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Everything posted by david rigby
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BTW, it is acceptable to post a question in more than one forum, if it's appropriate. However, because other users might find the Q&A via search, it's useful to have all the answers in one place. To that end, putting in a cross-reference helps.
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- overfunded
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IRC 414(p)(1)(A)(i) allows a QDRO to assign "... all or a portion of the benefits payable with respect to a participant under a plan...", so I’m gonna suggest "No". I know this is unusual: have you given any thought to using up some excess by making her a participant in the plan?
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- overfunded
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Here's another question to add to Peter's excellent list: Does the entity (whether TPA or plan sponsor/PA, etc) want to get the correct and/or best solution to its problem?
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4980 excess asset Issue
david rigby replied to VeryOldMan's topic in Defined Benefit Plans, Including Cash Balance
I'm much more concerned that it might not be transparent to Corbel. <wink> -
Please let me know if I can help you find a new TPA.
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Cost to start a VEBA/MEWA?
david rigby replied to misterfinder's topic in Other Kinds of Welfare Benefit Plans
Duplicate post. Responses are here: https://benefitslink.com/boards/index.php?/topic/64347-cost-to-start-a-vebamewa/ -
terminated participant resurfaces
david rigby replied to thepensionmaven's topic in Plan Terminations
Good points. When investigating this EE, look out for an assumption the person was deceased (and therefore no benefit due). If such error was made, the PBGC will have no record (ie, money) for this person, and the sponsor might have to amend its PBGC filing to include the missing participant. -
4980 excess asset Issue
david rigby replied to VeryOldMan's topic in Defined Benefit Plans, Including Cash Balance
Really? One-seventh, one-sixth, one-fifth, one-fourth, etc. -
Yes, the sponsor will probably find that retirees lump sums are less costly than retiree annuity contracts. However, other factors might be relevant; for example, a 2019 lump sum based on August 2018 rates might be about 2.5% greater than if the lump sum is based on November 2018 rates (ie, without regard to possible annuity purchase). Therefore, the "savings" can vary from plan to plan, but more importantly will vary based on the plan definition and the actual retiree population. IMHO, the sponsor might want to think long and hard, and think again, before doing a LS offer to retirees. My experience with this is summarized as, "Retirees don't like change". Someone will probably have to explain it when EACH retiree calls on the phone, and again when the retiree's spouse calls on the phone. (Voice of experience.) Don't treat this lightly. Don't be surprised if the acceptance rate is low.
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4980 excess asset Issue
david rigby replied to VeryOldMan's topic in Defined Benefit Plans, Including Cash Balance
Subsection 415(e), which "co-ordinated" the maximum when the EE is covered by both DB and DC plans, was repealed several years ago. (Taxpayer Relief Act of 1997?) -
Fair value of plan assets
david rigby replied to SSRRS's topic in Defined Benefit Plans, Including Cash Balance
To quote the guys from Car Talk, "my knowledge is half-vast". -
Fair value of plan assets
david rigby replied to SSRRS's topic in Defined Benefit Plans, Including Cash Balance
IMHO, the auditor gets to answer both of your questions. Measurement of Plan Assets appears in ASC 715 at paragraphs 715-35-50 thru 715-35-61. Reading subparagraph -60 indicates that "gross contract value" might not be appropriate. -
QMCSO vs Consent Order
david rigby replied to NJ_BenAdmin's topic in Health Plans (Including ACA, COBRA, HIPAA)
DOL/EBSA booklet: https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/publications/qualified-medical-child-support-orders.pdf Don't forget the administrator's responsibility to determine if the order is qualified. -
Survivorship benefits and beneficiaries
david rigby replied to BG5150's topic in Qualified Domestic Relations Orders (QDROs)
Might be hasty to assume some sort of default, since some plans might allow multiple beneficiaries. -
Participant doesn't want to lose Medicaid benefits, plan is Safe Harbor
david rigby replied to BG5150's topic in 401(k) Plans
No Medicaid expert, but I thought eligibility is related to income ("modified adjusted gross income"). Are you (or the employee or the employee's guardian) sure that eligibility can be affected by assets in a qualified plan? Edit 01/13/2020: I learned that yes the eligibility can be affected by assets in a qualified plan. -
Long-time users of these message boards know that terminology is often mixed up. In particular, the word "shares" jumps out. Since that is (almost) never a characteristic of a defined benefit plan, it's possible something else is being discussed. In addition, note the link above will reveal the Form 5500 only for qualified plans; it's possible the "plan" under discussion is non-qualified, perhaps even an executive plan.
