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jeff77

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  1. Thank you for your answer here Brian. This is good news for me.
  2. On July 1 my wife enrolled in a non HDHP thru her employer. Along with this came eligibility to enroll in an FSA which she declined. I have a HDHP thru my employer. Does the eligibility of enrolling in an FSA now exclude me from contributing to my HSA for the term of her employers FSA plan year? Or is it since she declined to have funds contributed to this FSA still make me eligible for HSA contributions?
  3. Does anyone know where I can find an EGTRRA advisory/opinion letter for a DATAIR VOLUME SUBMITTER CASH OR DEFERRED PROFIT SHARING PLAN 06-070. We don't use Datair and I tried calling them with no answer.
  4. We have gotten some rejections as well. The funny thing with our is that they were mailed in one envelope and for the ones we have gotten letters back on some were approved and some were rejected. So far the "s" clients have been rejected. Does the IRS separate them when they are received?
  5. Does anyone have any thoughts here if there is a failure to provide a blackout notice?
  6. I am looking for a book that has sample forms, letters, amendments ect in it. I knew of one many years back but can't find the name. Does anyone know of a good one? On a side note does anyone have a sample spinoff amendment they would be willing to share?
  7. Have a situation where we were asked the correction for a plan that has 2 year entry (assuming PS only). Was a solo until they hired someone full time in 2010. The person should have been eligible in 2012 according to our calculations. So we are assuming that there would be 5 full years they would need to give a PS contribution. 1. Would this be corrected under VCP? And if yes I don't think there is a cookie cutter type application process correct? 2. Would the correction be to give a contribution needed to pass testing based on the allocation method defined in the document plus earnings? TIA
  8. We have a plan that is on the Sungard VS document. Comp defined as w-2 wages. As part of the Prevailing Wage requirement they give a 3% SHNEC and the rest is given as a Profit Sharing contribution. My question is when determining the amount for the 3% SH what compensation is used? Lets say the job calls for $20 total and $4 has to be the PW benefits. Would the comp be the $20 or the $16 because that is what they are paying their employee in wages? TIA
  9. I am starting to second guess myself here. Who does the notice go to on a plan conversion to another carrier? All eligible participants or participants with account balances and terminated with balances?
  10. Have a plan that calculates their match on a per pay basis. Paid Monthly Lets assume Joe Employee makes $84,000 per month and defers 401k of $1250. Their Match formula is 100% up to 3%. My calculation shows Joe would get $1250 in match per month. My question is do we have to cap his match to $7,950.00 (265000*.03) or does he get the full $15,000.00? More specifically with respect to tres reg 1.401(a)(17)-1(b)(3)(iii)(B)
  11. We are preparing a VCP submission along with a EGTRRA document restatement for a plan that didn't restate for EGTRRA. What effective date do we use for the restatement? A date in the restatement period or something like 1/1/15?
  12. We are a TPA and have been asked by one of our Plans to gather information/ideas on the possibility of the Plan charging a "terminated participant fee". Basically this would just be a fee to a participant's account for being terminated in the plan with an account balance. Does anyone out there have this? If so how did you determine the number? Any other comments would be helpful.
  13. With the implementation of EFAST2 and the requirement to file electronically I guess the DOL assumes that everyone needs to have a computer and email address
  14. Try to get a feel for what other firms are doing with respect to the disclosures for SDBA. Does anyone know how some of the brokerae firms are handling the requirements under FAB 2012-2? Schwab, Fidelity ect? Also I see there is some general information about these SDBA that Plans must provide. Does anyone have a sample?
  15. I would also add that distribution requirements would be subject to the Plan Provisions. Many of our Plans have that you can't even take a distribution until after the end of the Plan Year.
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