RDY2RTR

One of the requirements to mark yes to the small plan audit waiver in the Form 5500-SF is that any person who handles assets of the plan that are nonqualifying is bonded in an amount that is at least the value of the nonqualifying plan assets. Is this amount determined as of the beginning of the plan year or the end of the plan year? 5500 instructions just say bonded in the amount and doesn't clarifying the amount as of a certain date. In my case, there were no nonqualifying assets as of the beginning of the plan year, but were acquired during the plan year. Thanks-

What about a terminated participant with a zero balance on the plan's recordkeeping system and an accrued contribution (fully vested) for the plan year? The daily recordkeeping balance on 12/31/2014 was $0.00. The 2014 profit sharing was deposited into the trust in January 2015, which is when the terminated participant first had a balance on the daily recordkeeping system. I believe the terminated participant should be included in the 12/31/2014 5500 count because he does have a balance in the plan. Net assets reported in the 5500 include the accrued contribution. The recordkeeper disagrees with me.

Plan has immediate entry for employee deferrals, but requires 1 YOS for the employer match. When I run the 410b test in Reilus Administration without dissagregating otherwise excludable employees the number of non-excludable NHCEs and HCEs are correct. When I run the 410b test, choosing to disaggrate otherwise excludable employees, the number tested in the otherwise excludable group for the employer match is including employees who never met the eligibility requirements for the match portion of the plan (however they have a plan entry date due to employee deferral eligibility). Not only this, the test says they are benefitting under the match. I would expect to see the nonexcludable population from the first test I ran (w/o dissaggregating) to be split into two pieces when I disaggregate. It should be easy to check the numbers: sum of nonexcludables for 410b purposes not excludable by statute + nonexcludables for 410b purposes excludable by statute should equal the total nonexcludables from the first test, correct? Do other users out there have the same problem? What is your workaround? Also, if anyone can tell me what Relius' logic is in determining whether an employee is non-excludalbe and benefitting (what fields should I be looking in to trouble shoot), I would appreciate it.

I am a new Relius user and am unsure about a warning I receive when running the ADP test. I'm using the prior year testing method, and shifting. The warning says: Warning: The prior year NHCE percentages stored in Plan Specifications differ from the values computed using the prior year data. Shift corrections will be processed on the data computed using the previous plan year. Test(s) affected are: Year to date ADP, Year to date ACP Does this mean that there is something wrong in the database and when Relius re-calulates the NHCE rates based on the prior plan year data, the group average does not agree to the rates rolled forward in the plan specs when the new plan year is created OR does it mean that the calculated percentages are different because Relius has shifted contributions resulting in new NHCE rates and there really isn't anything to worry about?

I would look to see when the eligibility computation period starts. Most of the plans I work on say it starts on the date the employee first performs an hour of service. In this case the relevant date would be the August date.

This appears to be the SH match formula for a QACA (qualified automatic contribution arrangement). This also allows for a 2 year vesting schedule.

Thanks for the information Tom. The client allocates the match on a payroll basis and we verify their calculation at year-end. It looks like we will have to do this in excel. Thanks for reminding me about the BRF test. We do have a gentleman in our office who knows crystal report. I would love to look at your BRF test based on YOS.

Is there a way to code the following type of match formula in Relius? 0-2 YOS: 25% up to $400 3-5 YOS: 25% up to $800 etc. I'm new to relius and can't see that this can be coded in the plan specifications.

What if semi annual allocation periods were used for one group of employees and an annual allocation period was used for another group of employees? Is this allowed as long as the plan passes 401a4?

Plan is terminating effective 10/31/2011. Assets will not be distributed until after the end of the year. For testing purposes (compensation limitation, 415 limit, etc.) is this considered a short plan year. My thought is no becuase the 5500 will not be a short plan year.

I am not too familiar with insurance contracts in retirement plans and hope someone can help me. The 5500 I am working on has an insurance contract with The Hartford. The Hartford provides schedule A information. They (The Hartford) also provide Schedule D information for all investments in the contract, so I"m assuming these investments are all PSAs. If I mark the funding arrangement on page 1 of the 5500 as "TRUST" and "INSURANCE", complete Schedule A and put the MV of the insurance contract as PSAs on schedule H, then I get and error message that there is a conflict between the funding arrangement "INSURANCE" and $0.00 assets in BOY and/or EOY on schedule H of Insurance General Account. IF PSAs are wrapped in (aren't they always?) an insurance contract, then which type of assets are they for Schedule H purposes. Any help would be greatly appreciated. Thanks.

When running the ADP test, we can disaggregate otherwise excludable employees using the early participation rule or running two separate tests. Can the early participation rule be used in the 410b test also or is it's use limited to the ADP and ACP tests. Thanks.

Question about webclient. I need to amend a 2009 because the wrong attachment was originally filed with teh 5500. I've clicked the amend button in webclient and status is a "amendment in progress". Do I just delete the original amendment, attach the revised and then efile or do I need to republish?

In 2008 controlled group was comprised of 8 entities. ADP test was run on the controlled group and the NHCE ADP was calc'd at that time for use in the 2009 ADP test as prior year testing is used. In 2009, 1 of the entities is no longer part of the controlled group and needs to be tested alone. I am unsure how to determine the 2008 NHCE ADP to use for this single entity. Can someone point me in the right direction?

Thanks so much for your responses. It makes sense to me now.