ratherbereading

I'm not sure. We just took over the plan from another TPA. The previous 2 years there was no match. Not sure before that.

The document does not specify!

Thank you in advance for all responses -- Client began matching in July 2014 (plan was not amended - that's just when they began matching again). One HCE had maxed out at $17500 in June, therefore the client did not give him a match contribution for 2014. Is this allowable? Match is discretionary and there is a discretionary cap on the match. No conditions to share.

A final question. In a DB/CD cross tested plan - what if they did prepay the Gateway to terminated participants, and then the PS plan decided not to make a contribution? Wouldn't that be an issue? I am assuming just because the Cash Balance plan has to make a contribution, the PS plan does not. However, in giving the terminated participants the Gateway early, now they are obligated to give other eligible a contribution, correct?

Thanks rcline - good point about the W2s!

Thanks ESOP Guy. Yes, the client does want everyone paid out immediately because a lot of their employees leave the country as soon as they are terminated, not understanding they have money, then the client can't find them. The plan does state ....distributions as soon as administratively feasible. And they have to get a forfeiture allocation at the end of the year anyway, so there is no advantage that I can see in prepaying their Gateway.

HI Tom. This isn't a safe harbor plan. The client wants to avoid paying the terminated EEs out twice - once with their normal distribution then again when they get their gateway. However, they will also get a forfeiture allocation at the end of the year, so they are going to be paid out twice anyway. The client is making this way too complicated. I can't see using the forfeitures to make the gateway, because when they get paid out, part of that will be forfeited.

Follow up question. Suppose someone terminates, gets their gateway, then is rehired. Wouldn't they need an additional gateway contribution?

Thank you, John!

Hope Red Sox fans are enjoying their last place team! Yankees all the way!

I have a client who has a combined PS/DB plan. There are terminated participants who are getting a Gateway contribution. The client wants to pre-pay the Gateway contribution on the PS side using the forfeiture account every time someone terminates vs. waiting until the end of the plan year. Is this allowable? So for instance, someone terminates on 4/11/15. He wants to give them their 5% and then process their termination. Thank you-