david rigby

IRS Reg. §1.411(d)–3(g)(6)(i)) http://ecfr.gpoaccess.gov/cgi/t/text/text-...26/26tab_02.tpl

Carefully read IRS reg. 1.436-1(h).

A few thoughts, in no particular order: - Are you sure no AFTAP certification was issued? (No valuation on October 25 is not the same as no certification.) - If none issued, is any action required to accomplish "full restrictions"? - Participant notification? - If you issue a 2010 certification now, there is no impact on 2010, but what is its impact on 2011?

Did you read the posts and/or the FAB? As stated above, the AFN for the 2008 PY was sent in 2009; the AFN for the 2009 PY was sent in 2010. Etc.

Might help: http://benefitslink.com/boards/index.php?showtopic=45542

It's the earlier of the actual filing date or the due date.

Those disabilty rates look high to me. Might be company or industry specific. You will find some disability tables here (but no turnover tables): http://xtbml.soa.org:8080/xtbml/jsp/index.jsp Perhaps ask the actuary for the complete table?

TH determination is based on accrued benefits (DB) and/or account balances (DC). No imputing of anything. However, don't forget that Key Employee is not the same definition as HCE.

As of this posting, nothing on the IRS website. Last year, IRS news release 2009-94 was dated 10/15/2009. I'm not speculating about any hidden IRS agenda with the (apparent) delay. However, when they do release it, IMHO, we are entitled to an explanation.

You're correct. My booboo.

Based on my own experience, YES. (In years past, I've received a large booklet from a prior employer, coveering about 20 different plans, only 2 of which ever covered me.) For complete analysis, you may wish to review DOL reg. 2520.104.

Apparently, the strikers/rioters are bad at math.

No, the due date for distributing the 2009 AFN for larger plans is/was April 28, 2010.

See Q&A1 in DOL Field Assistance Bulletin 2009-01 http://www.dol.gov/ebsa/regs/fabmain.html

415?

Expanding on Effen's comments: Employee contributions to DB plans are very unusual in the US, except in limited circumstances (such as a plan sponsored by a governemental unit). Make sure you heed Effen's advice about requesting your statement, and don't overlook the SPD.

duplicate posting: http://benefitslink.com/boards/index.php?showtopic=46923

IMHO, not a snowball's chance .....

Good Q. Not sure, but my guess is that the test is based on FICA wages. This Q&A does not address your point exactly: http://ssa-custhelp.ssa.gov/app/answers/detail/a_id/295

Please explain what this is.

this may be the referenced thread: http://benefitslink.com/boards/index.php?showtopic=45522

Success in this conversation might depend on who's doing the talking. If the TPA is having "difficulty" getting the plan sponsor to understand the issue, then perhaps the sponsor will more readily listen to his/her legal counsel.

Indeed. Counting participants is not the same as counting account balances. (This is especially true in a DB plan.)

Are you looking for the line that you don't want to cross? There is no permitted "range". Answer the question to the best of your knowledge. Later, if you discover an error due to imperfect data, then your choices are to (1) amend the filing, or (b) ignore it and get it right the next year. If your participant count is in the thousands, errors are much more likely than a count in the range of 30.

My middle name is "middle". Or maybe it's "muddle".