abanky

Can this plan file the 2014 5500-SF? Participant count: 1/1/2012 - 99 Filed 2012 SF 1/1/2013 - 117 Filed 2013 SF 1/1/2014 -- 108 ? I believe they can keep filing the SF until they get over 120 participants. 1. The plan (a) covered fewer than 100 participants at the beginning of the plan year 2014, or (b) under 29 CFR 2520.103-1(d) was eligible to and filed as a small plan for plan year 2013 and did not cover more than 120 participants at the beginning of plan year 2014 (see instructions for line 5 on counting the number of participants);

I see your point about abuse. Consistency is best in all cases, imho. I would see no problem with 200%, should I.

so i can give 20k and have a 401a4 allocation rate of 200%

New Comparability Plan: Comp from date of participation. Employee enters on 7/1/2015, and comp is exactly half of his full year. let's say full year is 20,000, partial is 10,000. Can the participant receive an allocation of 20k and therefore have an allocation % of 200%?

That was what i was thinking (about only one ABPT)... then i thought, hey, if i failed the ratio percentage test on the group tested by allocation method, how would i satisfy the ABPT on that portion of the testing population.

I'm trying to understand some of the fine points about this.... 1st, the whole plan passes 410(b). 2nd, I split the plan into two groups. each group passes it's own 410(b) ratio test. 3rd, i test half the hces on an accrual basis and half the hces on an allocation basis. My question is if for the each group of hces, if i can't pass the ratio % of the rate group test, do i use the Plan Total 410(b) ABP% for accrual, for allocation or each has to use the 410(b) ABP% based upon testing method used for that restructured group?

Further Question... if the participant is an excluded group for employer discretionary contribution (because of location), but eligible to make deferrals, do they get top heavy? and does the particpant then get thrown into the gateway calculation?

Thank you all for you comments. Andrew

What about 404(a)(6)?

The plan sponsor met the minimum funding requirement prior to 9/15, but then put in an additional 50k in the plan today towards 2010. I know this 50k can't be put on the 2010 SB, but can it be included on the SF. I think it can. Also, does the 50k (reduced with interest) increase the prefunding balance as of 1/1/2011? again, I think it does and i would show it on the 2011 SB Part II 7(b) with additional explanation attachment. Anything wrong here? Andrew

Can anyone verify that I have the basics down about a 401(h) in a db plan? Assets held in DB plan Assets can't be used in valuation in DB plan Formula for amount set aside in 401(h) is in the document. Amount for each participant per year reduces amount available for DC plan Formula can't be discriminatory, but are they able to be tested in a 401(a)(4) basis. That's all i know now. What other main points am I missing? Andrew

I didn't think it was combined. Thank you very much you guys.

is 84 table = 94 table?

Anyone have the factors out there? I have it for male and female, but not unisex.

1) the plan doesn't allow lump sums if the pvab was ever over 5k. 2) anyone ever deal with a Terminal Funding Annuities?

The plan sponsors are sure they don't want to pay lump sums... they have no problem paying 140% the lump sum payout value to make sure their ees have a pension at 65. (i wish i had a job with them) Follow up question, are their annuities that are out there that allow a plan to terminate and guarantee the participant his/her nrb and make it so they can't touch it or sell it to jg wentworth? Also, if that's not possible, can a plan hold annuity policies for all participants in the plan and be guaranteed that they will never have to make another contribution?

Believe me, i've told the sponsor of the additional cost... my question is if someone is 35 now with a 1,000 single life benefit at 65, once the participant hits 65, would they be able to choose the forms of benefit (all ae) that is offered by the plan, such as J&S. Also, the plan does not have a death benefit for single employees, if the participant is single now and gets married before they take the annuity do they still get the J&S option of the plan. Also, what about ER? Again, i have never had a plan do this, but i would think that the annuities would have to be purchased with all the assumptions of the plan (at a way higher cost of course)

I have a plan that wants to terminate. The plan does not offer lump sums... the plan sponsor wants to purchase deferred annuities for all participants. Am I correct in thinking that the annuities must include all rights and features as stated in the plan document?

I like it. Andrew "Deuce"

not pbgc covered.

HI Andy, All three are majority owners. Family business.

Thanks very much, Andrew

I have a plan with only hces (majority owners)... the plan is underfunded.... can Hce A waive part of his benefit, Hce B waive part of his benefit, and Hce receive an increase in his benefit? They want this to happen so each will have the same pvab at the time of distribution. My initial thought is no.

Nm, you are right... i'm chalking it up to monday morning

follow up... there shouldn't be a tnc for the 2011 plan year. correct?