david rigby

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".

Does the DOL determine tax value?

Is there an SSA requirement for the 2009 plan year?

Line 4a of the Schedule H requires an additional table showing the Delinquent Contributions. However, Line 10a on the SF does not require the additional table.

Yes. See DOL reg 2520.104b-1©

While it might be "traditional", it is the prerogative of the plan sponsor. To be precise, the sponsor has always been responsible for choosing the funding method, while the actuary has (until recently) been responsible for choosing the assumptions.

Q1: IMHO, this is a change anticipated by the both the statute and the reg, except that you have a temporary pass. Read both 1.430(h)(2)-1, subsections (e)(1) and (h)(2) and (3).

What does "... or fraction thereof..." mean to you? In my observation, interpolation is nearly universal. Computers have made this task a trivial one.

Prior discussions: http://benefitslink.com/boards/index.php?showtopic=31601 http://benefitslink.com/boards/index.php?showtopic=26083

We celebrate Veteran's Day.

I've learned that my knowledge is often imperfect, so I omit the exclamation points. More importantly, you can gather useful information by a careful search of these Message Boards, often finding that your question has been asked before. For example, http://benefitslink.com/boards/index.php?showtopic=30393 http://benefitslink.com/boards/index.php?showtopic=43403

Not sure the 1099 needs to be "fixed"; it reflects the actual distribution. After the fact, the participant has decided to rollover (whether to IRA or to subsequent employer plan) all or a portion of the original distribution. These are separate transactions. Whatever portion of the orginal amount is not rolled over will (probably) become taxable income. Details of that is the responsibility of the individual, not the subsequent ER or plan. Your questions might be getting pretty close to giving tax advice. Sometimes the best answer is to refer to other sources of information, such as this link to IRS forms and instructions: http://www.irs.gov/app/picklist/list/formsInstructions.html

McKay Hochman's comparison chart: http://www.mhco.com/Library/Articles/2008/...art_103108.html