Bri

Gotta think this is a no - Won't the plan already have a definition for Years of Service and what periods count? And you're wondering if they can now cut that back?

One last thought - I do think Bill's argument is right - is that perhaps they run one final payroll for everyone on 10/31 so that it's captured before the re-organization plan kicks in.

Would it kill them (okay, inconvenience them more than appropriate) to change the term date to 11/3?

Either bring them in the DC.....or increase their DB accrual up to the gateway equivalent since it's probably not high enough to start with in the first place? Maybe check if these people are short-service enough to run in a disaggregated set of tests for the otherwise excludable? (Trying to think how the DB got the easier eligibility to get into, so maybe they use something less than the 410a max.)

It could just be a post-tax annuity, too, which means the purchase of the annuity was used with more than enough plan funds to satisfy the plan RMD.

yeah, so if they do unfreeze down the road, you'd pull that code. Otherwise you might sort of visualize it as just an ongoing plan with a 0% formula for everyone - you do everything else like you'd "normally do".

Same as any other plan, but code 1I (one-eye, depending on your font)

Should be, since the key point is whether or not the plan itself doesn't pass without aggregation. If the DB plan were the only plan, and it was frozen, nobody would be benefiting at all and therefore wouldn't need another plan to help it pass.

I'd say it depends on whether either plan needed the other to pass its tests. With the DB frozen, that sounds like its return should answer no. And unless the DC testing required prior benefit accruals under the DB plan like on an accrued-to-date test, that plan probably should answer no as well, thinking it's passing for 2023 as a standalone plan.

If it's not an annual addition because of their 415 limit being zero, I'd argue those aren't actual deferrals triggering the THM. (As opposed to an ADP refund)

Are they evicting themselves? Their landlord certainly could do it, but otherwise I'm with justanotheradmin on this one.

Does anyone ever back-fill their designations when ASPPA issues new kinds that are lower-ranking than what one's already attained?

72(t)(2)(A)(iv) probably answers the penalty issue, but whether the annuity can start at any time is more likely a plan document issue.

Track it separately and manually adjust whatever reports you get from RK B?

Ha, I've got the draft all ready to go to everyone, was just kinda curious of how that rule would really be enforced/interpreted (or if it has ever seen in a similar fact pattern). Thanks all!

Sponsor filed 5500-SF in July, so on time. Sponsor could have had the automatic extension due to extended tax return, but didn't need it, and the 5500 doesn't reflect it (after all, why would it, since it was filed on time?) SAR is due 2 months after the 5500 deadline. Can that still be 12/15, or does it have to be 9/30 specifically as a result of not checking the automatic extension box on the 5500? Hmmmm...... --bri

Maybe rate banding works leaving the 9% plus 50 bucks in there?

Someone 25 years ago introduced the concept of "class year vesting" to newbie me, and already as not allowed.

Isn't this just a BRF issue with separate vesting schedules for different groups of employees based on hire date?

Aren't we in the context of a sole proprietorship, though, and the old question as to when one of those "retires"?

You could build a custom Crystal report and select/sort based on the PAYROLL table, then summarize the hours over the SSNUM field while restricting the select field to just the time frame you need. (Or build a formula where the high end of the range is HIREDATE plus a year, something like that.)

I kept it straight by realizing the same new early-eligible people who are dropping the TH ratio from 61% to 59% get absolutely no thanks for it from anyone other than the owners. "You cost us a top heavy minimum even though you weren't qualified to even get it in the first place."

First thought is, why ask the actuary's office rather than the accountant's?

I'm wondering if there's a way to claim MDO as 0% for the NHCEs and just take it all back as an ADP test failure.

"By the way, a lady in a bar told me I had a mistake of face once. No respect!"