BG5150

I've never reported them, but I never understood why. I started a thread many years ago here, but I don't remember any resolution to it. My theory was that the funds belong to the plan. If they are used for fees, so be it--plan funds were used to pay fees. If not, then it got allocated to the participants as earnings. Still a plan asset. Maybe it's not considered earnings until it's actually allocated, like a dividend? Dividends are declared ahead of time, but are not considered plan assets until they are actually allocated...

Not true. It's semantics, but from: RC 416(g)(4)(H). Note, a plan funded by only SH contribs, the plan is NOT Top Heavy. Doesn't matter if the TH% is 5% or 99%. Plan is not top heavy. So, the 3% SH (or match) doesn't satisfy the TH contribution if it is the sole ER funding. The plan is not considered TH in that case; there is nothing to correct.

So, if I have 5 yrs of service on a 3-yr cliff schedule, I'm 100% vested. If my employer wants to change to a 6-yr graded, my old money (obviously) stays at 100% vested, but also all my future contributions? (I've been fortunate to only have done vesting amendments a handful of times in my career, and they have all been a liberalization of the schedule.

You are paid hourly? I would think that is more the exception than the rule in our little world.

That applies to the accrued benefit. You can make it more restrictive going forward. You would just have to record-keep two buckets for each vestable money type. At least that's the way I've always seen it.

Put the additional match in a bank account in the plan's name (under the trust id #). When the plan comes out of blackout, put the funds in participant accounts and adjust for earnings. Check the 415 rules for when the contribution will be considered an annual addition for the participant. I'm not sure if it would be 2020 (when the funds left the ER and put into the adjunct trust, or bank, account) or 2021 when they actually gets invested in the accounts. Really only relevant if anyone is close to maxing their 415.

I wanna work where you work. 50 plans is 4 a month, one a week. I could handle that!

How do you react/respond to a client's request for their current plan docs (AA, BPD, SPD, etc)? I find in way too many cases, soon after I supply the requested material, I get a letter saying the client thanks us for our service, but they are making a change. Why should I facilitate that? I know that's not the case will everyone who requests them, but I also want to shout into the phone: YOU SHOULD HAVE ALL THIS. IN FACT YOU MUST. How do you admonish the client for not having these doc without sounding like a jerk?

That all depends on the support the administrator gets from the company. If there is a good tracking system in place and good management overseeing it, then it will remove some of the burden. If the data collection requests are largely sent out and collect by support staff, that reduces some of the work. Is there staff to handle the approval of distribution requests? Billing? Someone preparing docs and amendments? I've been in places that had a lot of support, so I could manage my caseload a lot better and even be somewhat proactive with my clients rather than being merely reactive. I've also been in places where the admins were similar to independent workers, getting a caseload and being responsible for everything, including sending out YE requests and followups, approving distribution requests, preparing docs and amendments, PS illustrations, testing. Everything. With only a modicum of oversight. I don't think keeping everyone at a static level of cases despite complexity. A small plan with brokerage accounts and a less-than-knowledgeable employer can take up more time during the year than some large plan filers at a good carrier. The TPA needs to balance that across its admins. Otherwise you can foster resentment. "How come I get all the difficult plans, whilst Lisa only gets the 10-person John Hancock plans? I'm working until 6 every night while she goes home at 4:30..."

No owners?

How old is that phone forum? 7-8 years? In that time has any audit or investigation ever have a problem with prime +1 or even prime? I'm sure we would have heard it through the grapevine somehow.

That I don't know. EPCRS has the 415 corrections.

People have been using prime +1 without consequence (that I know of) for years now.

Yep

Is it a 5500 or 5500-SF? Then, yeah. As long as it's readable.

If you use one, what type of workflow tracking software do you use to manage your firm's caseload? Pension Pro? Pension Pal? Other software? In-house database/spreadsheet? We are looking to alternatives to what we do now. I've used Pension Pro, and it may be too robust for us. I'm not sure if there is a scaled-down version, but at the one company I worked for that used it, it seemed a bit complicated with all the task assigning and stuff...

Seems like deferrals are already effective in the plan. I thought for plans like that, SH had to be for the entire year. And for plans with no deferrals yet, you can add a SH, but it has to be for at least 3 months.

Too late for 2020...

Plan is termed a/o 9/30. In process of paying out accounts. Hope to get this done by 12/31 for obvious reasons. Tracking down former employees, get in touch with one of them. She tells me she is getting a divorce. Normally, flag goes up, put hold on account and wait for DRO. Is that the same thing here? Can a divorce hold up a plan termination? Or, at least, hold it up for this one person?

I had a brain fart. I was just discussing with a co-worker about a client who is an employee of a company and he has his own plan (un-related). So he has two 415 limits.

Doesn't each plan have its own 415 limit?

Also, what happened in the years before? You have to start at the beginning. You track sets of deferrals (Jan to Sep and Oct to Dec) and just draw a chart showing where the deferrals overlap between calendar and plan years.

I'm not saying you are correct, BUT if the $4,755 is 2019's catch-up, then there is a way to treat it that way in your record keeping software. There is probably a field where you can enter various years' catch-ups. Talk to their support.

I wouldn't be comfortable paying any benefits other than by check unless the participant consented. I think the best way to do this is the way someone mentioned: Hey, pal, you already paid taxes, or you will if you did not include that 1099-R in your tax return. So you might as well cash the stinkin' thing.

Is it a safe harbor plan?