Bri

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

Failsafe provisions generally address 410(b) rather than 401(a)(4). That's the first thing to clear up - whether you have insufficient people, versus insufficient benefits to those people. Gateway minimums are required for anyone sharing in the nonelective contributions of the employer. (That means, in for a penny, in for a pound, and if you have a 3% SH nonelective, that means they're already benefiting some, if not yet enough to meet that gateway level.) If your plan allocates individual contributions by person (rather than one big contribution to be shared pro rata, if your plan says that instead - I'm referencing individual allocation classes with 1 person in each class) then you can adjust people with more individually. That's the typical fix if you're passing coverage but not non-discrimination....increase NHCE benefits as necessary for the 401a4 testing.

If this new person is an otherwise excludable employee, as it sounds, they could potentially be excluded from THM requirements.

My eyes were drawn to the idea that all 58 participants have an earmarked percentage of any specific investment in the pool.

It took about six weeks last fall, AND since this was a prior plan that never had done the determination filing, we were able to get a few years of past premiums refunded. Of course the plan terminated a few weeks ago and the whole point of the coverage request was to say, "Wait, is the PBGC really supposed to be involved here?" and luckily no year's DB/DC combo amounts exceeded 31%, either.

I've done a coverage determination for a small pharmacy - they asked for an approximate revenue breakdown between health and non-health (lottery tickets, etc) revenue. About 95% was health-based, and the PBGC said they were exempt.

It's like a collectible!

even though it's also been reported on the W-2? (I'm voting for 120K)

I used to use Crystal to merge the John Hancock year-end import files into a spreadsheet format, so yes it works with common data structures. Basically setting the database to be a text file rather than the Oracle. I miss Pentabs.

Pam, do you know anything into how Relius's DB functionality will continue beyond this transition?

yeah, they let you now.....well, depending on what you're doing! (hence my reference to 4% as the safe harbor nonelective, rather than 3%)

Iffy's not the word. But why not adopt a 4% SH at this point for last year?

Medicare wages don't typically include Section 125 deferrals, so you might find that your proper pay number isn't actually found on the W-2 itself, even if your plan uses "W-2 wages" with deferrals grossed back in.

CBZ nails it. Plus hey, if an employer "matches" an employee's loan payment, that's just called, making extra loan payments.....on occasion even also described as "being a nice boss!"

Does everyone "really" treat SDBAs as true daily val where required, or are TPAs just pro-rating a year's worth of gains among the sources based on some prior balance? I've seen way too many plans run allocate earnings like mini "pooled accounting" setups for each employee, where the receivable is just the beginning balance for the next year with earnings not truly determined at each transaction's source's level.... I mean, I've seen it done properly, but I've also had to suggest the plan documents not indicate daily valuation, because it's 10x the work to do it properly "from scratch".

As long as Company A employees are made ineligible, to prevent any new benefits from arising for them, their assets should be allowed to linger behind (as a bunch of ex-employees from the ongoing plan sponsors, right?) until the spinoff is executed.

Is a real estate company a service organization for these purposes?

Sounds right to me...Even 20 wouldn't work because 5.00 is not greater than 5

Depending on how many HCEs are members of the union, maybe this becomes something to negotiate for....

I would guess that unless the amendment specifies it, you start with your BOY balance 1/1/24 and start that at 6% along with new contributions, but you don't then retroactively increase the priors. Whether the prior benefits stay with a 5% ICR is going to be indicated in the amendment.

404(c) means they have to be able to transfer investments at least quarterly, but the deferral rate isn't tied to that.

Sounds like what you only need is signed deferral elections for the owners indicating $0.