Tom Poje

I have seen a number of cases in which the document says distributions occur after the year of termination, so make sure if these people can even be paid out at this point in time. - just tp prevent such a situation as you describe from happening. I have also had to deal with cases in which once an individual has his account closed out, that is it, and it is a pain to get the additional amounts credited to the individual paid out. (The investment house simply won't touch the $) So I know how you feel. Obviously a contribution can be made at anytime (you don't have to wait until after the end of the plan year), but you establish a possible dangerous practice by allocating a contribution to one individual over another. e.g. now this individual has the $ in his hand while others don't. certainly if the individual was an HCE you can see where this would lead. Or, if the plan was a standardized document, and the ee you refer to has over 500 hours, then what are you going to do? If the company were to make an additional profit sharing contribution, then you would still have to cut an additional check. Again, not likely to happen but food for thought. In fact, suppose the plan you referred to was not a safe harbor. Would you pay him out an additional amount assuming the plan would make a for example a 5% contribution? All that being said, and of course I could be wrong, I don't think you can't establish a policy like that...maybe get it in writing since the safe harbor contribution is required. well maybe, since now you have the option of saying 'we might make a safe harbor contribution.

The instructions say to use 'nonelective'. I bet the DOL had fun last year 'cuz I bet we sent some out 401(a) or something similar.

you will have to do the following when calculating the 415 limit: ESOP runs 10/1/99 - 9/30/00 Use that contribution plus the amount of deferrals made from 10/1/99 - 9/30/00. (It doesn't matter that the 401k is calendar)In other words, you use some deferrals from one plan year, and some from the other plan year. you would also include the match and any ps contribution deposited in that time frame. Then you have to run the 415 test on the 401k plan. Plan year 1/1/00 - 12/31/00 and include any ESOP contribution made during that time period. That is probably the easy one to test.

more important, what type of ESOP? If it is a leveraged ESOP, there are special rules to consider. (It is possible that only principal paid on the leveraged shares counts towards 415 limit) It is possible that the document(s) will indicate which plan returns excess 415 limit.

403(B) cannot be combined with other IRAs, same rules as defined contribution plans

I agree with the above - QNECs and QMACs are the only thing I have ever seen used as a booster contribution. The only thing I have heard the term catch up referred to is a match. In particular, an 'extra' match at the end of the year. For example, plan matches 100% of the first 3% deferred. Company is putting in the match monthly. For the first 6 months an ee doesn't defer. For the last 6 months he defers 6%. If things are done strictlt monthly, he would only get 3% each of the last six months, so he needs a catch up to follow the terms of the document, which probably looks at the whole year when describing the match formula. but be careful, some documents do specify match by pay period as a formula.

If you are talking about Report Writer reports (Crystal reports) you can do anything you want. printing by division is one of the easier taks. Hey, this comes from an idiot at crystal, but someone who tinkers with the Quantech reports. anyway, select "Reporting" from the tool bar, select "Report Writer". "File" "Open" select the report you want, e.g. "Cnsverr" on the left side of this report you should see the words 'Page Header' scroll down to the next solid black line. Keeping your cursor in the area under the words 'Page header' watch the bottom right corner of the crystal report (it should say Page header). When you just pass the solid black line, the bottom corner will say 'Group header #1 - RPTEE SORTNAM (if you go to far it will say "group header #2 - ..or something else" make sure it says Group header #1. click on the Right mouse and from the menu select 'change group' you can now change your sort to 'division'. you will probably want to change group header #2 to sort by name afterwards. hopefully I haven't left anything out. you will probably want to save as another report when finished. this will require you to print under custom reports, but that shouldn't be a problem. good luck! if you get stuck, ask! If you are in Southern Users Group, and can make the meeting in Aug, thats one of the tips I hope to cover.

there is no such thing as using a look-back or not. the guy (or gal) either made $80,000 or not in the prior year. end discussion. That is the whole concept of pension simplification. you know ahead of time who an HCE is. you don't wait til this year to find out. e.g. suppose the guy made 6666.66 a month in 1999. you would have no idea until the last day of the year to find out if he was an hce. Pension simplification did away with that. the only exception to the rule is possible change in ownership during the year.

Count only those deferrals made by the employee for that portion of the year he was a non union member. (and I suppose if need be, then count only that portion while he was a union member (if you have an HCE union member and need to test union members as well) so, I think that you are correct, although I don't know if I would use the term 'prorata', rather comp/deferral as union memebr, and comp/deferral as non union member might be better terminology.

