Mike Preston

Why not?!? I have lots of DB plans with rollovers. Just fire up an excel spreadsheet to keep track of the separate pools.

Thanks, everybody. As I mentioned in the other forum, it has been a hectic few days. Appreciate all the kind words.

Thanks, everybody. Much appreciated. It has been a hectic few days. I have new found respect for those who seem to effortlessly remember all they should in an acceptance speech. No matter how much one prepares for it, when you stand (or sit) there in front of your peers the words just don't fall trippingly off the tongue.

Correct.

Clearly not an insignificant failure eligible for SCP after the two-year period. File VCP or it remains subject to disqualification.

Happy Birthday, Dave!!!!!!

What's to address? You have it right: it is an ADP option, not a coverage option.

I said it doesn't recognize the waiver for funding purposes.

Are you sure about the "exiting" part of that? Seems to me the option has to be free to exercise even in the absence of the deck being re-shuffled.

Once you get the hang of it, Access still gives you freedom.

dBase was much easier to program in than FoxPro.

Majority owner only when it comes to PBGC. Period. Full stop. IRS doesn't recognize majority owner waiver for funding purposes. Period. Full stop. IRS will consider allocation of assets on plan termination based on majority owner waiver as non-discriminatory and LOD is no probem. I like to amend plan terms before plan term to make sure allocation of assets on plan term based on majority owner waiver doesn't conflict with plan document language (which is typically ratio to PVAB if non-integrated or 4044 if it is).

ESOP Guy, are you sure? Maybe the question should have been: "... meet any kind of design based safe harbor without further testing?" because 1.401(a)(4)-2(b)(3) sure seems to be a safe harbor as described, but only if 1.401(a)(4)-2(b)(3)(B) is satisfied (average of HCE's must not exceed average of NHCE's).

Thanks, Tom.

Well, it is that time of year again. The July CPI was published a few hours ago, so I imagine Tom is busy updating his spreadsheets. To get the ball rolling: It looks like we can lock in the 2018 limits as follows: DB $220,000* DC $55,000* Comp $275,000* 401(k) $18,500 HCE $120,000 Key employee $175,000 Catch-ups $6,000 SIMPLE - $13,000 Those marked with an asterisk have a slight chance of not increasing as shown. For that to happen the August CPI would need to decrease 1.58 and then remain level at 243.206 for September or if August remains level at 244.786 then September would need to decrease all the way to 241.625 (a decrease of 3.16). To put the 1.58 and 3.16 raw decreases into perspective, the CPI did, in fact, decrease from June to July by 0.169. If you are a fan of smoother rates a decrease of 1.05 from July to August and another decrease of 1.05 from August to September would also result in those three limits not increasing. mike

So you are arguing for a required DRO modification if the AP moves?

versus what?

Hardships must be limited to vested.

You can only do that if the SPD says that is what the Plan does.

I agree. If you can have Relius do it, DO IT! For 4,000 people there ought to be enough in the budget to pay somebody on staff to develop a spreadsheet, if you can't get it from Relius.

Agreed.

Do the orphan plan provisions of EPCRS help?

Is it just ADP? Or ADP and ACP?

How many bodies? I have a spreadsheet but I haven't looked at it in years so I'm reluctant to send it into the wild. I probably got it from Tom P.

As do I.