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david rigby

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Everything posted by david rigby

  1. T-H rules provide minimums (benefit, vesting). If the plan is more generous than the minimum, then it automatically satisfies T-H. Don't worry, be happy. BTW, I think that all plans must include T-H language even if all other plan provisions provide something better. (am I remembering that correctly?)
  2. Likely, this question has been answered (in the negative) sometime in the past when another EE changed positions. QDROphile is correct.
  3. You've probably heard me say it before: there is no insurable interest.
  4. This attachment is from a discussion draft dated 10/26/15. Apparently, the ability to count PBGC premiums as "general revenue" is so attractive to Congress that they will continue to abuse sponsors of DB plans. Proposed Budget 10.26.15.pdf
  5. Have you asked your actuary this question? By the way, what is "AMT15"?
  6. Why? could be lots of reasons. My hunch: it's a way to avoid most audits, by requiring the submission of information that would be requested in any audit.
  7. Only partially snarky: so what?
  8. BTW, the reference to "...100% vested in 3 years..." implies a cash balance design. Is that correct? Any other participants? Is the sponsor trying to postpone the RMD as long as possible?
  9. Pardon my ignorance: if they did not execute participation agreements for the "new companies", how is there a multiple-employer plan?
  10. In this context, does "advisor" mean someone involved in the asset investments? someone who gets a higher compensation/commission/etc. when the plan assets are larger?
  11. https://www.irs.gov/uac/Newsroom/IRS-Announces-2016-Pension-Plan-Limitations;-401(k)-Contribution-Limit-Remains-Unchanged-at-$18,000-for-2016
  12. Never cheat! BTW, what does the plan's attorney say?
  13. Any precedent? BTW, if you are not the actuary, the plan's actuary should be involved in this discussion.
  14. AndyH, are you suggesting we should be wary of attorneys from Mass?
  15. News release last year was dated 10/23/14.
  16. The point of the 80-120 rule (see link above), is they may file whatever form they filed last year.
  17. You might have issues other than taxation, such as EE contributions toward medical coverage, LTD coverage, etc.
  18. Nope. See PBGC Blue Books. Q&As 2000-16 and 2007-05. http://www.pbgc.gov/prac/other-guidance/blue-books.html
  19. See page 8 of the 2014 instructions. http://www.dol.gov/ebsa/pdf/2014-5500inst.pdf
  20. I don't think so. You may wish to review regulation 1.410(d)-1
  21. The plan might define the death benefit in a way that includes the 415 limit.
  22. Maybe none? In general, the plan pays to those eligible who make a claim. As long as you aren't hiding, I suggest the plan does not have an obligation to seek out a potential beneficiary, especially when such potential beneficiary is not obvious.
  23. Is the PS contribution discretionary? If the ER, in its discretion, decides to make a zero PS contribution, is that a freeze? Put another way, what is the intent of the original question?
  24. It may be prudent to inquire about the source of this "life insurance" payment.
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