abanky

how are people with cash balance plans with AE interest defined as 417(e) proceeding? Changing definition of credited interest?

These are questions, I think I know the answers for, but I need back up for the 2008 Plan year, does that mean the 2008 Applicable Mortality Table as described in RR 2007-67? Yes for the 2008 Plan year, any db plan that defines actuarial equivalence mortality as: the "applicable mortality table" means the table referenced in IRC Section 417(e), must use the 2008 AMT as AE? Yes Does anyone see anything wrong with these statements? does anyone see anything wrong with having a rotating mortality table for AE?

does the 401(a)(26) Minimum benefit have to pass in the cb alone or does the aggregate allocation of the nc and cb have to pass it if we always test together?

justed looked and we do use the 7.5% to 8.5% to determine the MVAR. I was worried for a minute.

for cash balance plans you have to use the 7.5% to 8.5% range?

I really don't know how to propose this question... but for 2008, will cb have to test based on the segment rates?

Has anyone had a plan where they were 100% positive that a determination letter was issued for, but can not find it? Is there anyway to contact the IRS and receive a copy?

was there guidance published on how to calculate the min. lump sum? I can't find it in all the piles of stuff i have around my cube

Jim, Thank you for your comments... what about the document submission and all that mess? Andrew

we are using relius government forms... it works pretty good for the most part

so the employer gave us the wrong company ein when we submitted the plan and for all the plan admin for the last couple years... anyone ever have to correct the corporate sponsor EIN?

If a plan terminates in 2006 or 2007 and the payouts are in 2008, does the plan have to pay the lump sum greater of Gatt factors or PPA factors or just Gatt Factors or just PPA factors?

what's the process?

"technically" you pay the premiums for the coverage year at the beginning of the year. If a plan terminates in the middle of the coverage year, would the sponsor be able to receive a refund? if so how do you request this refund? is there a form or just a letter?

Tom, Thank you very much.

any comments... ideas... theories?

I'm thinking that because they get any contribution, they then become subject to the gateway and might have to get an additional 2% or more

I have a cb with two year eligibility and a nc ps with two year eligibility. My SH 3% contributions have a 1 year eligibility. Do I have include the employees who are just receiving the SH 3% in my cb/ps cross testing?

1) if i create a NC/CB where the retirement age is 65 for the CB plan. Can I test them both at 65? Yes... use the higher of two retirement ages for your testing age. (did i answer my own question correctly?)

I have an integrated ps plan which has a retirement age of 59 1/2, normal form is lump sum at retirement, but allows annuity options. Also, the death benefit is exclusively annuity forms for over 5000. My questions are: 1) if i create a NC/CB where the retirement age is 65 for the CB plan. Can I test them both at 65? 2) if 1) is no, how complicated is it to change the retirement age of the PS plan to 65. Thanks in advance, Andrew

I have a owner who owns 100% of two completely separate companies, Clinic A and recently purchased Hair salon B... he currently has a plan that covers only Clinic A... Am I correct in telling him that we have to test the eligible employees for both companies for coverage testing? Can I get the reg #s that show yes or no?

1.401(a)(4)-3©(3) --- "safety valve" I haven't been able to get any good explaination regarding this reg... anyone have any comments?

Thank you Tom, I see that now in the reg. that hours aren't a factor. I was thinking just 3% otherwise noneligible. I worded that wrong. I was am converting the cb to equivalent dc dollars.

Plan is definitely Top Heavy for 2006. Both NC and CB have a 1 year eligibility rule for contributions and we are giving all active non-keys with over 500 hours, 5% between the two plans. My question is this... the 401(k) enrollment is immediate with dual entry... so if a participant enters 7/1/06 and is eligible for deferrals, has over 500 hours, but is missing the one year for contributions... does he/she have to get the TH minimum?

I have a plan where the participants individually invest... and the plan sponsor lets them invest in about everything under the sun (all legal of course)... They get quarterly statements from all their investment companies.... to comply with ppa, do i have to have a combined statement with the PD and vesting language or can i send a notice explaining that they recieve statements from so and so and the newly required language?