GMK

In the DC case, the RMD amount for 2016 is the balance as of 12/31/2015 divided by the life expectancy based on her age on her birthday in 2016 (or her age at the end of 2016 or however you want to remember it), regardless of whether it is paid in 2016 or in early 2017. The RMD amount for 2017 is the balance as of 12/31/2016 divided by the life expectancy based on her age on her birthday in 2017 and is due by 12/31/2017. I don't know DB.

Plan documents are usually explicit about what happens when an employee's classification changes from included class to excluded class. It's worth a look.

About the time they receive their account statements, send a reminder letter of how much in plan administration fees they're paying by not rolling out. Not paying administration fees is a gift card that keeps giving.

^ That's an applicable analogy, but at least Ford is in the business of making cars. My message to plan sponsors is that this is but one of many examples that show that retirement plans are out of their depth when they try to be in the banking business, unless the fiduciaries are bankers.

ombskid - either your client has the expertise to manage the fiduciary responsibilities of offering loans (and not just the payment issues) or needs to hire such expertise or should consider not offering loans. After all, it's a RETIREMENT plan, not a bank. My apologies for shouting. To me, the idea of plan loans is like a roaring flame about 3 feet tall.

You raise an interesting point, but like, ESOP Guy, I haven't seen it done. Seems to me that you have to figure out what the company is worth, whether by share values or an overall appraisal or other (?), and then see if the owner's stock is worth more than 5% of that value or not. It's probably easier said than done.

If we're citing this shoe style reference book, maybe we should first check if this is a marketing word, and not a real word, coined to assuage the self-conscious concerns of persons at whom the size 13E's and larger are targeted. I tried to find "bigly" in Webster's, but all it said was, "Wha'choo talkin' 'bout, Tom?"

Not sure, but I believe that a child who is a "tax dependent" can be kept on the parent's health insurance past age 26. This link summarizes to which children the term "tax dependent" (qualifying child) applies: https://turbotax.intuit.com/tax-tools/tax-tips/Family/Rules-for-Claiming-a-Dependent-on-Your-Tax-Return/INF12139.html

The amount of the RMD for 2016 is based on the balance in the plan at the end of the previous year, i.e., as of 12/31/2015. Earnings in 2016 would not change that balance, so yes, the participant should simply withdraw the RMD amount from the IRA.

If the employee is no longer employed by the company at some time in 2016, then that person is required to take an RMD for 2016 has an RBD of 4/1/17. When a person has an RBD, then the first portion of any distribution during the year in which the person retired is deemed to be RMD. JP's solution appears to be the correct one. That said, from what I've read at BenefitsLink, if there is still enough money in the employee's account to cover the 2016 RMD now, and if those funds are distributed to cover the 2016 RMD soon after the employee's employment ends, then there probably wouldn't be an issue about not taking it from the distribution last February (when no RMD was due). But if the 2016 RMD isn't covered now, then a portion of the rollover in February was not eligible for rollover. As JP proposes, the plan issues the two 1099-R's, and the person has to get the cash back from the IRA.

My understanding is that under ADA, after the end of an FMLA leave, you need to discuss a continuing health issue with the employee to try to determine if a reasonable accommodation is possible. If it is, then you provide the reasonable accommodation. If it isn't, then you proceed consistent with ADA and your company's policies. Continuation of coverage under the company health plan may or may not be reasonable accommodation, depending on the specific circumstances, past practices, etc. I do not know of anything in ACA that requires continued coverage beyond that provided under FMLA, but I don't know everything about ACA. Maybe someone else can help there.

I'm guessing that the disclaimer is common to most, if not all, such accounts, and I share your concerns about not knowing that my money is being stolen until after it is gone. (Paranoia strikes deep.) I like your solution. Thanks. I plan to implement it for myself, as I am soonly to step into retirement world. Besides, my wife doesn't use the computer, so this provides a procedure that she will like for accessing the funds and when she later wants to access her survivor benefits (some day ... in the not too near future, we hope.)

ETA - don't know one way or the other, but from what I've read here at BenefitsLink, MBozek may have already written this paper. Actually, I'd be interested to know if he's published any such overview papers.

Since I'm in such a good mood this morning, write about the primary effects of requiring ERISA fiduciary rules to apply to elected and appointed government officials and their staffs. Yah, I live in a dream world sometimes, but it is a serious suggestion and should make for interesting reading.

I don't have a cite to answer this interesting question. The phrase I rely on is that if an RMD is due, then the first portion of any distribution is deemed to be RMD until the RMD for the year is satisfied. Presumably this is so that the IRS gets its long-awaited tax money first, before the participant hides the rest in an IRA. Now, with a Roth, the money is also taxable, so maybe they don't care much either way, but until someone points out anything different, I will continue to assume that the deeming of the first portion to be RMD applies.

Could it be that the truth is in this typo?

IMO, the best solution is, as ETA suggests, to get the Plan to switch to daily valuations. Otherwise, explain to the accountant the importance of getting the information out earlier. If the accountant continues to wait until September, find an accountant who is more responsive to the needs of the Plan. For example, years ago, we had a TPA that treated our annually-valued ESOP like a daily-valued 401(k) and thought is was OK to wait until 5500 time (July) to get us EOY account balances. To do distributions as soon as practicable after the end of the Plan Year (12/31), we need the information much sooner. We explained all that to this person, but it didn't stick. So, we got the TPA firm to assign someone else to crank the numbers for the ESOP, and we were able to do distributions timely. Whatever works for Plan purposes is good.

l hope you are right, Pilgrim, but is there reason (historical or otherwise) to believe it will be the same for the SF and 5500 (whose names imply that they are not meant to be as E-Zee)?

We especially like the dark chocolate cow pies. I think they leave them out in the field a few extra days for richness of color and a more fragrant aroma. mmmmm and for us, just a short drive up the road.

As a plan administrator, I like A Shot's list (post #2). And you could consider adding that you would put your promises in writing.

^Well said. A couple references: https://www.shrm.org/hr-today/news/hr-magazine/pages/0113-wrap-documents.aspx https://www.law.cornell.edu/cfr/text/29/2520.102-3

Thank you for getting your answer posted today, Manny (assuming you'll be busy at the travel agency tomorrow). IMHO, Grim Fandango is still the best.

The employer sends a check to the TPA for $75 and deducts the $75 from the employee's next payroll check(subject to state law, see post #2, above), and ta da it's done. Kinda like when the employer sends the check to the health insurer and deducts the employee's portion of the premium from one or more paychecks. Figure out how you want to handle the cases where there's no payroll check and explain that to the participants in the SPD section on loans. Even simpler, don't offer loans from a plan that's meant to build a nest egg for retirement, unless of course you're a banker or the plan enlists the services of a banking loan expert.

Isn't it the FSA Plan Doc that needs amending (with a revision of the SPD)? Sometimes, the Plan Doc is also the SPD, so maybe I'm stuck in semantics.

FWIW, it feels to me that they probably can't switch to the High Deductible plan mid-year. If they were not eligible to enroll in the High Deductible plan before the baby was born (not likely), but now, because of the birth, they are eligible for the High Deductible plan, then yes, that's consistent, and they can switch mid-year. Otherwise, I think they have to wait for the open enrollment period. I'd be happy to see a cite that shows I am wrong in this analysis, but the consistency requirements make sense, too.