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david rigby

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Everything posted by david rigby

  1. david rigby
    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
  2. david rigby
    Have you asked your actuary this question? By the way, what is "AMT15"?
  3. david rigby
    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.
  4. david rigby
    Only partially snarky: so what?
  5. david rigby
    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?
  6. david rigby
    Pardon my ignorance: if they did not execute participation agreements for the "new companies", how is there a multiple-employer plan?
  7. david rigby
    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?
  8. david rigby
    Think "intranet".
  9. david rigby
    https://www.irs.gov/uac/Newsroom/IRS-Announces-2016-Pension-Plan-Limitations;-401(k)-Contribution-Limit-Remains-Unchanged-at-$18,000-for-2016
  10. david rigby
    Never cheat! BTW, what does the plan's attorney say?
  11. david rigby
    Any precedent? BTW, if you are not the actuary, the plan's actuary should be involved in this discussion.
  12. david rigby
    AndyH, are you suggesting we should be wary of attorneys from Mass?
  13. david rigby
    News release last year was dated 10/23/14.
  14. david rigby

    80-120 Rule

    david rigby replied to coleboy's topic in Form 5500

    The point of the 80-120 rule (see link above), is they may file whatever form they filed last year.
  15. david rigby
    You might have issues other than taxation, such as EE contributions toward medical coverage, LTD coverage, etc.
  16. david rigby
    Nope. See PBGC Blue Books. Q&As 2000-16 and 2007-05. http://www.pbgc.gov/prac/other-guidance/blue-books.html
  17. david rigby

    80-120 Rule

    david rigby replied to coleboy's topic in Form 5500

    See page 8 of the 2014 instructions. http://www.dol.gov/ebsa/pdf/2014-5500inst.pdf
  18. david rigby

    Church Plan

    david rigby replied to nancy's topic in Form 5500

    I don't think so. You may wish to review regulation 1.410(d)-1
  19. david rigby
    The plan might define the death benefit in a way that includes the 415 limit.
  20. david rigby
    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.
  21. david rigby
    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?
  22. david rigby
    It may be prudent to inquire about the source of this "life insurance" payment.
  23. david rigby
    Don't know how the DOL will treat the draft attachment. But it's probably not as bad as no attachment.
  24. david rigby
    If you create an interim valuation (or an estimate), isn't that a plan feature that is outside normal plan operation? You could: - segregate now, with no interim gain/loss, or - reply that the DRO is not a QDRO, since it requests something not in the plan. Any precedent?
  25. david rigby
    What is your relationship to the plan? to the Plan Administrator? Assuming it's only a typo, and you mean 401(k) plan, if you are the TPA, perhaps you will want to express an opinion and then back out, saying this is a job for the plan's ERISA counsel.
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