 without the required IQPA report, correct that error as soon as possible.”

I think for the Line 14 (FTAP) the PFB used to offset MRC should not have any impact. The 5500 Schedule SB instruction doesn't mention any adjustments, and it seems pretty clear. However, for the Line 15 (AFTAP), I would take it into consideration.

The terms “shared interest” and “separate interest” are used a lot in DROs for splitting benefits earned under defined benefit plans but could also apply to defined contribution plans as well. Attorney should be able to help you to answer questions and to draft a DRO. You can find more information here: Qualified Domestic Relations Orders and PBGC | Pension Benefit Guaranty Corporation QDROs The Division of Retirement Benefits Through Qualified Domestic Relations Orders 2020 (dol.gov) FAQs about Qualified Domestic Relations Orders (dol.gov) FAQs Drafting Qualified Domestic Relations Orders (dol.gov)