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Mike Preston

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Everything posted by Mike Preston

  1. Times two up to two plus two over two until you get to 2 * 2 * 2. Then it's (100 + ( 5 * 5 )) / 100. If Tom were here he could sing it to you.
  2. Play close attention to top heavy benefits.
  3. Why don't you just do the test?
  4. Keep in mind that 417e has favored lump sums in DB plans for quite a while. Dramatically!
  5. It is allocated as an employer contribution. If employer contributions to your qrp are subject to qjsa then yes otherwise no.
  6. I still think Lou had it right. It wasn't the first time and it won't be the last time that a pension distribution is the quote unquote solution when a distribution is made from the plan on a whim.
  7. While I agree that termination as of 12/31/2021 solves all problems, the plan termination does not establish a short year for non-discrimination purposes.
  8. But be aware that it is highly likely that the employer contribution to the K plan must be 6% or less of net compensation or else the plan sponsor will run afoul of 404(a)(7).
  9. If end of yr valuation, sure. If it's beginning of yr valuation then you should check with your actuary.
  10. Everybody's administrative software (DATAIR, ASC [as shown above by C. B. Zeller], etc. should have the ability to generate the factors necessary to produce the disclosures. Here is a screen shot of my program confirming the 252.208 factor.
  11. Just because the compensation definition fails doesn't necessarily mean that there is a failure. Just do the test using a non-discriminatory definition of compensation and see if you pass. If you do there's nothing to do. If you don't then the 11g amendment looks good.
  12. What part of escalate is unclear? Call them back and if they insist on silliness your response is to request a conversation with their supervisor.
  13. Do not appease. Escalate!!
  14. Yes, it's a cut back. No can do. You can change the interest crediting rate on hypothetical allocations not yet made.
  15. Mike Preston

    SMM

    I'm sure it's obvious to everyone else but can you tell me what capital p capital s stands for in this context? Your name? Are you talking in the third person?
  16. Somebody should be pointing out to this doctor and his accountant that he can't do what he's been doing! If the IRS comes in and redirects how things should have been he's likely to have a nasty surprise. Somebody ought to tell him.
  17. I think it's meant by the poster to say something like "See, I did my research and couldn't quite find the answer."
  18. I can't believe it matters all that much. Doesn't it depend on the partial age? That is, for simplicity sake, if the partial ages between 0 and 1/2 then one method will give you lower overall mortality but if the partial age is between 1/2 and 1 the other method will give you lower overall mortality. I have a spreadsheet somewhere that has a selector based on either UDD or CFM but I haven't dusted it off in years.
  19. Are you sure there isn't a provision for a contingent trustee?
  20. Extremely pedantic comment: MP also.
  21. Ilene wrote what she wrote before the update to epcrs. She implies strongly that since the requirement to benefit everybody has been eliminated it very well may be possible to retroactively adopt as an 11g amendment or as an SCP amendment. I didn't check the effective date of the change. That might change things.
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