Bri

Figure out what month the actuary elected last year, and you can see that on the SB where the rates are listed and the applicable month is indicated (0 for when the rates are the month including the valuation date). You should be able to find the rates for this year's version of that month in table 3A. Isn't 2A just to show how the corridors are established?

If they're related, the employees would not have had a severance of employment with the (overall combined) sponsor, so benefit elections shouldn't typically be available.

I believe it's one of those Secure 2 amendment things, just gotta keep track of what you did ahead of executing the amendment later this year.

The loan paperwork may also have a "payable on demand" clause to it to cover such a situation where the plan's trust is going away to let the participant know there's not going to be a loan any longer. That too should easily establish a default date (and I acknowledge to @fmsinc that the loan wouldn't yet be in default but eventually that bell will toll for the participant to pay up sooner than expected).

Sometimes I don't realize the original post is in the 401(k) section, but I do lots of DB plans too, and no such "account balance" exception exists there.

You are indeed meant to add the number of January 1 newbies to the prior EOY count. And if that means 118 now turns into 121, guess what....

I'd think no issues, just like any ongoing plan other than maybe the termination distribution is looming faster where you don't want an RK to discharge a defaulted loan as everything else is getting distributed.

Are you testing otherwise excludables separately or at least carving out? Usually no need for that subgroup to utilize a safe harbor. Like, if everyone in the "main test" is getting the SH and probably none of the OEXs, then their OEX ADP test might not use a SH but should pass without HCEs. And who gives OEXs top heavy minimums any more, really?

If you can argue when the deposit started being late, leading to the 5330 filing requirement, that should guide which year to file for.

My guess is they'll either work great (common RK platform DC plans), or they'll be horrible (trustee-directed pooled assets with spousal consent).

If you're going to general-test the allocations anyway, is it an actual problem to no longer potentially have the safe harbor uniform formula alluded to in that Regulation? (And I apologize, earlier I missed that the DC was actually two distinct plans.)

you need to state in the CB document that the 5% THM will be handled under the DC plan. but then, sure, the person needs to get a total of 5% and 4 of that can be the match. insert disclaimers about gateway minimums, though, here.....

Figure out the passing QNEC level and figure even if they'd all been auto-enrolled at something lower, they would have needed more corrective amounts anyway to pass the ADP? Obviously going for a "this feels like a reasonable correction" approach

oh absolutely, that'll be easier than setting up the commutation functions from scratch (which is why I pointed to a table of q values, depending on how much "first principles" were going to be utilized.)

you mean, like, here are the q's and you can take it from there? i found this on the SOA site.... https://mort.soa.org/ViewTable.aspx?&TableIdentity=831