Way back when, there was a discussion on this on PIX (pension information exchange) There were two lines of thought: 1. add any new people as of 1/1 or 2. make sure your count at beginning of year equals count at end of last year. the instructions seem to say 1, but a number of administrators said they did 2, because they were tired of the gov't 'audits' because the counts were different from one year to the next. Note: that doesn't say it is correct, I am simply reporting what some administrators claim they are doing. I guess the best solution would be to have entry dates of 1/2 and 7/1. Then the count would stay the same and eliminate the nonsense.(or entry date is 12:01 am, but the count on the 5500 is at 1 second after midnight.)

technically, the answer is Yes, but you would never pass discrimination issues. In other words, in addition to the ACP test, you have to test each rate of match as well. Since no NHCEs benefit under the higher rate, that particular rate of match would fail the ratio percentage test.

perhaps. If the NHCEs deferral % has increased dramatically over last year, you might have a good reason for switching to current year [especially if you were really limiting the HCEs in the current year.](as much as I prefer to use prior year) but for the most part, if you are going to use prior testing, there seems to be little reason to do a mid year test. save time and expense!

Aug 6 and 7 (Fri / Sat) in Orlando includes Dinner at Bergamos (Italian Resteraunt, singing waiters and waitresses) Fri Aug 6 1:00 Welcome, misc 1:45 - 2:30 ERISA 404© Education Techniques 3:00 - 4:30 Quantech Tips from Tom Poje 6:00 - Dinner at Bergamos Sat Aug 7 (Corbel Instructor) 8:30 - 10:00 Quantech Defaults 10:15 - 11:45 Transaction Processing 11:45 - 12:15 (Fidelity Resource Select) 12:15 - 1:15 Lunch 1:15 - 2:45 Distribution processing and data entry 3:00 - 4:30 Loan Processing For more information, contact Maggie Heffernan (770) 641-1429 This meeting is open to all Quantech Users - not just members of the Southern Users Groups! I'm bringing copies of the Quantech Dirge song, along with my version of the ADP reports for Crystal.

Try 'The ERISA Outline Book'(4th edition, probably 3rd as well). In chapter 11, Part J there are 3 possible options how to handle.(not just merged plan, but plans with different years as well) I got a headache just skimming the material (hey, its 8:30 in the morning, my brain isn't fully functionally yet for that complicated a scenario)- there is no way I can reduce it to a few paragraphs. Personally, I consider this book a 'must' as a reference. lots of examples if you are not familiar with this book.

lets see if this is what you want. entry dates 1/1 and 7/1 ee hired 3/1/97 so 1 year later is 3/1/98, you want entry on 1/1. if ee hired 4/2/97 1 year later is 4/2/98, you want entry 7/1. Correct? suppose you code system (non retroactive entry, but 9 month wait.) ee hired 3/1 --> 9 months later is 12/1, so enters 1/1. ee hired 4/2/97 --> 9 months later is 1/2/98 (this date is beyond first enry date) so enters 7/1, which is what you desired. I think this will work, there might be problems for ee hired on 1/1, 4/1,7/1, and 10/1, but even those might work. I'm not sure. *using 9 months instead of 12 months for waiting period will 'fail' if ee terminates between the 9th and 12th month of hire, but its the best I can come up with to get around your situation. By the way, the same logic applies if you have a 401k with immediate entry, but 1 year wait for profit sharing. e.g. If you have quarterly entry dates, enter 15 months under profit sharing waiting period. (this is 1 year wait plus 3 months for quarterly) [This message has been edited by Tom Poje (edited 06-29-99).]

forfeitures: I am not sure where the bug lies. I too have had some problems and I am doing dollar accounting. I modified some of the Quantech reports to separate the contributions and forfeitures into separate items. There are 'two' gains items on a lot of the reports. E.g. : sum gains/loss (usually supressed) and dispSsUnrealized gainAmt. Since I am not doing share accounting, I reversed these items...suppressed the unrealized gain and unsupressed the gains items. This solved my problem. Since I am a Crystal 'tinkerer' rather than an 'expert' I figured I might have done something wrong. However, since 'daily' also reports a problem, it sounds like a bug might exist, at least at the report level- but without time to look at deeper I don't know. In the account screen are forfeitures showing as both $ and shares? 2. Eligibility - not sure what is meant here, 'clicking on the first box'. which one? I have had very few problems in this area, but then maybe I have a better understanding of what happens when you click on the different elements. (Lots of experience on this one going back to the old Pentabs system) give an example and maybe I can help. (sorry, thats all for now)

If there are some issues that you feel should be addressed, but don't think are worth discussing on this forum, please feel free to e-mail me directly. There is a national council users meeting coming up, and I will pass them on there. One of the purposes of this meeting is to set possible priorities for future releases. That's right. get your suggestions in now. can't say it will help, but it can't hurt.

