BG5150
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Everything posted by BG5150
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SHNEC deposit for 2017 plan year not made until now
BG5150 replied to MarZDoates's topic in 401(k) Plans
They are also annual additions for 415 purposes for 2018 as well, I think. -
Hopefully, it's the owners AND some NHCE's who will make after-tax contributions...
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Purchase house in 401(k)
BG5150 replied to Cheryl S's topic in Investment Issues (Including Self-Directed)
Tell them you think its a bad idea b/c of some of the ideas above, and that they should consult an ERISA attorney for a final determination. -
Maybe. But, again, I've yet to hear about an auditor question +1. Side question: what is the penalty for having loan rates too high or too low? Is it a prohibited transaction? Some sort of fiduciary breach? What would the remedy be?
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The interest rate is supposed to be commensurate with a rate that would be charged by a local (regoinal?) bank for a similar loan. In some places of the country, the cost of borrowing may be higher or lower. But instead of calling around to banks in the area, ERs have been using the prime rate +1 or +2 as a shortcut. The IRS said in a phone forum a bunch or years back, that prime +1 may be too low and that +2 is better. Anecdotally, I have not heard of any auditor questioning +1, so many people go with that. We use prime +2.
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Call it the Stable Value Fund Investment Account. Or the SVFIA.
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These guys really love splitting hairs!
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I would say reasonable classification applies to prevailing wage. It is clearly stated who gets it, it is a bona fide business reason and there is no employer discretion.
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If "everyone" get a prevailing wage contribution, how could coverage fail?
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I was asking more towards in any situation. Someone said once the IRS starts leveling penalties it's too late for DFVC. But is it too late to stop DoL sanctions?
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Could you call it Stable Value Investment?
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Something to keep in mind: SH can be allocated on comp while a participant, so first year entrants may only get 3% of partial year pay. If there is a TH minimum due, they must get 3% of full year pay. Another thing, it's not only PS that blows it up. Discretionary match that is not ACP SH complaint or even reallocation of forfeitures will drop the SH protection of TH.
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Would it help remove any future DoL penalties?
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Is this a Schedule H 5500? Or Schedule I? SF? In any case I would just put it on the 'Other Income' line. Who cares if it's a negative. It certainly is NOT a benefit payment. Was a 1099-R issued? (If so, I think it should not have been).
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Tom, Can you resend the spreadsheet to me? I've changed jobs and the file stayed at my old job.
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And talk to them about the Top Heavy rules, too, and how they are not needed any more...
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Call your Congressman.
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Gap period earnings for 415 excesses
BG5150 replied to BG5150's topic in Retirement Plans in General
Never mind. 415 corrected under EPCRS. Earnings thru date of distribution. /thread -
(When) Did gap period earnings get removed for 415 excesses? If so, when?
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A plan terminates in 2016 and funds were distributed. Company opens new plan for 2018. Are those plan distributions added back in as in-service withdrawals for 5 years?
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It may or may not be material, but if you are using the software to calculate your coverage testing it will be off by 1 non-benefiting employee.
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PS allocation compensation for the last 2 years...
BG5150 replied to Karoline Curran's topic in 401(k) Plans
My compliance department? Where do I send the invoice? ;) -
They are counted as eligible but not benefiting for coverage. If they are HCE doctors, then that's probably good.
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Non-key HCEs must still get TH.
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PS allocation compensation for the last 2 years...
BG5150 replied to Karoline Curran's topic in 401(k) Plans
If you are going to try to correct under EPCRS, there are precious few things you can remedy with a retroactive amendment.
