Tom Poje
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Everything posted by Tom Poje
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you will probably have to do some minor tweaking. I beta tested 5.0 and tried running a few customized reports. they worked, though, for instance, I have one with a graph, and I need to go in an edit the scaling used on the graph. I've seen oracle print ages 65.00 and things like that. other than that, my understanding is that things convert fairly well - thank heavens!
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"any reasonable method of rounding or tie-breaking is permitted as long as it is uniformly and consistently applied" 1.414(q)-1t-Q3 2b in other words, if you have rounded down for 3 straight years, don't all of a sudden round up (to pass) just cuz you fail if you round down. That is not consistent. also, on your body count, remember the guidelines are minimums. if you want to count everybody (e.g. rather than exclude those with less than 6 months) you can
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Contact: John Gingas Financial Technology, Inc. 517 351-8600 jpgingas@ix.netcom.com He might not be the head of the group, but he can certainly get you pointed in the right direction. He 'drafted' me for the last meeting in INDY. Tell 'em I said Hi! By the way, good move! Get involved with the group, I don't think you'll regret. (If I remember, you said you were new to the system) Feel free to pick anyones brain if you get stuck!
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Now that I have your attention..... Have you ever longed for a Crystal version of theADP /ACP test? I'm giving away one such version at the next Southern Users Group meeting being held Friday April 30,1999 in Atlanta. (Details on the report below) Souther Users Group Agenda: 8:00 - 8:30 Continental Breakfast 8:30 - 9:00 Business Meeting 9:00 - 10:30 Document Update, emphasis on safe harbor plan. Instructor is Robert Richter from Corbel 10:30 - 12:15 Quantech 5.0 Update, instructors: Tom Poje, Lorraine Dorsa 12:15 - 1:30 Lunch, sponsored by Manulife 1:30 - 4:00 Autodoc Update and training, Instructor: Beverly Jackson The group is planning on dinner afterwards. The group has reserved rooms at SWISSHOTEL in Buckhead. 149.00 a night, call (800) 253-1397 for reservations. Rate is guaranteed through April 12. Hotel is accessible by MARTA from the Airport to the Buckhead stop. Nearby Hotels: Holiday Inn $99 per night. (404) 264-1111 (next door to Swisshotel Marriot $109-$119/night (404) 869-0818 (across the street from Swisshotel ............ membership is $50 annually (per firm) future meetings this year: Orlando, FL Aug 6-7 (2 day) Columbia, SC Nov 13 nonmembers who wish to attend (or those who want to become members) should contact: Maggi Heffernan (770) 641-1429 Hey, last year we had 2 people from Seattle attend! .............. Anyway, no guarantees on my ADP report, but this is a Crystal version, it sorts alphabetically, and will tell you who is excludable on the ACP test.(but does not do statutory exclusions at this time) There is also a version for plans with no match contribution. Report seems to be working fine, but one never knows what exceptions might arise. Anyway, I'll bring that and a bunch of other reports to share. By the way, I will be at the hotel Thursday night, if someone wants to hash out some Qtech questions. Hope to see you there![my e-mail is lda@leading.net ] thats the letter l not the number 1.
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Treatment of deferrals after amendment excluding cammisioned employees
Tom Poje replied to a topic in 401(k) Plans
the suggested method I have been given previously has been: Give deferral $ earnings back to participant. 2 ways to handle: 1. direct distribution and 1099 r or 2. cheat. use the amounts to offset ongoing contributions and have employer reimburse employee (run it through payroll as negative deferral so toatl deferral for year = 0) hey, there are some creative suggestions I have run across through the years. of course, step 1 is to check the document and see if it offers a solution. Depending on the document, you might be able to call them for support as well. these employees are treated as includable and not benefitting for 410(B), so don't forget that test. -
possibly they have a 242-b election, but that is the only other exception I know of.
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Assuming ees A-F are all eligible, you have 422,000 in compensation 15% is 63,300. if the two doctors get 30,000 a piece, that leaves 3,300 to spend amongst the others. that is 3.23% of pay, enough to cover top heavy, but won't be enough to pass nondisrim. That is why I suggest a money purchase as well. It will be tough (I think impossible) to get 30,000 to the owners without a second plan- at least at this time. A $50 minimum contribution is a nice concept to employee D, but remember, it won't cover top heavy.
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don't worry, there will always be users who load updates right away! and remember, one of the nice things about this forum- it is a great place to post discovered problems. so please (to all), if you trip across something post it so others know.
