quinnfield
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Everything posted by quinnfield
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FAS 88 Settlement Acounting
quinnfield replied to dmb's topic in Defined Benefit Plans, Including Cash Balance
But a monthly distribution is not completely relieving the plan sponsor of the obligation, just a part of it. Thus it doesn't fit the definition of a settlement. -
Because oft times, the Schedule H is prepared on a cash basis, and regulations require the Schedule B to be prepared on an accrual accounting basis.
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May someone age 65 or older contribute to an HSA?Friday, December 12th, 2008 by WPJ In Administrative, Procedural, and Miscellaneous Notice 2004-50, the IRS addresses this question. See Questions 2 and 4, excerpted below: Q-2. May an otherwise eligible individual who is eligible for Medicare, but not enrolled in Medicare Part A or Part B, contribute to an HSA? A-2. Yes. Section 223(b)(7) states that an individual ceases to be an eligible individual starting with the month he or she is entitled to benefits under Medicare. Under this provision, mere eligibility for Medicare does not make an individual ineligible to contribute to an HSA. Rather, the term “entitled to benefits under” Medicare means both eligibility and enrollment in Medicare. Thus, an otherwise eligible individual under section 223©(1) who is not actually enrolled in Medicare Part A or Part B may contribute to an HSA until the month that individual is enrolled in Medicare. Example (1). Y, age 66, is covered under her employer’s HDHP. Although Y is eligible for Medicare, Y is not ctually entitled to Medicare because she did not apply for benefits under Medicare (i.e., enroll in Medicare Part A or Part B). If Y is otherwise an eligible individual under section 223©(1), she may contribute to an HSA. Example (2). In August 2004, X attains age 65 and applies for and begins receiving Social Security benefits. X is automatically enrolled in Medicare. As of August 1, 2004, X is no longer an eligible individual and may not contribute to an HSA.
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Curtailment
quinnfield replied to Mister Met's topic in Defined Benefit Plans, Including Cash Balance
From Para. 40 of SFAS #88: 40. The Board concluded that a curtailment gain or loss as defined in paragraph 13 (which does not include recognition of prior service cost) should first be offset to the extent possible against the plan's previously existing unrecognized net loss or gain. Any remainder of the curtailment gain or loss cannot, at least in an overall sense, be a reversal of unrecognized amounts, and therefore, recognition of that remainder is appropriate. -
Required Quarterly Contributions
quinnfield replied to alexa's topic in Defined Benefit Plans, Including Cash Balance
Love that avatar! Here's some guidance I stole from a Towers Watson publication: Failing to make a required contribution is a reportable event under Pension Benefit Guaranty Corporation (PBGC) rules. If the accumulated missed contributions are more than $1 million, the sponsor must notify the PBGC using Form 200 within 10 days of the missed contribution deadline. The failure also triggers a lien. If the accumulated missed contributions are $1 million or less, the sponsor must file the much simpler Form 10 within 30 days of the missed payment deadline. However, sponsors that pay the amount within the 30 days do not have to file the form. -
Once again, if you’re over age 65 and not eligible for Medicare or not enrolled in Medicare Part A or Part B, you’re still eligible to establish or contribute to an HSA. If this statement is false, please point me to the section of the Code that governs this.
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Why would an actively employed person bother to enroll in Medicare? Isn't it more advantageous to enroll in the HDHP and enjoy the tax benefits of the HSA as well?
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SAS 70 is being replaced by SSAE 16 (Statement on Standards for Attestation Engagements No. 16).
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Your approach is OK, except that the ROA assumption should be set at the beginning of the measurement period with the difference between expected return and actual return deferred into the unrecognized gain/loss. It always comes down to what the firm's auditors find acceptable.
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Can Medicare premiums and copays be flexed?
quinnfield replied to bcspace's topic in Cafeteria Plans
I know you can't contribute to an HSA after the month in which you turn 65, but I would expect that any monies on deposit could be used to pay Medicare co-payments. -
just an observation--if HCE3 is a NHCE, then the answer is C. I and II only. In any year after 1988, the HCE limit is more than 80,000.
