Bri

The hassle, of course, will arise when either LTPT (long time, part time) employee becomes eligible for deferrals only, and you have to set up the account for him/her.

They owe it to you one way or another, although most sponsors will throw it as plan benefits where possible to avoid running payroll taxes on it. If it's not going to be a match as you're not signing up to do 401(k) from your paychecks, for you they potentially could make it your "profit sharing contributions" for the year. Again, it avoids the related social security/medicare taxes, but you'd get your prevailing wage obligation through the plan that way.

There is, although I don't have a copy myself. It basically parrots the language in question 33a of the EFAST FAQs. Someone here should have a Word version or something readily shareable.

It's listed as 2024 Applicable, 2025 Applicable, etc., with a separate table for each year.

yeah, go to Data Entry -> Tables -> Actuarial -> Annuities Enter your interest rate, your mortality table, and the age range you want and it'll give you a list, looks like this:

Can your recordkeeping software export it? I have a 25-year-old Excel spreadsheet I use for DC cross-testing, and I know I was able to just manually enter the APRs for 8.5%/UP84 (which would almost always prevail for my plans anyway) for all relevant ages off a printout from either Quantech or Pentabs at the time.

If the loans were distributed as a benefit offset, then there's nothing to repay. The plan would have discharged the loans. If they were "only" deemed distributions, then the notes still "exist" and the sponsors could get some tax basis by repaying them with all the accrued interest.

The gateway is a nondiscrimination test on the nonelective contributions they're making, so I suspect you would use the compensation for the period the employee was eligible to receive nonelective contributions. In this case, since the SH entry date is earlier and it's made as a nonelective, that earlier entry date is the relevant starting date for the compensation determination. If they used a SHM then I'd suggest the opposite.

I'd be worried that a true-down is actually a cutback if the calculation and allocation are paired together at the pay period (rather than annual) level.

Of course not, but does the plan document address separate one-off paychecks separately with regard to deferral elections?

Is that an ASC document? I think they have separate QNEC options available, depending on how you filled out that 6D. Something where the BPD allows much more limited QNEC options unless you choose that "special contributions" option in 6D. Coordinate 6-D1's italicized notes with the BPD.

Sounds as though you need a new locator to find the old locator service!

I suppose unless there's a mandatory payout limit in the plan, there's no reason they can't stay await direction from the participant/beneficiary.

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.