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Things to consider: if amount of contribution is never going to be a problem, the money purchase is probably the way to go. Based on the comp figure provided, they could never get 30,000 a piece in a ps plan due to 15% limit. since plan is top heavy anyway, consider a 3% Money purchase, and a profit sharing plan by group. if doctors get 30,000 with 160000 in comp, they have received 18.75% of pay. if you allocate 7% contribution to rank and file, a 10 year difference in ages between them and the docs is needed. e.g. 1.085^10 = 2.26 2.26 * 7% = 15.827 with permitted disparity the value would come close to 18.75. By the way, if you have a 20 year difference in ages, a 3% contribution usually works.
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Using elective contributions to pass ACP test under prior year testing
Tom Poje replied to a topic in 401(k) Plans
I don't think it matters. suppose my hce this year is 6 and 3. my nhce for last year was 5 and 1.4 (ADP and ACP) using elective deferrals isn't physically done, its really on paper, so I simply 'shift' 1 point from adp to acp for the NHCEs and pass the test. or looked at from another point of view, even though my values last year were 5 and 1.4, i didn't use those in last years test. so technically last year I had 4 and 2.4 or any other type of shift. I don't know of anything that says I have to announce ahead of time what my shift will be. (but I have been wrong before, so I have no cite to give you) I suppose if last year you used current year testing method, you might have problems, assuming you used 5 and 1.4 to pass test last year. I'm not sure about that scenario. -
am doing some Beta testing. currently the biggest problem I know of is that the system won't run a transaction if a participant goes over the 415 limit. supposedly that is being changed. there are some fairly big changes. Vesting schedules are no longer part of plan specs. they are now a separate table. user definable elements have been increased to 100. adp test and nondiscrimination will do statutory exclusions, and you can also exclude union people from the adp test. if you have two accounts, lets say, both subject to vesting, and both are coded the same fund (e.g. CASH) [perhaps one is individual investment]then you have to add a description to the accounts to distinguish them. There is a field to do this, but just be aware. lots of other changes, but those are a few for you to ponder.
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Dan offers good advice. In regards to updates, (such as the upcoming 5.0), it never hurts to hold off loading for awhile. Let other people discover the problems that may exist. For particular fixes, you might as well load fairly soon. If something was broken and a calculation wasn't correct, you probably aren't going to lose ground if the fix broke something else. The biggest danger of some 'fixes'? Sometimes we will process a plan at our office for another Quantech user. Sometimes one so called minor fix will result in an incompatibility between two systems, and therefore data can't be transferred unless both systems have the exact same fixes. Absolute best recommendation - Join the user group in your area. especially being new to the system. you will get lots of help and tips and tricks.
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If you have a proposal system that will allow you to export data, obviously you can import the data into Quantech if you so desire. so, technically, any proposal system has the potential of being 'compatible', at least as far as census data is concerned. Just like Quantech reached an agreement with Hyper-Prep for Govt Forms, there is a possibility of a similar thing happening with a proposal system in the future. I know they are considering it, but there is no time frame and maybe it will never happen. About all you can do is wait and see. I know a number of people have asked the same question you have.
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I doubt there is any cite. A plan doesn't have to allow in service withdrawals at all, so I imagine it can put whatever restrictions it wants to on them. but of course, we are talking regs and IRS, so you never know.
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Top heavy percentage - 60.71% rounds down to 60%, so plan not top-heav
Tom Poje replied to Jean's topic in 401(k) Plans
I would agree with above advice. There is nothing in the regs to suggest rounding. This has been argued on the PIX bulletin board as well. (PIX is pension information exchange) When that close, it is time to verify everything - e.g. were profit sharing contributions included in the total? Since most are made after plan year end, they should not be included. (You don't count contributions that are not required - only in year actually made) how about previous distributions. most calculations I've seen includes distributions made over last 5 years. actually, it should be from date of termination. example - if ee quit 20 years ago, but received a distribution this year, would you include the distribution in the balance? Hopefully you haven't been counting it for 15 years, why should it magically reappear. remember, you don't count balances of people who didn't perform service for 5 years. -
Code Sec 404(a)(3) Deduction Limit - Can you count Comp of a Participa
Tom Poje replied to a topic in 401(k) Plans
no one knows for sure. the conservative approach is, of course, not to count ees who do not defer. however, Sal Tripodi in the Erisa Outline Book puts forth the following argument: ees who are eligible to defer (even though they do not) are treated as benefiting for coverage purposes and are reported as participants on the 5500 as well. It seems reasonable to include their compensation even if they do not receive allocations. -
which items are trying not to import?