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And in a perfect world, your expected benefit payments used in the calculation of the FAS87 pension expense should match to what you reported in the benefit payment schedule in the FAS158 disclosure report.
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Jan 10 Funding Segment Rates
quinnfield replied to mwyatt's topic in Defined Benefit Plans, Including Cash Balance
Has anyone seen the IRS Notice that's published monthly with the updated interest rates? Has the IRS stopped issuing this? Thanks, -
Here's a table from DataIR: AnnualLimits.pdf
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At my firm, we do check increase for changes in the salary and dollar limits caused by CPI increases. This is from the 2007 instructions: Part III – Amendments Line 8. • Check “No” if no amendments were adopted during this plan year that increased or decreased the value of benefits. • Check “Increase” if an amendment was adopted during the plan year that increased the value of benefits in any way. This includes an amendment providing for an increase in the amount of benefits or rate of accrual, more generous lump sum factors, COLAs, more rapid vesting, additional payment forms, and/or earlier eligibility for some benefits. • Check “Decrease” if an amendment was adopted during the plan year that decreased the value of benefits in any way. This includes a decrease in future accruals, closure of the plan to new employees, and accruals being frozen for some or all participants. • If applicable, check both “Increase” and “Decrease.” I believe either way is acceptable to the DOL.
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No. This is from the 2008 instructions: "Any changes in a plan’s funding methods that are made for the first plan year for which Code section 430 applies to the plan and that are not inconsistent with the requirements of Code section 430 do not need IRS approval."
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2009 AFTAP based on 2008
quinnfield replied to a topic in Defined Benefit Plans, Including Cash Balance
What are the implications of being under 60%? Benefits are frozen.No lump sums can be paid. -
Here's a format you can use for IAS 19 reporting. IAS_19.xls
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Actuarial Resources
quinnfield replied to WDIK's topic in Defined Benefit Plans, Including Cash Balance
Here's an outline I found by accident: Workshop9_Deutsch.doc -
Cash Balance Funding Whipsaw
quinnfield replied to JAY21's topic in Defined Benefit Plans, Including Cash Balance
in the interest of simplicity, I would stick with the old 96-8 safe harbor rates for 2009. This would result in an interest rate of 4.00% using 30-year TCM and a 2-month lookback. Notice 96-8 states: Under a frontloaded interest credit plan [e.g., a typical cash balance plan] that, for this purpose, specifies a variable index equal to the PBGC immediate rate or the sum of one of the standard indices and a margin not greater than the specified margin associated with that standard index, no impermissible forfeiture would result from projecting that the rate used to determine future interest credits for an employee is no greater than the applicable interest rate under section 417(e)(3), as amended by RPA '94. Thus, if such a plan has been amended to comply with the changes to section 417(e) made by RPA '94, the employee's entire accrued benefit could be distributed in the form of a single sum distribution equal to the employee's hypothetical account balance without violating section 411(a) or 417(e), provided that the plan provides the appropriate annuity conversion factors. Standard Index Associated Margin The discount rate on 3-month Treasury Bills 175 basis points The discount rate on 6-month Treasury Bills or 12- month Treasury Bills 150 basis points The yield on 1-year Treasury Constant Maturities 100 basis points The yield on 2-year Treasury Constant Maturities or 3-year Treasury Constant Maturities 50 basis points The yield on 5-year Treasury Constant Maturities or 7-year Treasury Constant Maturities 25 basis points The yield on 10-year Treasury Constant Maturities or any longer period Treasury Constant Maturities 0 basis points Annual rate of change of the Consumer Price Index 3 percentage points -
Missing Employee Data
quinnfield replied to Randy Watson's topic in Defined Benefit Plans, Including Cash Balance
just a suggestion--but you could ask them to provide their Social Security Benefit Statements. These include the full earnings history. Maybe you could impute hours worked from the annual earnings. -
Here's a good summary of the Small Plan Audit Waiver Regulation promulgated in October 2000: http://www.dol.gov/ebsa/faqs/faq_auditwaiver.html
