Bri

I always wondered why nobody else calls these the red, blue, and yellow matches, just as a way to get other people to understand that the matches are basically concurrent!

I'd suggest looking up the pension organizations that give us all the fancy letters after our names, and explore their education offerings. (ASPPA/NIPA to name two to start with)

No, my boss was sharing a laugh with me at idiot participants that get their TPA's phone number and next threaten to "call ERISA" if they don't get what they want!

Sure, but if your testing demographics can support it, it's okay to have. And you know, make sure the bases are covered for switching in/out of classes.

Go figure. According to my old boss, an angry participant could just pick up the phone and call ERISA, especially to rat out a bad employer. 😳

I'm surprised that, despite flying cars, we still don't have match calculators that will roll up the aggregate on the fly? So that every pay period determines the aggregate match due so far and trues up as needed every time. I mean, I used it in Relius 15 years ago, so kinda figured every payroll company should be able to do this by now.

This feels like something that 25 years ago should have been addressed at a symposium with IRS people around - Hey, are you sure that's how we're supposed to interpret this? No Key could defer even a nickel without triggering the full 3% by the time everything cascades. I respect that it's such a reasonable fact pattern.

what's the benefit that gets increased specifically by a wage increase? An X% money purchase contribution? Their pro rata share of a $Y company profit sharing? The application of a match formula? kinda suspecting it's not something the plan has discretion to finagle with, absent the comp definition change.

They're not 402(g) excess deferrals, though, so I'm not sure the parallel works.

I've been treating them as otherwise excludable employees, tested separately against no HCEs. You can likely exclude them from SH, PS, gateway, TH, etc., that way.

If you're following a document's failsafe provision, you have to choose who that indicates. Absent that and doing an -11(g), then they can choose who they'd like to provide additional benefits to. Just don't try to give it to someone who you know terminated and is also nonvested, such that they'd never see the benefit anyway.

I think he just meant whatever way his pay is reported, W2 versus Sch. C. But you don't take 2/12 of it just because everyone else stopped working then.

Did the CB terminate or did it last all twelve months?

A QOSA is just an IRS rule indicating what level of survivor portion must be made available to the participant as an Option, depending on what's the plan's default QJSA level. Typically "actuarially equivalent".

What, none of you had to import a program basically via tape recorder and cassette like on a Commodore Vic-20? (Could be a computer program on there, could be VH taped off the radio....)

The PA is generally listed in the SPD. But it's usually listed as the employer. As long as it's just somebody different within the same company who also has legal authority to sign on behalf of the company as PA, there should be nothing further to update in the plan/SPD.

I'd use the actual legal plan name as reflected on the document, and I'd also never worry about the IRS caring one way or the other unless the plan would also have much bigger fish to fry under an audit. You can update the name change on the 5500 after it's actually been effected.

No less rapidly than ratably, actually, according to the text. Seems like you could do a third in year 1, as long as you still do at least a 6th in year 2, a 5th in year 3, rather than being forced into then only getting 3 years. No?

Both refunds are due by 12/31. You just avoid an excise tax by also beating 3/15.

I personally have never seen the guidance that allows us then not have to use that one person's age/service history as the "lowest" requirements that typically get applied in 410(b) analysis, though. That's the magic bullet (which may indeed exist)

I know "Brad Pitt" sometimes lingers the board and he's at FIS, but might not know who to relay this to!

Anyone else get pushed 5.26/5.36/5.00 as the January rate update, which then were presumed to need to be corridored into 5.25/5.31/5.50? It's like someone in Jacksonville didn't line up the columns right when updating their master to push out to users, since the first two rates are the December 2nd/3rd, while the 5.00 is the January 1st segment.

If they're in the testing, and they're already benefiting from the non-elective safe harbor, then they have to get at least the gateway minimum via additional profit sharing allocations. Check your plan document, many pre-approved documents will have a line in the BPD indicating that anyone who has to get gateway, will get gateway even if it conflicts with other plan provisions.

It happens, albeit rarely - maybe if they adopted a PS plan with no deferral option, and then didn't make a first year contribution. Can't say I've seen it in a plan with a deferral option.

Just thinking out loud here, trying to figure out if my logic is okay.... CB plan is going to cut the contribution credit for the two principals for 2025, which they accrue upon 1000 hours of service. Plan is getting its restatement for Cycle 3 in the next couple of weeks. Typically we'd have the restated doc effective 1/1/25. That date is, of course, before they'll get a 204(h) notice. I'm torn between: a) So what - give them the 204(h) notice now, so that they get 15 days warning that their benefit rate will drop. If they happen to hit the 1000 hour mark in the middle of March, then they'd be prohibited from the cutback in the formula and still get their old percentage of pay. b) Make the Cycle 3 doc effective March 31, 2025, instead of 1/1/25. That way they definitely get the notice before the effective date of the drop. Obviously (b) is okay, but (a) seems like it could potentially still be okay and if it does, at least there's not some kind of weird rando date in the plan's history. Thoughts? --bri