JanetM

I don't see where in the post you get asset deal austin.... maybe I am just dull and thick today.

This one can be tricky. If B is not buying A in stock deal, A can termimate and distribute assets before the deal goes through. Just remember you have to vest everyone 100%. If B buys assets and doesn't assume A's plan than A can terminate. If B assumes A's plan then successor rules apply.

FJR We do exactly what you are propossing. Various union groups around the country have bargained for different benefits that are are within the 401k plan. One union plant get flat amount per hour paid, couple get percentages of comp at end of year. It issue with the TPA comes down to their inflexible systems. We solved that by calculating all contribution in our payroll systems. We don't have TPA calculate anything. We deicide the amounts, label them and TPA posts them. Blinky said it - blah blah less than 2% professionals, subject to good faith bargaining. You can give the union folks LOTS more than non-union and as long as they are subject to bargaining agreement you don't have to compare the two groups in testing. But each group - union and non-union- must past discrim tests.

Austin; Back in my public accounting days I worked with CFA who developed one. It was so complicated and the results contained so many caveats and ranges in numbers that the clients found it confusing and about useless. I think you should find out the clients primary goal in sponsoring a plan and go from there.

Sure thing! Hope it was enjoyable and educational.

What does the plan doc say? Does is say the match is calculated annually? Per payroll? We have 4 K plans - three do annual true up and one matches on payroll basis with no true up. As for threshhold to correct - if the match is done annually then you need to be accurate. Just curious, is this plan audited? Ask the auditor what is too much or too little.

Sure I don't see any problem with that - but I will change the company name. Opps, the year in question didn't give the effective percentage. You get the idea. 2003_ps_contrib_djd.doc

Thanks for answering for me austin. That is exactly what I meant. Sorry for confusing you Katieinny.

Actually, the employer could not provide any benefits to union employees and rich benefits to non union employees and still pass discrimination tests. Participation in the multi doesn't matter. In reality the employer should be cognizant that the two groups will have a vauge itdea of what the other group gets. They could be fostering a very bad environment if they play favorites. This could also result in added pressure during collective bargaining. One alternative - instead of increasing benefits by formula, offer some kind of bonus and the opportunity to defer the entire bonus.

In question 3c on the I, the point of measurement is the last day of the plan year. At that point, not in the future when you use exchange the asset for another, what is it and what is it worth. I would deem in an interest or non interest bearing interest bearing cash deposit and not worry about question 3 until you take title or sign the lease in the plan's name.

CSTS don't toss the idea just yet. I have 13 DB plans in MT with assets of about 400M. This allows me to file the 13 plans with only couple lines on the H filled in. All the detail is only done once at MT level. Believe me there is a lot of detail in this size operation. Another advantage is scale. Pool the assets and cross that institutional line and you get lower fees .... and we are not talking chump change.

We do a memo from the CFO that shows total contributions and the percentage that goes to each. This gets sent to the 100 or so locations who can either post it on the board or make copies and hand it out.

Never heard of, or seen a letter of acceptance from the DOL. I used to have 150+ clients, seems if there is such a thing I should have seen one. Easiest thing to do is get copy of check. Not that difficult to do. I also simpler than fretting over what a letter of acceptance is.

Yes you do unless you have been filing Schedule I using the 80/120 rule. The chance to skip and audit with short plan year is for plans starting up. But you still have to include all months of both years in audit.

Make that Happy New Year.

If any of these underlying plans are audited you have some additional work. There is requriement for MT footnote disclosure for assets and income. There is additonal work on part of individual plan to ensure that trustee/custodian didn't make or error (or that plan sponsor didn't give bad directions that trustee followed) posting contributions, allocating expenses, making distribution and charging the right plan. Just cause you might save a few bucks on asset management expenses might not cover the additonal work and issues that you will find. As jquzza stated, it acutally makes filing 5500s easier for me. There are couple of quirks. On MT filing you show all assets and income detail, but contributions and distributions are deemed transfers to and from. At plan level, the assets and income are one line and the contributions, distributions are listed. Some other differnences, but it does really reduce the work.

Sounds more like settlor function than plan expense. I would hesitate to pay legal fees from plan assets.

If you leave it in a CD you will be losing value long term since the interest on the CD is less than inflation. If you are worried about losses look for a stable value mutual fund. There are many funds out there to select from.

Very simplistic - but does that translate to.... Some non-profit organizations under 501© may also be defined as a private foundations under 509(a). Been a while since I looked at non-profits.

That is what I meant. You can change the match going forward but now match accrued in the past. You never take away something that has already accrued - but you have every right to change the amounts in the future.

Match amounts can be changed for future amounts. What you can't do is wait till the end of the year and change it for past contributions. Match amount is not one of the things included under the anti cutback rules. If it were PS would never be about to do anything but increase benefits.

Notify participants in advance that the plan will be terminating and merging with another plan. You will have to pass ADP/ACP test for short plan year.

Absolutely, you can change the formula at any time by amending the plan and sending notices to participants. If the target date is 7/01 you have plenty of time to communicate and amend.

We carpet bomb them with large envelopes full of tissue paper booklets, SPDs, and SMMs via the US mail. Kind of like AOL used to do with software CDs. Adds expense, but is easiest way to get information to 20,000 participants in just about every state. HR at large plants frowned when we suggested shipped the stuff to the locations and having them hand it out.

Effen, my first guess is that they realize they won't make any money on the little accounts.