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Everything posted by david rigby
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Proposed 415 Regs
david rigby replied to JAY21's topic in Defined Benefit Plans, Including Cash Balance
Huh? If the accrued benefit is zero at BOY, but not at EOY, how does this give you "no funding"? Have I misunderstood your post? -
Earlier related discussion http://benefitslink.com/boards/index.php?showtopic=28656
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Special Benefits (discounts to employees).
david rigby replied to a topic in Miscellaneous Kinds of Benefits
If your employees are geographically close, organizations such as health clubs, may be willing to offer "group rates". -
One Year Term Cost For Envelope Funding
david rigby replied to a topic in Defined Benefit Plans, Including Cash Balance
Although this is not my usual type of client, I thought the term cost is just that, the cost. Determine all liabilities; determine all assets. Combining them is what makes a funding method. -
Is this recent discussion relevant to you? http://benefitslink.com/boards/index.php?showtopic=29070
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Modified Aggregate Funding Method
david rigby replied to a topic in Defined Benefit Plans, Including Cash Balance
The best answer is: don't do it! However, one could refer to page 196 of Authur W. Anderson's excellent book "Pension Mathematics for Actuaries" (second edition). There may also be references in SOA exam study notes. -
RMD in year of distribution from PS plan
david rigby replied to dmb's topic in Distributions and Loans, Other than QDROs
Are you sure the RMD applies? 5% owner? -
It would seem not, at least with respect to accrued benefits. To do so would likely violate one or more existing plan provisions, not to mention 411(d)(6) concerns.
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Because many plan sponsors have taken advantage of their ability to have expenses paid by the plan. If the plan participants pay this cost, then the last one standing will bear a significant cost.
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Have you checked the yellow pages? http://benefitslink.com/yellowpages/
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IRS rulings --very general question
david rigby replied to jeanine's topic in Other Kinds of Welfare Benefit Plans
That is exactly what it means. -
Sounds like a question to direct to the "Help" section of your software.
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Is it really a change? Or is the term cost just zero? Are you changing an assumption? Look carefully. If you (I'm assuming you are the actuary) consider it a method change, then by all means, report it on the Schedule B. If it does not meet the conditions of Rev. Proc. 2000-40, then IRS approval would seem to be needed.
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As stated many times, the least expensive route may be to award the 100% vesting. However, it may still be advisable to discuss with counsel what would be the best mechanism and timing for this.
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Installment Payments and Funding Waivers
david rigby replied to a topic in Defined Benefit Plans, Including Cash Balance
Lien? Is this conclusion valid? My understanding is that a waiver application will specify the $ amount requested, which should include the amount of any interest penalty that accrues due to late quarterly contributions, if applicable. Don't over-analyze it. -
Partial termination is always a facts and circumstances analysis. With the facts presented, I would conclude YES, but it is useful to remember that other facts could be relevant.
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Yes, available to plan participants. No, not available to participants. Additional help can be found using the Search feature, especially using the keyword "public".
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Missing from the above discussion is whether the "disappearing" plan has any problems, especially those that would cause an IRS or DOL auditor to be concerned. If so, making the plan "go away" will not make the problems go away. If this plan was "aqcuired", then the sponsor may have also acquired the problems withouth knowledge. The sponsor may wish to make sure it has done its own due diligence about this issue, and discuss with its ERISA counsel, before proceeding. The statement by Bird about "should have identical BRF" is a bit overdone. Consultation with counsel will show that amending either plan before merger may be a useful step in this process, depending on the provisions of both. Difficult to make that determination here without complete review of such provisions.
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can a 401k distribution be rolled over to an account in England?
david rigby replied to a topic in 401(k) Plans
There have been some previous discussions on similar topics. For example: http://benefitslink.com/boards/index.php?showtopic=25894 -
Have not looked recently, but recall that the instructions (or perhaps the PBGC regs) deal with this issue, and the Standard Termination can become something else, such as a Distress Term. A bankruptcy is just about the biggest red flag there is. Not sure if bankruptcy must be reported to participants, but a change in the termination process must be.
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Did the Plan pay these expenses? The C is to report expenses paid by the plan, not by the plan sponsor.
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CONTROLLED GROUP?
david rigby replied to himt4's topic in Defined Benefit Plans, Including Cash Balance
I think you need some more facts. Have you read the Q&A's here on controlled groups? http://employerbook.hypermart.net/QATopic.html#C6 The question of Affiliated Service Group will also come up. -
DB 415 Limit question
david rigby replied to fiona1's topic in Defined Benefit Plans, Including Cash Balance
Everytime I went to math class, 57 was greater than 55.