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I don't do daily, but have a number of years experience on Quantech and its precursor Pentabs. System accomplishes everything I want, well, of course not. It does the basics very well, with update 5.0(coming soon) it will now do statutory exclusions, which is really the last piece of 'basics' it needs to do. everything else is a plus. Biggest gripe I have heard is training. Thus, learning curve is great for some people. If you show up for their training having looked very little at the product, you will be overwhelmed. (They do have a video they 'require' you to look at beforehand) all in all I am very satisfied, but heck, that is the pension system I learned on so I know a lot of ins and outs, what to watch out for, etc. Used to work as a service tech for the Pentabs systems (Quantechs is the Windows version of that program) so, maybe you can't take my word for it, I am prejudice in favor of it. If you go with the product, make sure to join a user's group, they can be very helpful. Customizing reports is actually fairly easy, and this comes from someone who knows nothing about Crystal! maybe I shouldn't say any more, but feel free to contact me if you have some specific questions about system features that you would rather have answered from a user rather than a salesperson! (Pension type questions, not hardware)
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The next meeting is scheduled for April 30 (Friday) in Atlanta. Contact Maggie Heffernan for more details (770) 641-1429 fax (770) 594-9631 or email mheffernan@afg-online.com Robert Richter from Corbel will give a presentation on documents Beverly Jackson will talk about Auto-Doc. discussion on Qtech 5.0 enhancements. (I am a beta tester) Meeting is Not limited to Southern User Group members only. again, contact Maggie for details. My promise was to give away some customized crystal reports- certificate by fund with pie chart allocation report enrollment form (Projects out to retirement assuming 1,3,5,7,10% deferrals at 8.5% interest) and what happens if you wait 5 years heck, I'll bring a bunch of the reports. see what you can use (Sorry, gotta show up to get these) looks like I will get in Thursday evening if you want to throw out ideas on the system. hope to see you there.
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the document should provide guidence. for example 1.the company shall allocate 3% to all eligible employees. if there is insuufficient contribution to cover, the contributions shall be pro rata based on compensation. 2.if there are additionals $, an additional contrib up to 3% shall be allocated to all participants based on compensation in excess of 60,000. 3. if there are any remaining contributions, they shall be allocated to all participants on compensation in excess of 80,000 obviously, your document may be worded slightly differently, but should be somewhat similar. (Hopefully it is not written like a money purchase, 3% will be alloacted on this comp, 6% on this, 23% on this comp. If so, you have problems, though you could probably argue 'its a profit sharing plan, the formula was written incorrectly - in fact its nonsensical with the type of plan. what was intended was ... (Don't know if you could win that arguement, but...) anyway, assuming plan is truly discretionary, with a 3 step formula, then you could certainly allocate just 3%. I have seen some formulas which would say 3% < 60000 6% 60000 to 80000 23% > 80000 if insufficient contribution made, then the %s will be adjusted prorata. assuming plan is top heavy, you can get by with 3% across the board. Same argument, I put in 0 contribution. Oh, plan is top heavy, now I have to contribute an additional 3%.
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Administrative expenses can be paid from trust assets. what can not be done is to charge an individual a fee for processing a distribution. That could be considered as part of the admin expense and charged across the board. in other words, if an ee quits with a $50 balance and you charge $50 to process distributions, you can't charge him the $50, thus resulting in a zero distribution. the $50 is across the board.
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we are still at 5.7%. This question comes up every year. I forget the reason why we use 5.7 instead of the 6.2, but I guess that's another story.
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HCEs, prior year data, eligible compensation questions for ADP test
Tom Poje replied to a topic in 401(k) Plans
Make sure your document allows you to use comp from DOP. some do not,(why, why, o why are there documents written that stupid) and you get stuck with a lower deferral %! -
there is nothing in concrete. The Erisa Outline Book notes that some (and I stress some) IRS personal will use 3% or less. It becomes more of a facts and circumstances. (I imagine if bonuses are excluded and the hce gets no bunuses, then you fail at 3%. But if the boss had a bonus, then 3% would be ok. That would be my best guesstimate)
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who is charging the fee? Supposedly you are not allowed to charge a fee to the participant for distributions. Be careful on this! If it is individually allocated accounts, I realize there are fees assessed by the investment house, but that is a different type of fee. In that case, the 'fee' is more like a loss, hence the distribution is after the distribution. In either caes, I can't imaging the 1099 for more than what the actual distribution is.