I prefer them being shared at a user group meeting. mainly cuz it hits a bunch of users at once, and there are certain items about the reports that should be discussed...e.g. make sure plan specs are coded this way. Not that I don't trust people to read notes, but it helps to hear a topic discussed. (Plus I won't have to email the reports to a gazillion users) have head of the user group send me an e-mail. (This applies to all user group heads, since I imagine other meetings are coming up shortly)

Since my boss is the 'Empress' of the Southern User Group, I can say the following: always lots of goodies. I did pass out some Crystal reports that do the ADP test. Someday I hope to get them attached to our Web site (LD&A) so anybody can have access to them. These reports sort alphabetically, and include a column listing reason why an ee is excludable from ACP test. Also have a version which lists ADP results only - if there is no match. These reports do not offer suggested corection if plan fails (yet), however they do at least look like all the other crystal reports you give to the client. also gave out a program that checks your data base for vesting schedules. with update 5.0, the vesting schedules have been moved/changed, etc. If, for example you have a 2/20 vesting schedule, but the predefined table option says 'none', then the system creates a new predefined vesting schedule for you and calls it your plan ID. I give a heavy recommendation towards naming all vesting schedules if possible before converting. Those were probably the main items of interest as far as the Quantech end of things goes. The next meeting is Aug 6 and 7 (Fri/Sat) in Orlando. Friday afternoon talk by Fidelity and then I will give a talk on tips and tricks on the system. Saturday will consist of 4 to 6 sesions given by a Quantech representaive (bring your tomatoes) Amongst the topics covered will be: Transaction processing, distribution processing and loan processing. More details shortly! (Reports are availabe from Atlanta, but if you are going to Orlando in August, I will have them available again.)

Not sure what you are asking... do you mean each year : you want to recalc the particpant and not the beneficiary (or recalc the beneficiary and not the particpant) if so, I created a worksheet to do that, 'cuz it drove me crazy trying to figure that out.

and a reminder...first subtract deferral, then limit comp... e.g. if ee makes 200,000 and defers 10000 you still have 160000 to play with. (200,000 - 10000) not cap at 160,000 then subtract 10000.

well, the cpi for May has been released...no change from April...it stands at 166.2 assuming the value remains constant for the next 4 months (or at least assuming it won't drop) the following are the 'estimates' for next year: 166.2 / 145.7667 = 1.14+ comp limit 150,000 ==> 171,026 use 170,000 db limit 120,000 ==> 136,821 use 135,000 our favorite limit 30,000 ==> 34,205 still stuck at30,000 (maybe next year) deferral limit 9240 ==> 10,535 use 10,500 hce limit 80,000 ==> 91,214 if I understand the rules correctly, this means to be an HCE will now take 90,000. but since that applies to the prior year, does that mean 90,000 in 1999? anyway, all the above is based on my understanding of how things work. in addition to the prior message on how to obtain the CPI, you can search the WEB under consumer price index as well.

and if the plan happens to be top heavy, you now have to provide top heavy minimums for more employees, those who wouldn't normally be in the plan. Be careful of that. By the way, disaggregating employees is not new in 1999. you have been able to do this for a number of years. What is new, is that all HCEs, regardless of length of service are treated as having more than 1 year of service. and even that appears to be optional. the new rules did not do away with the old rules of disagregating ees. (that is, you could still count an HCE with less than a year with all other employees with less than a year, but why do an extra test when you don't have to.)

you have to follow terms of the document. in other words, if alloaction is comp to comp you cant simply give one owner 25% and another 19%. however, if owners are in classes, then you could give different contribution rates to each owner.

there is no easy answer. (by the way, no, I am not or ever was a Datair user) anyway, as I said, there is no easy answer. if you are in the daily environment, Quantech is probably the way to go regardless of cost. It has 4 or 5 years in windows under its belt. In other words, it is probably the most stable system out there. It is impossible to say what other systems will charge when they fully convert to windows/daily environment. however, if you are a small operation, then the costs may not make it worthwhile. there is also the learning curve of a new software - and I know plenty of people (being honest) who have had a hard time with this. and the costs of equipment - but you probably know that already. too many factors to consider. if you are not doing daily, but simply plan processing (like me) Quantech is more than enough. the biggest advantage is the ability to customize reports. My boss can't stand me so she 'rents' me out from time to time to other users. (it helps when you really know the system fairly well. If you want further info, please feel free to email me. tpoje@lda-fcpa.com